## Fish Finders Inc. UAS Oceanic Fish Surveillance , Tracking, and Photography (A subsidiary of SSJ Global Innovations, LLC. )

**July 29, 2015** Docket Management Facility U.S. Department of Transportation Docket Management System 1200 New Jersey Ave SE Washington D.C. 20509
**RE: Exemption Request, Section 333 of the 2012**  **FAA Reform Act of the Federal Aviation Regulations 14 CFR.** 
Dear Sir/Madam: Fish Finders Inc. is respectfully seeking a request for exemption that would lead to a safe an d legal entry into the NAS under Section 333 of the FAA Modernization and Reform Act of 2012. A granted exemption would allow us to obtain a COA, if required, to conduct commercial operations and training described in this letter. Furthermore, it would e nhance airspace safetyand efficiency in our community by offe ring affordable aerial surveillance, imagery and tracking,

real

- time data and coordinates, and detour and mitigate unsafe and illegal entrance into the NAS by untrained and unlicensed UAS users. For the commercial fishermen, the two biggest problems are: 1) wasted fuel and operational costs searching for the fish, and 2) the EPA and marine environmental issues that constantly plague the fishing industry. My company can o ffer a solution that will benefit the fishermen , and the fishing industry, by increasing their profit margin, reduce their operational costs , and reduce the amount of harmful emissions that are being disbursed into the air , and into the offshore waters by the fishing boats. Like any new business, one must build confidence with its consumer before a financial agreement can be decided. Once the consumer’s trust is earned, the agreement will be easier, especially when presented with a win

- win situation. I expect my first y ear to be over $250,000.00 dollars, and my second year to gross over $500,000.00 dollars. Once my system has proven itself within the first year, my client base will grow exponentially.

**FFI UAS Platforms** 1. Operations will be conducted long

- range, over wate r using the Aeroval Flexrotor, fully equipped for all

- weather, long

- range, surveillance, and tracking. 2. PIC(s) will be trained on, and operate by strict conditions defined by the Safety Program of the Academy of Model Aeronautics, attached flight manuals, a nd FFI (Note that Fish Finders Inc. will herein and after be referred to as “FFI.”) Training program. Inspections will be conducted before and after each flight according to Flexrotor’s platform’s respective checklist and Annex. 3. Maintenance and repairs wi ll be performed following Flexrotor’s user manual, at minimum, quarterly, or upon pre

- or post -flight inspections. 4. All equipment, frequencies, and payloads comply with FCC requirements and can be furnished upon request.
**FFI Pilot in Command (PIC)** 1. FFI has developed a PIC training program that can be furnished upon request. Refer to Annex B for further information. 2. All PIC(s) will obtain and maintain First Aid and CPR certification. They will be able to provide and apply basic aid in the mishap that an UAS collides with personnel.**Operation of UAS**

1. FFI will conduct long

- range aerial surveillance and tracking for the general public, prim arily the commercial fishermen. 2. Because the Flexrotor is an all

- weather vehicle, equipped with IR and long

- range capabilit y (55nm), it will be launched from a floating platform, as well as from land. The Flexrotor’s maximum operating speed will not exceed 158km/h ( 86 knots).Although the Flexrotor can reach and sustain an altitude of FL280, the primary altitude for operation w ill be 1,000 feet or less. The Flexrotor can sustain winds greater than 25 knots, but will only be launched from land during those times. All PIC(s) are equipped with the Kestrel 4500 to not only

measure the current site wind speed, but to collect wind launch data for analys is of future launches. 3. Area of intended operation will be primarily off

- shore, and will be defined by government agencies consent and boundaries obtained by government geographic information system (GIS) sources and the government agencies in charge of navigable off

- shore waters
. 4. PIC(s) will not conduct operations within five nautical miles (nm) of airports or military airspace without approved consent from base operations or air traffic control (ATC) authorities. PIC(s) will notify these agencies at least 72 hours prior if operation site is within five nautical miles of an airport or military airspace. 5. PIC(s) will maintain constant surveillance and monitoring of the unmanned aeri al system (UAS) from the point of launch through the point of retrieval through relay flight information systems. The Flexrotor will be flying distances up to fifty

- five miles away from the launch site, visual line of sight (VLOS) will only be feasible dur ing takeoff and retrieval. 6. PIC(s) will verify flight limiting factors upon arrival to the operation site by using government sources and Kestrel for weather data, surveying and documenting site hazards, and conducting pre

-flight inspections and main tenance checks prior to launch. 7. PIC(s), when applicable to operations, will submit FAA Form 7711

- 1 Certificate of Waiver or Authorization (COA) or equivalent form with Flight Standards District Office at least 72 hours prior to operation. 8. I will obtain COA, if re quired, from FAA Air Traffic Organization if granted exemption.We hope that you grant us exemption to the current regulations. We are looking forward to

leading the way and setting a safe and efficient standard for future companies and UAS operators. Than k you for your consideration on this matter. Very respectfully, Steven D Lowe, CEO Fish Finders Inc.

**The name and address of the applicant is:**

Fish Finders Inc. Attn: Steven D Lowe 366 SW M Street Apt. H3 Madras, Oregon 97741

- 1097 Phone: (904)859

- 1879 (541)316

- 1274 Skype Email: fishfindersinc@gmail.com
**Regulations from which the exemption is requested:** 14 C.F.R. Part 21 Certification procedures for products and parts 14 C.F.R. 45.23(b) Identification and registration marking 14 C.F.R. 61.113(a) and (b) Private pilot privileges and limitation: pilot in command 14 C.F.R. 91.7(a) Civil aircraft airworthiness 14 C.F.R. 91.9(b) (2 ) Civil aircraft flight manual, marking, and placard requiremen ts 14 C.F.R. 91.103 Preflight action 14 C.F.R. 91.109 Flight instruction; simulated instrument flight and certain flight tests 14 C.F.R. 91.119 Minimum safe altitudes; general 14 C.F.R. 91.121 Altimeter settings14 C.F.R. 91.151 (a) Fuel requirements and f light in VFR conditions

14 C.F.R. 91.167 Fuel requirements for flight in IFR conditions 14 C.F.R. 91.203 (a) (b) Civil aircraft; certifications required 14C.F.R. 91.405 (a) Maintenance required 14 C.F.R. 407 (a) (1) Operation maintenance, preventative main tenance, rebuilding or alteration 14 C.F.R. 409 (a) (2) Inspections 14 C.F.R. 417 (a) (b) Maintenance records