PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 1

February 10, 2016

Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Opera tion West Building Ground Floor Room w

- 12

- 140 1200 New Jersey Ave, SE Washington, DC 20590



## Petition for Exemption

RE: Petition of R. J. Corman Railroad Group, LLC. for an Exemption under Section 333 of the
FAA Modernizatio n and Reform Act of 2012 and from certain rules of 14 C.F.R.

Dear Sir or Madam:

The followin g is a Petition for Exemption relating to Section 333 of the FAA Modernization and Reform Act of 2012. Specifically, this Petition for exemption is filed by DMZ Marketing, LLC., on behalf of R. J. Corman Railroad Group, LLC. for exemption from certain rules of 14 C.F.R. R. J. Corman Railroad Group, LLC. requests Exemption in a n effort to be granted per mission to operate small Unmanned Aircraft Systems (“sUAS”) commercially in the United States of

America. These operations would be subject to the current rules and regulations , not stated herein as rules requested for exemption under Section 333, under t he jurisdiction of the Department of Transportation and the Federal Aviation Administration

. Additionally, all operations will adhere to str ict safety rules enforced by R. J. Corman Railroad Group, LLC. within their company

. These safety rules will be modeled after recommendations made by the FAA and community

- based organizations such as the Academy of Model

Aeronautics. Specific conditions relating to the safe operations of sUAS by R. J. Corm an Railroad Group, LLC. will be covered in more detail in the documentation to come, however basic flight safety parameters often cited by organizations such as the Academy of Model Aeronautics will be closely followed, such as operations at low altitudes and adequate distances away from airports, heliports, and approach areas to name a few. Petitioner Name: R. J. Corman Railroad Group, LLC. Petitioner C ontact: Benjamin Gettinger Petitioner Phone Number: 859

- 881

- 2445 Petitioner Email Address: ben.gettinger@rjcorman.com Petitioner Address: 101 R. J. Corman Drive Nicholasville, KY 40340

Document Preparer : DMZ Marketing, LLC. Contact Person: Zach Fiene Phone Number: 608

- 370

- 2858 Email Address: dmzaerial@gmail.com Website: www.dmzaerial.com Address : 1501 Parkview Court Prairie du Sac, WI 53578 USAPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 2



### As was established in Huerta v. Pirker

, an aircraft is, “any” “device” that is “used for flight.” 1 

### Clearly this broad definition encomp asses the types of sUAS the petitioner, R. J. Corman Railroad Group, LLC. , plans on flying commercially within the United States of America and as such, are governed by the rules of 14 C.F.R. Due to this, in the following Pe tition for Exemption and associated documentation, R. J. Corman Railroad Group, LLC. will establish clear reasoning as to why their particular commercial sUAS flights should be granted exemption and why their
business should be exempt from certain parameters of 14 C.F.R.

A s has been established by the FAA ov er the last year, sUAS pilots are allowed to petition for exemption from certain aircraft rules that may be inapplicable to sUAS craft or that may place
an undue burden on a peti ti oner looking to turn their sUAS hobb y into a commercial business. R. J. Corman Railroad Group, LLC. would like to request exemption from certain parameters contained in 14 C.F.R. The specific rules for which R. J. Corman Railroad Group, LLC. requests exemption will be covered in further detail in the documentation to come, but, in summary, R. J. Corman Railroad Group, LLC. looks to be exempt from the ty pes of rules that may limit or otherwise prevent their intent of operating sUAS commercially within the United States.

Furthermore, t hese commercial operations would only be conducted after a granted Section 333 Exemption and within the outlined conditio ns below or that may be otherwise highlighted by the Federal Aviation Administration in their Exemption Approval Letter

. With the approval of this exemption, R. J. Corman Railroad Group, LLC. will be allowed to commercially operate their sUAS within the United States of America. Specifically, R. J. Corman Railroad Group, LLC. will be allowed to fly commercially with the DJI Inspire 1 and DJI Matrice

100

. Furthermore, R. J. Corman Railroad Group, LLC. will be opera ting their sUAS in furtherance of various applications within the following industries; Ci nematography

, Insurance

, Railroad Services, and Search and Rescue

. Details of these flight crafts; their manuals, safety parameters, operational checklists and more, along with these sUAS flight applications, will be expanded upon in more detail below.

