KL3 3010423.3 UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

__________________________________________ ) Petition for Exemption ) Pursuant to Pub. Law 112-95 § 333 ) and 14 CFR Part 11 ) concerning Unmanned Aircraft Systems ) Used for Search and Rescue Purposes ) and Certificate of Authorization Request ) ) __________________________________________)

PETITION OF RPSEARCH SERVICES, INC. FOR REGULATORY EXEMPTION AND CERTIFICATE OF AUTHORIZATION REQUEST

Dated: April 30, 2015 Filed Electronically

Please address all communications with respect to this Petition to:

Brendan M. Schulman Kramer Levin Naftalis & Frankel LLP 1177 Avenue of the Americas New York, NY 10036 Phone: (212) 715-9247 Fax: (212) 715-8220 Counsel for Petitioner RPSearch Services, Inc. Email: BSchulman@KramerLevin.com2 I. Introduction: Search and Rescue
According to the FBI’s National Crime Inform ation Center, an average of 1,700 people are reported missing each day in the United States. 1 Many of them are at grave risk in dangerous situations: lost children, stranded hikers, mar ooned boaters, mentally ill, psychologically troubled or intoxicated individuals, or victims of abduction or other crimes. The sheer number of missing people, combined with the challenges of search ing in the vast open areas of our country’s geography, overwhelm community groups, families, emergency responders and taxpayer-funded resources. Missing persons have been, and will con tinue to be, effectively, efficiently, and safely located by aerial imagery of locations of inte rest, which provides invaluable information to searchers on the ground.
Petitioner RPSearch Services, Inc. (“RPSS”) respectfully submits this Petition for Exemption from regulations the FAA considers a pplicable to the civ il operation of unmanned aircraft systems, and that the FAA considered ne cessary for an operator to be exempted from, for operations concerning search and rescue. 2 The benefits of these opera tions to the public and to the nation are unquestionable, and safety is assu red when they are conducted under the proposed procedures herein by an experien ced and knowledgeable operator.

1 See NCIC Missing Person and Unidentified Person Statistics for 2013 , http://www.fbi.gov/aboutus/cjis/ncic/ncic-missing- person-and-unidentified-pe rson-statistics-for-2013 (last visited May 20, 2014).

2 Petitioner takes no position with respect to which federa l aviation regulations, if any, legally apply to the proposed operations.3 II. The Identity and Interests of the Petitioner Petitioner RPSearch Services, Inc. has been a pioneer in the implementation of protocols and operating procedures for the us e of unmanned aircraft systems fo r search and rescue purposes. Its current designated pilot in command, Eugene Robinson, was the first person to successfully obtain a certificate of waiver or authorization (COA) on behalf of a public operator, (the Wimberly, Texas Fire Deparment), in 2008. Mr . Robinson has lectured across the country concerning the safe and responsible use of UAS during search and resc ue operations, including appropriate coordination with inci dent commanders and local aut horities. Mr. Robinson has also served as the designated pilot- in-command for the National Instit ute for Standards and Technology in its program to use UAS to study wildfires, flying over 70 successful missions without incident under that agency’s public aircraft COA.
In September, 2014, the FAA also granted Mr . Robinson an emergency COA via NIST to use its UAS in the search for a missing person in Plano, TX. More recently, Mr. Robinson was granted an emergency COA through the Wimberly Fire Department to conduct a missing-person search operation using a UAS in Baytown, Texa s for two missing teenagers. Mr. Robinson has trained law enforcement and first responders in UAS search and rescue procedures, and has successfully used UAS to locate a nd rescue missing persons, alive, in a foreign country. In short, petitioner is a responsible, successful, safe ty-conscious UAS operator who will conduct the proposed operations within the parameters set ou t in the operating proce dures and the grant of exemption that is requested.

