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 and 

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 enhance airspace safety 
and efficiency in our community by offering 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 offer 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 year 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 water 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, and 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 will 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, 

primarily the commercial fishermen.

2. Because the Flexrotor is an all-weather vehicle, equipped with IR and long-range 

capability (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 

will 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 

analysis 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 aerial 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 during 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 maintenance 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 required, 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. Thank 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 requirements

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 settings
14 C.F.R. 91.151 (a) Fuel requirements and flight 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 maintenance, rebuilding or alteration

14 C.F.R. 409 (a) (2) Inspections

14 C.F.R. 417 (a) (b) Maintenance records