In addition to R. J. Corman Railroad Group, LLC. ’s Petition for Exemption pertaining to the use
of the aforementioned aircraft and use

- cases, the granting of this Petition will also allow for the commercial operations of sUAS in Clas s G Airs pace, below 400 feet Above Ground Level (“AGL”) , nationwide, or as otherw ise granted in a Certificate of Authorization (“COA”). To start, R. J. Corman Railroad Group, LLC. will adhere to the blanket Certificate of Authorizat ion that is granted to each entity receiving an Exemption Number. This COA currently allows for flights nationwide, in Class G Airspace, below 200 feet AGL. 2 

### Further flight areas sought by R. J

. Corman Railroad Group, LLC. will be applied for through the FAA’s COA Portal. Additionally, with the potential hazards and obstacles associated with low

- altitude flight

, R. J. Corman Railroad Group, LLC. will adhere to t he Visual Flight Rule (“VFR”) minimums which apply to this airspace. Further details on these operational minimums will be discussed in the
documentation to come.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 3



### The Petitio n for Exemption below provides details relating to the proposed applications of

c ommercial sUAS use by R. J. Corman Railroad Group, LLC. Specifically, R. J. Corman Railroad Group, LLC. seeks exemption in an effort to conduct commercial operations within the following indust ries; Cinematography

, Insurance

, Railroad Services, and Search and Rescue

.
In addition to the v ariety of Industry applications highlighted above, this Petition for Exemption will also cover details on various methods of operation and sensor/imagery types for the various applications. Specifically, R. J. Corman Railroad Group, LLC. will incorporate a variety of sensor payloads on its sUAS in an effort to capture necessary imagery or data types for each

sp ecific application or use

- case. Examples of the payload technologies used on the sUAS include, but are not limited to; Visible Light Spectrum Imagery, Near Infrared ( “ NIR ” ) Imagery, Thermal Infrared Imagery, LIDAR, Se nsor Technologies , GPS Guidance, Photo grammetry, Semi

Autonomous and Autonomous Flight Controllers (For safety), Object Avoidance Systems, and more. With the data collected from these various sensor payloads, R. J. Corman Railroad Group, LLC. will be able to pro vide high quality data for representatives from the below

highlighted industries.

 Cinematography: High

- resolution images and video can provide a n elevated vantage point from which to assess an asset; such as a railroad, facility, train, or
the like . This elevated vantage point can yield a different perspective and provide valuable information relating to the asset's condition, compliance relating to the asset's con tinued use, marketing pertaining to the business that owns, controls, or manages the asset, and more.

 Insurance: High

- quality, high

- resolution imagery, coupled with advanced identification and measurement software, can help turn aerial data collected by a sUAS into actionable infor mation for Insurance Agents, Adjusters , third

- party service providers, asset owners, and the like. With an aerial map of a train derailme nt for example, advanced software can identify the precise location of train cars and other debris, providing an assessment of the overall scene and a record of what it looked like prior to clean

- up. This information can be valuable, especially in the eve nt of any litigation or other challenges.

 Railroad Services : High

- quality, high

- resolution imagery can help those in the Railroad Industry better service their infr astructure and promote their businesses. In terms of Railroad management, imagery

- data and 3D modeling can help railroads gain confidence in their operations and efficiency in their practices. In particular, aerial imagery can be used for various forms of compliance, be it organizational compliance relating to safety or other benchmarks or whether it be compliance with outside parties, such as insurance companies, banks, or government agencies. Furthermore, aerial imagery provided by a UAV can assist in various railroad service efforts, such as infrastructure inspection, train derailment assessments, and the like. Additionally, in the event of an environmentally

- impactful derailment, aerialPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 4 

### services related to environmental protection can be executed in an effort to minimize a potentially hazordous situation. Finally, in various repair or clean

- up situations that require the use of large equipment, an aerial perspective, provided by a UAV, can be valuable as it pertains to that piece of equipment’s

move ment around the job site.

 Search and Rescue: High

- quality, high

- resolution imagery and aerial video can provide an incredible vantage point from which search and re scue teams can more effectively scope out an area. Furthermore, with the ability to stitch still images and georeference data, Search and Rescue teams can more effectively map the areas they have already search ed and more efficently direct their

resources to lesser searched areas.