The name and address of the Petitioner is:4 RPSearch Services, Inc. 290 Brunson Lane Wimberly, TX 78676 Email: texhills@verizon.net Petitoner requests that communications also be directed to its counsel: Brendan M. Schulman, Esq. Kramer Levin Naftalis & Frankel LLP 1177 Avenue of the Americas New York, NY 10036 Phone (212) 715-9247 Fax (212) 715-8220 Email: BSchulman@KramerLevin.com III. RPSearch’s Request Would be in the Pub lic Interest and Benefit the Public as a Whole The benefit to the public interest of R PSearch’s request is unquestionable. Thousands of people go missing each day, and the subs equent search that is conducted for those whose disappearance raise concerns overwhelms ta xpayer and community resources. The use of manned aircraft is in many instances more expens ive, and more dangerous, than the operations proposed herein. Thus, the operations are of e normous public benefit a nd, as set out herein, present at least an equivalent leve l of safety under 14 CFR part 11.

IV. The Unmanned Aircraft Systems Petitioner intends to operat e two models in connection with the operations proposed herein, at or below 400 feet a bove ground level. The following is a summary of the technical specifications and other considerations of each UAS. Additional documentation from each manufacturer is being submitted as together with this Petition.
Configuration 1 Spectra5 Aircraft Type : Spectra AP flying wing Manufacturer : RPFlightSystems, Inc. Construction : EPS foam/ABS/composite Aircraft Empty Weight : 3.3 lbs. Aircraft RTF AUW : 4.5 – 5.5 lbs. Propulsion : Electric sing le propellorr Power : 5.4AH lithium polymer flight batteries Onboard electronics : Manual control system RX, flight control system Optics : (1) still imager, up to (2) video Launch Type : Hand launch Landing Type : Skid, net retrieval Launch Speed : 15 mph Cruise Speed : 25-34 mph (@ 75% power) Cruise Speed : 25 mph (@ 50% power) Landing Speed : 12 mph Stall : 12 – 18mph (depending upon wing loading) VNE : 75 mph Duration : 1 hour (5.4Ah battery, 50% power) Construction: The Spectra is constructed of foam (expanded polystyrene) wings with internal bracing. Center section may include carbon fiber skeleton and outer skin of vacuformed ABS. Propulsion: Aircraft utilize brushless, three ph ase, AC motors. They utilize a switching electronic speed control to provide throttle management. Hazard mitigation The Spectra is designed to collect imag ery utilizing a lightweight and relatively slow airframe. This reduces the potential for injury by reducing the mass that can be delivered in a small area. These UAS are considered “frangible” in that they will come apart on impact without concentrati ng force in any vector. They do not use internal combustion motors and do not car ry any flammable liquids for operation. The aircraft utilizes a redunda nt communications fail safe so that that if either the command over-ride link or the telemetry fa ils, the UAS will abort the mission and return to the launch area.6 Demonstrated Capabilities and Prior FAA Approvals The Spectra was one of the first UAS to re ceive authorization vi a a Certificate of Authorization (COA) granted by the FAA for use by a public entity (Hays County, Texas Emergency Management Office), in 2008. See FAA COA 2007-AHQ-25- COA. The COA was renewed a total of two mo re times during its tenure with the EMO. See 2009-CSA-2-COA and 2010-CSA-28-COA. Additionally, on behalf of the Emergency Service District #4 of Hays County, Petitioner’s PIC assisted the Wimberly Fire department in applying for and receiving a COA for Spectra ope rations in December of 2014. See 2014-CSA-143- COA.
Radio Frequency Spectrum The Spectra utilizes an FCC-approved co mmand-and-control systems and telemetry downlink operating on the 900 MHz and 2.4 GHz bands.
Configuration 2 DJI Inspire 1

