Saxon Aerial Drone Services

Leesburg, VA

November 8 th , 2015
U.S. Department of Transportation, Docket Operations We st Building Ground Floor, Room W 12
- 140 1200 New Jersey Ave SE Wa shington, DC 20590

SUBJECT : Section 333 of FMRA 2012 sUAS Exemption Request

Dear Sir/Madam, Wi th safety as our first priority, p ursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Saxon Aerial D rone Services , a Virginia based limited liability company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and surveys for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. T he requested exemption would permit Saxon Aerial Drone Services to pursue its commercial interests in providing services to consumers interested in aerial data capture using sUAS in the following areas:

• Infrastructure Inspections

• Real Estate & W atercraft Photography & Videography

• Agricultural Surveying and Data Collection

• sUAS Operator Training

• Product Demonstration , including Entertainment

• Research and Development Regulations from which the exemption is requested:

 14 C.F.R. Part 21
 14 C.F.R. 45.23(b)  14 C.F.R. 61.113(a) and (b)
 14 C.F.R. 91.7(a)  14 C.F.R. 91.9(b) (2)
 14 C.F.R. 91.109 14 C.F.R. 91.119

 14 C.F.R. 91.121
 14 C.F.R. 91.151(a)  14 C.F.R. 91.203(a) and (b)
 14 C.F.R. 91.205(b)  14 C.F.R. 91.215
 14 C.F.R. (91.401

– 91.417) Weare petitioning for exemption to enable Saxon Aerial Drone Services to operate the following s UAS:

 DJI Inspire 1  DJI Phantom 2 and 3  PrecisionH awk Lancaster  3D Robotics Solo  3D Robotics X8  Aeryon Labs Sky Ranger Note: User Manuals for the sUAS propose d in this petition are not included. All of the sUAS have been approved in previous Section 333 exemptions and it seemed redundant to attach additional manuals . The most recent versions are available on the vendor websites. Saxon Aerial Drone Services does not currently own each of the sUAS listed above, but anticipates purchasing them in accordance to a pre
- set business plan. Saxon Aerial Drone Service pilots place an extraordinary emphasis on safety. It is our first prior ity and crucial to our business as well as the right thing to do. Saxon Aerial Drone Services at all times will respect the space and privacy of citizens and property while keeping our skies safe. Werespectfully request, without delay, an exemption un der Section 333 to enable Saxon Aerial Drone Services to operate safe, low
- risk commercial sUAS operations for the activities stated. Sincerely,

Ann Carswell Legal and Insurance Advisor Saxon Aerial Drone Services info @saxonaerial.com 1513 Artillery Terrace NE Leesburg, VA 20176**EXEMPTION REQUESTS A ND EQUIVA**  **LENT LEVEL OF SA FETY** 

Saxon Aerial Drone Services requests an exemption from the following regulations as we ll as any additional regulations that may technically apply to the operation of the sUAS System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. W hile the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an exper imental certificate be issued for the DJI Inspire 1, Aeryon Labs Sky Ranger, Zero
-Tech High One and 3D Robotics AERO sUAS under either or both of the following provisions: 21.191 Experimental certificates Experimental certificates are issued for the foll owing purposes: (a) Research and development Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of foam, carbon fiber, a nd/or plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Sub part H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 14 CFR 45.23 Display of marks; general and 45.29 Size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word “EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cab in, cockpit, or pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. W e propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard disc ussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the groundstation, the banner should be visible to anyone that observes the aircraft and chooses to

investigate its point of origin. 14 CFR 61.113 Private pilot privileges and lim itations: Pilot in Command and 61.133 Commercial pilot privileges and limitations The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 CFR 91.9 Ci vil aircraft flight manual, marking, and placard requirements This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. W e assume that the intent of this requirement is to ensure that flig ht manual information is available to the aircrew while operating the aircraft. W e request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground
based control station consists of a small hand
- held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. W ith both student and instructor having "hands
- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. 14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photog raphy or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre
- planned has bee n performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the s UAS, the hazard to perso ns, vehicles and structures is minimal compared to manned aircraft, wh ich should be considered in granting the exemption.14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising

altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 500 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff p oint is transmitted via radio from the sUAS on
- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight in an airplane under day
-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Wefeel the intention of this paragraph is to provide an energy reserve as a safety b uffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12
-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of i ntended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. W e request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". W e also request exemptio n from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpi t entrance so that it is legible to passengers or crew." W ith our largest vehicle, the 3D Robotics AERO, at a maximum gross weight of 13 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passeng ers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co
- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 14 CFR Subpart E (91.401
- 91.417)
- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including com pliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after every two hours of flight. Maint enance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on
- board computer. All other maintenance will be performed by the manufacturer or their desi gnated repair facility. The PIC will document work performed in accordance with 91.417. W e feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.