The applications highlighted in this petition obviously p rovide high quality data to a variety of interested parties in var i ous industries. However, sUAS have more to provide than just interesting pictures and efficient operations. There is also the enhanced safety sUAS provide not only for the operators of these systems, but also, the people around them, communities as
a wh ole, and the National Airspace System (“NAS”).

Within this Petition for Exemption you will find that the applications highlighted above along with the aircraft systems utilized by R. J. Corman Railroad Group, LLC. , satisfy t he conditions highlighted by the Federal Aviation Administration as requirements for a successful Section 333 Exemption Petition

. 3 

### Specifically, the sUAS operating in furtherance of the industry applications above should;

1. P rovide a benefit to the public as a whole, and;
2. Not adversely affect safety.

To answer these requirements this Petition for Exemption will highlight the public benefits provided by the proposed sUAS operations as well as show the positive affect these o perations will have on safety. Specifically, it will be shown that the commercial sUAS flights proposed in this Petition further the public interest by satisfying what is sometimes referred to as the 3D’s or 4D’s of Unmanned Aerial Vehicle (“UAV”) Interve ntion

. 4 

### Basically, the “D” list provides a description of situations in which an unmanned vehicle should be used in place of a manned aircraft, more clearly, those situations in which an aerial operation is going to be; Du ll, Dirty, Dangerous, or Deep

. 5 

### This list is often associated with early military applications utilizing UAV’s. The UK Ministry of Defense for example has used this list in determining the role of Unmanned Aircraft, highl ighting the importance of Unmanned Systems in times where the operation is ; 5



###  Dull

- flights require persistence or repetition.  Dangerous

- flights carry a high degree of risk.  Dirty

- flights must be carried out in hazardo us environments, or;  Deep

- flights are beyond the range of manned platforms.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 5



### In addition to the justification that will be provided in detail in the pages to come relating to the 4 D’s of UAV Intervention and safety attributes of the sUAS Operation s proposed in this Petition for Exemption, it is also important to quickly consider the aircraft types utilized by R. J. Corman Railroad Group, LLC.

As mentioned above, R. J. Corman Railroad G roup, LLC. seeks exemption for the utilization of
the DJI Inspire 1 and DJI Matrice 100

. All of these aircraft ar e small Unmanned Aircraft Systems and are battery

- powered. Operati ons conducted by R. J. Corman Railroad Group, LLC. with these sUAS will adhere to the guidelines set forth by the Federal Aviation Administration and Community

- Based Organizations such as the Academy of Model Aeronautics (“AM A”). Through the adherence of these guidelines

, R. J. Corman Railroad Group, LLC. will commercially operate thei r sUAS with an equivalent level of safety, if not superior level of safety, as outlined by the Federal Aviation Administration’s Section 333 Exemption Guidelines.

Furthermore, the commercial sUAS operations being proposed by R. J. Corman Railroad Group,
LLC. in this Petition for Exemption would pr oduce far safer methods of data

- capt ure than currently

- used collection methods in which manned aircraft are used. Consider that manned aircraft weigh thousands of pounds, are made of metal, are powered by a combus tion engine, carry flammable fuel, and are carrying people. Plus, with the ty pe of data

- capture proposed in this Petition, a manned aircraft would have to operate in high

- risk situations, including, in close proximity to the ground where the risk of an accident is highest and the risk to people and property on the ground is the gre atest. Contrasting the two aircraft types, it is clear that a plastic, battery

- powered, unmanned vehicle operating at low altitudes, would be m uch safer
than a multi

- thousand

- pound, metal

- aircraft, powered by a combustion engine, and carrying a person at low altitudes.

This fact is furt her bolstered by the operational and aircraft

- specific parameters giv en by the FAA when deciding whether or not to grant Section 333 Exemptions

. 6 

### These directives include ;

1. The size of th e aircraft
2. The weight of the aircraft
3. The speed of the aircraft
4. The operational capability of the aircraft
5. The aircraft operation’s proximity to airports
6. The aircraft operation’s proximity to populated areas , and;
7. The aircraft operation’s adherence to Visu al Line of Sight Rules

As highlighted above, it is clear that this Petition for Exemption and both the aircraft types and applications state d herein, strictly adhere to the operational and aircraft

- specific parameters highlighted by the FAA for a successf ul Exemption Petition and thus, support the granting of this Exemption. A summary of the reasoning behind this statement can be found below as;

1. All proposed sUAS are Small
2. All proposed sUAS weigh below 55 lbs.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 6 

### 3. All proposed sUAS travel at less than 100 mp h (87 Knots)
4. All proposed sUAS are capable flight systems and have been granted Exemptions previously
5. All proposed operations will take place at least 5 miles from an Airport
6. All proposed operations will take place in unpopulated area s (U nless prior

approv al is given {See Condition #34 [“ Proposed Conditions of the Exemption ”] below})
7. All proposed operations will adhere to the Visual Line of Sight Rules

By adhering to t he parameters published by the FAA and by prom oting the public good through the various Industry applications to be highlighted below, this Pe tition for Exemption on behalf of R. J. Corman Railroad Group, LLC. s trongly supports approval.