Aircraft Type : Multi-rotor, Inspire 1 Manufacturer : DJI Construction : Carbon fiber, plastic, aluminum Aircraft Empty Weight : 3.3 lbs. Aircraft RTF AUW : 4.5 – 5.5 lbs. Propulsion : Electric – four two blade propellers Power : 5.4AH lithium polymer flight batteries Onboard electronics : Manual control system RX, flight control system Optics : (1) still imager, up to (1) video video, 2.4/5.8Ghz Lightbridge. Launch Type : VTOL Landing Type : VTOL Launch Speed : 15 mph vertical7 Speed Evelope : 15-35 mph Cruise Speed : 0-25 mph Landing Speed : 0 mph Stall : N/A VNE : N/A Duration : 15 minutes (typical) Propulsion The Inapire 1 utilizes (4) four brushless, three phase, AC moto rs. These utilize a switching electronic speed control to provide throttle management. Hazard mitigation The Inspire 1 is designed to collect its im agery utilizing VTOL capabilities where a fixed wing airplane would have difficulties in either take off or landing. The Inspire 1 is equipped with a return to launc h area (RTH) feature. The Inspire 1 does not use internal combustion motors for propulsion and does not carry any flammable liquids for operation. Risk is fu rther mitigated by the Inspire 1's ability to stay aloft while moving slowly, or to hover in place, unlike a fixed-wing UA which must continue late ral motion during flight. Prior FAA Approvals The DJI Inspire 1 has been approved for use by the FAA in connection with an exemption for aerial photography for the motion picture and television industry. See Exemption Grant No. 11279 (April 1, 2015). Radio Frequency Spectrum The Inspire 1 utilizes FCC-approved command-and-control and video systems operating on the 5.8 GHz and 2.4 GHz bands. V. Flight Safety Operations and Procedures Petitioner proposes to operate each UAS fo r the purposes indicated herein pursuant to its Flight Safety Operations and Procedur es (“FSOP”). The FSOP was developed over the course of nearly a decade, and is being submitted t ogether with this Petition. The FSOP consists of procedures and standards relati ng to Personnel Qualifications, Flight Operations and Mission Profiles, Launch and Landing Zones, Preflight, Ta keoff and Post-flight Checklists, In-flight Communications, and NIMS (National Incident Mana gement System) / IC Interface, all developed8 with an emphasis on the safety of UAS operations . The operation will be conducted by the pilot in command (“PIC”) who will maintain visual contact with the UAS during its flight within visual line of sight, while the UAS captures images of the ground for analysis. The UAS will be operated at or below a speed of 35 miles per hour, in Class G airspace at least 5 miles from airports (unless otherwise specifically authorized by FAA). Other operational para meters and various measures taken to ensure public safety are set out in the FSOP.

VI. Summary of Exemptions Sought RPSearch seeks exemption from the follo wing regulations, to the extent the FAA deems them applicable to the operation of civil UAS for the indicated purposes:

14 CFR Part 21 14 CFR Part 36 14 CFR 45.23(b) 14 CFR 61.3 14 CFR 61.23(a) and (c) 14 CFR 61.101 14 CFR 61.113 (a) & (b) 14 CFR 61.315 14 CFR. 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.105 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2); and 14 CPR 91.417 (a) & (b)9 VII. The Specific Exemptions Sought and Reasons A. 14 CFR Part 21 and 14 CFR Part 36 Petitioner seeks relief from 14 CFR part 21 concerning airworthiness certificates, as well as any associated noise test ing requirements of part 36, with respect to the UAS identified in Section IV. As set out herein, the size, weight, speed, operational capability, visual line-of-sight operation, and intended operating area of these UAS meet the conditions of FMRA Section 333. Moreover, the proposed operations, conducted pursua nt to the RPSS FSOP, present an equivalent level of safety or better. An exemption ought to be granted or, in the alternative, a finding made that relief from parts 21 and 36 are not neces sary for Petitioner’s intended operation. ( See, e.g. , Grant of Exemption No. 11282, Docket. No. FAA- 2014-0977 (April 6, 2015), finding that such an exemption is “not necessary.”)

B. 14 CFR 45.23(b) Petitioner seeks relief from 14 CFR 45.23(b) concerning ai rcraft markings, to the extent such relief is necessary. Given the size of the UAS, its operati on within visual line of sight of the operator, and other factors, such an exemption is warranted. Petitioner will, if required, mark each UAS with the word “R ESTRICTED” in lettering as larg e as practicable. However, Petitioner notes that because its UAS’s will not be certificated under § 21.185, such marking is not actually required, and therefore Pe titioner alternatively requests a finding confirming same.10 C. 14 CFR 61.23(a) & (c), 14 CFR 61.101, 14 CFR 61.113 (a) & (b), and 14 CFR 61.315 Petitioner seeks relief from 14 CFR 6 1.101 concerning limitations on recreational pilot privileges, 14 CFR 61.113(a) and (b) concerni ng limitations on private pilot privileges, and 14 CFR 61.315 concerning limitations on sport pilot pr ivileges, together with an exemption from 14 CFR 61.23(a) concerning medical certificates. The RPSS FSOP establishes a level of safety exceeded by that provided by a commercial pilo t’s certificate in the ope ration of a passenger aircraft. The UAS intended to be operated do not carry any person and therefore present an equivalent or better level of safety compared to manne d aircraft operations. Although RPSS’s current FSOP does not strictly requi re a pilot certificate, Petitione r’s current design ated pilot in command, Mr. Robinson, holds a private pilot’ s certificate, and Petit ioner will accept as a condition of an exemption that the operator hold either a recreationa l, sport pilot or private pilot certificate. With respect to medical certificat ion, 14 CFR 61.23(a), Petitioner proposes that the PIC hold either a current FAA airman medical certif icate or a valid U.S. driver’s license issued by a state, the District of Columb ia, Puerto Rico, a territory, a po ssession, or the Federal government.

D. 14 CFR 91.7(a) Petitioner seeks relief from 14 CFR 91.7(a) concerning civil aircraft airworthiness. Given the size of the UAS, its operation within vi sual line of sight of the operator, and other factors providing an equivalent level of safety, such an exem ption is warranted. Moreover, because petitioner proposes that no airworthiness cer tificate be issued for the UASs to be operated under this exemption, § 91.7(a) is inapplicable. Ther efore, in the alternativ e, Petitioner requests a determination that an exemption from § 91.7(a) is not necessary.11 E. 14 CFR 91.9(b)(2) Petitioner seeks relief from 14 CFR 9 1.91(b)(2) concerning flight manuals and placard requirements. Because all persons involv ed in the operation will be on the ground, not on board the UAS, such an exemption is clearly wa rranted. Moreover, the FAA determined in an August 8, 2014 legal interpretation that keeping such documentati on at the control station, as Petitioner intends to, meets the re quirements under these regulations and therefore an exemption is not necessary. See Memorandum from Mark. W. Bury to Jo hn Duncan, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station” (August 8, 2014). 3

F. 14 CFR 91.103 Petitioner seeks relief from 14 CFR 91.103 concerning preflight action, and particularly that portion of th e regulation concerning FAA-approve d flight manuals (which do not exist). Petitioners’ pre-flight actions concerning UAS operations ar e set out in its FSOP, reflect that the pilot in command will “become familiar with all available info rmation” concerning the proposed flight, and therefore present an equivalent or better level of safet y. Given the size of the UAS, its operation within visual line of sight of th e operator, and other factors, such an exemption is warranted. Alternatively, given that Petitio ner will account for all relevant site-specific conditions in its preflight procedures, Petitioner asks for a finding that an exemption from § 91.103 is not necessary for the intended operation.

3 A vailable at https://www.faa.gov/about/office_org/headquarters_o ffices/agc/pol_adjudication/agc200/interpretations /data/interps/2014/Duncan-AFS-1-2%20-% 20%282014%29%20Legal%20Interpretation.pdf12 G. 14 CFR 91.105 Petitioner seeks relief from 14 CFR 9 1.105 concerning “Flight crewmembers at stations” and seat belt/harness fastening. Because there is no crew on board the UAS, and persons involved in the operations will be present at the UAS ground station pursuant to the FSOP, Petitioner believes that such an exemption is warranted due to Petiti oner’s FSOP providing an equivalent level of safety, or al ternatively that an exemption is not necessary for the operation. Although it does not appear that the FAA has addressed § 91.105 in various Section 333 UAS exemptions granted to date, we note that § 91.105 is listed in the FAA’s Public Guidance document as a regulation from which an exempti on may be required (Rev. 9/25/2014 at page 7). 4 Petitioner therefore requests either an exemption or an acknowledgement that an exemption is not
necessary.