We kindly ask for your considera tion of this Petition for Exemption. Please see the table of contents below for all our documentation and for assistance in reviewing this Petition. Thank you for your efforts in reviewing this document and we look forward to your response. If you
have any questions while reviewing this document, please do not hesitate to ask. You can contact the Preparer of this document for all questions relating to this petition and they can be reached by email at dmzaerial@g mail.com . Further contact information can be found at th e top of this Petition or on the following website ; www.dmzaerial.com . Once again

, thank you for your efforts in reviewing this Petition for Exemption and w e look forward to your reply.

Best Regards,

DMZ Marketing, LLC. (DMZ Aerial)



## C ontact Information

Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Court Prairie du Sac, WI 5357 8 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com

Petitioner:

R. J. Corman Railroad Group, LLC.
101 R. J. Corman Drive Nicholasville, KY 40340 Benjamin Gettinger
859

- 881

- 2445 ben.gettinger@rjcorman.comPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 7



## Disclosure

The Petitioner for this exemption is R. J. Corman Railroad Group, LLC.

, a railroad service provider that serves all seven major No rth American railroads, as well as many regional and shortline railroads. R. J. Corman Railroad Group, LLC. purchased document preparation servi ces through DMZ Marketing, LLC

. for the purpose of petitioning the FAA to be al lowed to fly their s mall Unmanned Aircraft Systems commercially within the United St ates. DMZ Marketing, LLC. , also known as DMZ Aerial, help s formulate these documents and work with the customer to help promote safe flying practices and appropriate

opera tions. This is done through questionnaires, phone conversations, document preparation, training module creation, and more. If you have any questions relating t o the Petitioner or DMZ Marketing, LLC. (“DMZ Aerial”), please do not hesitate to contact us us ing the contact information provided above.



## Table of Contents

Petition for Exemption

................................ ................................ ................................ ............................ 1

Contact Information

................................ ................................ ................................ ................................ 6

Disclosure

................................ ................................ ................................ ................................ ................ 7
The Applicant

................................ ................................ ................................ ................................ ........ 10
Commitment to Safety

................................ ................................ ................................ ...................... 10
Experience and Expertise

................................ ................................ ................................ ................... 11

Privacy

................................ ................................ ................................ ................................ ............... 11
Publishable Summary

................................ ................................ ................................ ............................ 11

Petitioner’s Contact Information

................................ ................................ ................................ ........... 13
Proposed sUAS Operations

................................ ................................ ................................ .................... 14
Small Unmanned Aircraft Systems

................................ ................................ ................................ ..... 14

DJI Inspire 1

................................ ................................ ................................ ................................ ... 14

DJI Matrice 100

................................ ................................ ................................ .............................. 14
Unmanned Flight Crew

................................ ................................ ................................ ...................... 15
Unmanned Flight Conditions

................................ ................................ ................................ .............. 15
Unmanned Flight Operations

................................ ................................ ................................ ............. 16
Aircraft and Equivalent Level of Safety

................................ ................................ ................................ ... 17
National Security

................................ ................................ ................................ ................................ ... 17
Proposed Conditions of the Exemption

................................ ................................ ................................ .. 17
Exemptions Requested & Applic able Conditions/Reasoning

................................ ................................ ... 23
14 C.F.R 21(h): Airworthiness Certificates

................................ ................................ .......................... 23PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 8

14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft

................................ .................. 24
14 C.F.R. 43.7: Authorized Maintenance/Repair/Alteration Personnel

................................ ............... 24
14 C.F.R. 43.11: Dispositions of Records for In spections

................................ ................................ ..... 24
14 C.F.R. 45.11: Making of Products

................................ ................................ ................................ ... 25
14 C.F.R. 45.23(b): Display of Marks; General