H. 14 CFR 91.109 Petitioner seeks relief fr om 14 CFR 91.109 concerning f light instruction and dual controls. Petitioner will evaluate the qualificatio ns of its PICs based on their experience and capabilities with the UAS to be operated, as set out in the FSOP Section I (“Personnel Qualifications”). Moreover, as each PIC will have previously been qualified by the FAA as a certificated recreational, sport, or private pilot, the operations proposed herein may be conducted without an exemption from § 91.109 being required. Thus, Petitioner requests either an exemption or confirmation that none is required.

4 Available at https://www.faa.gov/uas/legislative_programs/s ection_333/how_to_file_a_petition/media/section333_p ublic_guidance.pdf ).13 I. 14 CFR 91.119 Petitioner seeks relief from 14 CFR 9 1.119 concerning minimum safe altitudes. Each UAS will be operated no higher than 400 f eet above ground level, and, under the FSOP, safe alternative landing and “abort site” locations will be selected in adva nce of each flight, in compliance with 14 CFR 91.119(a) which pe rmits operations “[a]nywhere.”
With respect to the balance of § 91.119 concerning minimum altitudes, Petitioner proposes to conduct operations at least 50 feet from non-essential or non-participating persons, and prior to each operation the PIC will make a safe ty assessment of the risk of operating within the proximity of structures, vehicles and vessels. Petitioner believes that given the size, weight and speed of the UAS to be operated, these parame ters in the FSOP present an equivalent level of safety compared to the 500 foot minimum safe a ltitude of a manned aircraft set out in § 91.119(c).
Petitioner is aware that in prior UAS exem ption grants, the FAA has included as an operating condition a 500-foot mi nimum distance separation from uninvolved persons. Petitioner hereby requests the FAA either to raise the maximum operational altitude under RPSS’s proposed exemption to 500 feet above ground leve l (from the typical 400 feet), or, preferably , to reduce the required distance separation from uninvolved pers ons to no greater than 400 feet, so that Petitioner's UAS, when in opera tion, may pass above persons in the operationa l area. (In Petitioner’s experience, the requested minimum se paration parameter of 50 feet provides a very high level of safety.) In consid eration of the benefits of, and st rong public interest in, the proposed operations, which are potentially life-saving, this request ought to be granted, and would not adversely affect safety.14 J. 14 CFR 91.121 Petitioner seeks relief from 14 CFR 91.121 concerning altimeter settings. Petitioner's UAS will utilize a GPS altitude read-out, set to zero at the ground elevation of the departure location, thus indicati ng to the operator the operational altitude in feet above ground level. This approach will provide an equivalent level of safety.

K. 14 CFR 91.151 Petitioner seeks relief from 14 CFR 9 1.151 concerning fuel requirements. The Petitioner's Configuration 1 uses the Spectra UAS airplane equipped with 5.4 Ah lithium polymer flight batteries. Petitioner's flight duration unde r its FSOP is 30 minutes or less, which results in approximately 50% of the battery power remaining at landing. Petitioner' s Configuration 2 uses the DJI Inspire 1 battery-powered multi-rotor-craft which has an automated readout of remaining battery power at the ground stati on and will automatically initiate a return to launch and landing when the battery is low. Petitioner will land the Inspire 1 when the battery is at or above 50% capacity. In both configurations, an equivalent level of safety is achieved, in particular because each UAS is operated within visual line of sight, can be landed within moments of a low-battery condition, and the UAS never has the need to travel any significant distance to an alternate airport or landing area.

L. 14 CFR 91.203(a) and (b) Petitioner seeks relief from 14 CFR 9 1.203(a) and (b) concerning airworthiness certificates. Each of the UAS to be operated weighs under 6 pounds, and will be operated within visual line of sight, pursuant to the RPSS FSOP, by a knowledgeable certificated operator. An15 exemption from airworthiness cert ification is warranted pursuan t to Section 333 of FMRA in consideration of the weight, size , speed, and operational capabilities of the Petitioner's UAS.

M. 14 CFR 91.405(a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2); and 14 CPR 91.417 (a) & (b) Petitioner seeks relief from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417 (a) and (b), concerning maintenance inspections. Petitioner proposes to maintain each UAS in accordance with the manufacturer's sugge sted maintenance procedures, and to conduct preflight inspections in accordance with the FSO P for each operation. This approach provides an equivalent level of safety with respect to th e operational condition of the UAS. Moreover, the UAS are not contemplated to have an airworth iness certificate, and th erefore no exemption is needed with respect to maintenance requireme nts arising from airworthiness certificates.

N. Other Exemptions Petitioner requests relief from any other federal aviation regu lation that the FAA deems applicable to and preclusive of the propos ed UAS search and rescue operations in the absence of such an exemption.

VIII. Request for Blanket COA Petitioner hereby requests a blanket, nationwide Certificate of Waiver or Authorization for airspace use within Class G ai rspace, at or below 400 feet. The need for a blanket COA for Petitioner's proposed operation (or an exemption from the need to obtain one) is self-evident. Unlike other pre-planned small UAS operations (such as aerial cinematography, agriculture, or industrial inspection), search and rescue require s an operational response on little or16 no notice, and minutes can literally make a difference between life and death. We understand that the typical holder of a Section 333 exemption waits approximately three week s in order to receive a COA after the request is made, a timeframe that obviously is unw orkable for search and rescue operations.
FMRA Section 333 directly contemplates that a certificate of waiver or authorization is not necessa rily required for the operation of ci vil UAS. It provides that in making a Section 333 determination concerning operation of unmanned aircraft systems, “the Secretary shall determine . . . . whether a certificate of waiver , certificate of authoriz ation, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems.” FMRA Section 3 33(b) (emphasis added). By using the word “whether,” Congress specifically contemplated th at a COA would not necessarily be required for any civil operation. Therefore, the FAA has the authority to either exempt Petitioner from the need to obtain a COA, or to issue to Petitione r a standing blanket COA th at is suited for the contemplated search and rescue operations.
In the past year, Petitioner's PIC Eugene Robinson has twice had the experience of seeking an emergency COA from the FAA. A lthough the FAA's staff was prompt and courteous each time, the emergency COA took many hours to i ssue, resulting in the loss of more than an entire operational day. (UAS f lights are conducted during daylight hours only, thus a delay of even an hour or two can cause the aerial search to be delayed 12 hours until dawn the next day).

As an illustration of the difficulties inhe rent in trying to obtain specific COA approval for each search and rescue operation on an expedited basis, Petitioner sets out herein the details of a recent experience involving its PIC Eugene Robinson. In February 2015, Mr.17 Robinson was contacted in connection with a reque sted search for two mi ssing teenagers in the Baytown, Texas area and the proposition that the UAS operated under COA by the Wimberly Fire Department be used to assist. Mr. Robinson contacted Dallas Flight Standards District Office at 2130 hrs Central Time on February 26 to request emergency COA approval via an amendment to the existing Wimberly Fire Department UAS COA. He was referred to FAA Operations Center in Washington, D.C. The representati ve at Operations Center, in tu rn, referred Mr. Robinson to the FAA UAS Intergration Offi ce (UAIO). The representative at UAIO indicated that Air Traffic Organization and Flight Standards would need to be contacted fo r approval. At 2240 hrs Central Time, Mr. Robinson was told by the UAIO repr esentative that nothing more could be done concerning approval until the next morning, thus precluding a planned roll-out for an operation at dawn.
At 0715 hrs on February 27, Ft. Worth FSDO contact Mr . Robinson and advised that documentation would be required from the fi re department whose COA would be amended for the emergency. That documentation was provided to FAA 15 minutes later, at 0730 hrs. Mr. Robinson did not receive word back from UAIO until 1445 hrs that the emergency COA would be approved. Mr. Robinson then began the proce ss of initiating a NOTAM, which involved various discussions with Houston TRAC ON, which discussions continue d into the following morning, concluding at 0835 hrs.
The actual search operation using the UAS commenced at 1025 hrs Central Time on February 28. Thus, rather than a planned search start time at 0600 hrs on the morning of February 27, the operation was delayed over 28 hours, until mid-morning on February 28 , due to the protracted COA approval process, and even though it was acknowledged by the FAA that the18 situation was an emergency. This does not appear to be an atypical timeframe for the process. In a prior emergency COA approval concerning a missing- persons search conducte d in Plano Texas in September 2014, it similarly took approximately 22 hours for the emergency COA to be issued after the request was made by Mr. Robinson. Petit ioner respectfully submits that a standing COA granted for search and rescue operations is overw helmingly in the public interest because it will enable life-saving operations to commence sooner , and reduce the administrative burden on the FAA itself.
The FAA has recently indicated that holde rs of UAS exemptions under Section 333 are now granted a “blanket” COA for any operation up to 200 feet AGL. See March 20, 2015 Memorandum from Elizabeth L. Ray to Terry Biggio, “Small Unmanned Aircraft Systems Operations in the National Airspace System.” Ho wever, this streamlined (or so-called “blanket”) COA apparently still requires the operator to issue a Notice to Airmen (NOTAM) “at least 24 hours prior to the proposed operation.” Id . In many instances Petiti oner expects to be called upon with less than 24 hours’ notice. Petitioner requests that its blanke t COA issued in connection with the requested exemption require only that Petit ioner issue a NOTAM “as far in advance of operations as practicable,” with no specific minimum notice provision.
Additionally, Petitioner's FSOP and equipmen t are optimized for search and rescue from an operational altitude of just below 400 f eet AGL. The 200 feet AGL in the “blanket” COA is too low an altitude for these operations. Wit hout a streamlined COA at an altitude higher than 200 feet, Petitioner will be waiting days (or weeks) fo r a civil COA just to be able to operate at a modestly higher altitude, rendering the exemption potentially unworkable. Petitioner requests a streamlined COA for the highest altitude th e FAA will permit, ideally 400 feet AGL.19 An equivalent level of safety is esta blished for these blanket COA parameters because, currently, operations of this kind are permitted by FAA by recreational model aircraft operators without any COA or NOTAM requireme nts. Moreover, Petitioner's operations are subject to NIMS protocols and coordination w ith Incident Command and other first responders, who will be aware of air traffic in the area. Therefore, unlike commercial UAS operations undertaken for industrial purposes, ad ded layers of safety exist. All of these fact ors support the issuance of a streamlined or “blanket” COA for Pe titioner RPSearch Services in Class G airspace up to 400 feet above ground level, or a determin ation pursuant to FMRA Section 333(b) that a COA is not required for Petitioner’ s search and rescue operations.

IX. A Summary That Can Be Published In The Federal Register: The following is a summary that may be included in the Federal Register, should the FAA determine that publication of such a summary is required:
Petitioner RPSearch Services, Inc. seeks an exemption pursuant to Pub. L. 95-112 Section 333 and part 11 for the operation of unmanned airc raft systems for purposes of search and rescue. The benefit to th e public interest of such an exemption is unquestionable. Thousands of people go missing each day, and the subsequent search overwhelms taxpayer and community resources. The use of manne d aircraft is in many instances more expensive, and more dangerous, than the operatio ns proposed herein. Thus, the operations are of enormous public benefit. Petitioner’s operations will be conducted at or below 400 feet above ground level, within the visual line of sight of the operator, who will be a certificated airman with a sport, recreational or private pilot’s certificate, and pursuant to a detailed Flight Safety Operations and Procedures manual. Petitioner seeks exemption from 14 CFR Part 21, 14 CFR Part 36, 14 CFR 45.23(b), 14 CFR 61.3, 14 CFR 61.23(a) & (c), 14 CFR 61.101, 14 CFR 61.113 (a) & (b), 14 CFR 61.315, 14 CFR. 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CF R 91.151 (a), 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a ) (1), 14 CFR 91.409 (a) (2 ).; and 14 CPR 91.417 (a) & (b).20 Dated: April 30, 2015
Respectfully submitted,

Brendan M. Schulman Kramer Levin Naftalis & Frankel LLP 1177 Avenue of the Americas New York, NY 10036 Tel. (212) 715-9247 Fax (212) 715-8220 BSchulman@KramerLevin.com Counsel for Petitioner
Enclosures (filed electronically):
1. Flight Safety Operations and Procedures 2. Spectra technical specifications sheet 3. DJI Inspire 1 User Manual, Safety Guid elines, Maintenance Manual, and Battery Safety Information