................................ ................................ ..................... 25
14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft

................................ ................................ .......... 25

14 C.F.R. 45.29: Size of Marks

................................ ................................ ................................ ............ 26

14 C.F.R. 61.3: Requirement for Certificates, Ratings, and Authorizations

................................ .......... 26
14 C.F.R. 61.23(a) and (c): Medical Certificates

– Requirements and Duration

................................ .... 27
14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

................................ ......... 27
14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations

– Pilot In Command

.......................... 28
14 C.F.R. 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

................................ ................... 29
14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

................................ ................................ ..................... 33
14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual

................................ ................................ ................. 33
14 C.F.R. 91.9(c): Civil Aircraft Marking, Placards

................................ ................................ ............... 33
14 C.F.R. 91.103: Preflight Action

................................ ................................ ................................ ....... 34
14 C.F.R. 91.105: Flight Crewmembers at Stations

................................ ................................ ............. 34

14 C. F.R. 91.109: Flight Instruction

................................ ................................ ................................ .... 35
14 C.F.R. 91.113(b): Right

- of

- Way Rules

................................ ................................ ............................. 36

14 C.F.R. 91.119: Minimum Safe Altitudes

................................ ................................ ......................... 37
14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ................................ ... 38
14 C.F.R. 91.151(a): Fuel Requirements for VFR Flight Conditions

................................ ...................... 39
14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

................................ ..................... 40
14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use

................................ ..... 40

14 C.F.R. 91.403: General

................................ ................................ ................................ ................... 42
14 C.F.R. 91.405(a): Mainte nance Required

................................ ................................ ....................... 43
14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

................................ .................... 43
14 C.F.R. 409(a)(1) and (2): Inspections

................................ ................................ .............................. 43
14 C.F.R. 91.417(a) and (b): Maintenance Records

................................ ................................ ............. 44

Priva cy

................................ ................................ ................................ ................................ .................. 45
Public Interest and Safety

................................ ................................ ................................ ...................... 45
Cinematography

................................ ................................ ................................ ............................ 47

Insurance

................................ ................................ ................................ ................................ ....... 49PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 9

Railroad Services

................................ ................................ ................................ ............................ 50

Search and Rescue

................................ ................................ ................................ ......................... 52
Regulations Requested for Exemption

................................ ................................ ................................ ... 54
Appendix 1: Regulations Requested for Exemption

– List

................................ ................................ ... 54

Exhibit List

................................ ................................ ................................ ................................ ............. 54
Exhibit 1: R. J. Corman Railroad Group, LLC. Operations Manual

................................ ........................ 54
Exhibit 2: R. J. Corman Railroad Group, LLC. Logbook Example

................................ ........................... 54

Exhibit 3: R. J. Corman Railr oad Group, LLC. Visual Observer Training Procedures & Guide

................ 55
Visual Observer Training Procedures

................................ ................................ .............................. 55
Visual Observer Training Guide

................................ ................................ ................................ ...... 55
Exhibit 4: R. J. Corman Railroad Group, LLC. Pilot In Command Training Guide

................................ ... 55
Pilot In Command Training Procedures

................................ ................................ .......................... 55
Pilot in Command Training Guide

................................ ................................ ................................ ... 55
Exhibit 5: DJI Inspire 1

................................ ................................ ................................ ........................ 55
Exhibit 6: DJI Inspire 1 User Manual

................................ ................................ ................................ ... 55

Exhibit 7: DJI In spire 1 Quick Start Guide

................................ ................................ ............................ 55
Exhibit 8: DJI Inspire 1 Features

................................ ................................ ................................ ......... 56
Exhibit 9: DJI Inspire 1 Specifications

................................ ................................ ................................ .. 56

Exhibit 10 : DJI Inspire 1 Flight Controller System

................................ ................................ ................ 56
Exhibit 11: DJI Inspire 1 Smart Battery Manual

................................ ................................ ................... 56

Exhibit 12: DJI Matrice 100

................................ ................................ ................................ ................ 56

Exhibit 13: DJI Matrice 100 User Manual

................................ ................................ ............................ 56

Exhibit 14: DJI Matrice 100 Features

................................ ................................ ................................ .. 56
Exhibit 15: DJI Matrice 100 Specifications

................................ ................................ .......................... 56

Exhibit 16: DJI Matrice 100 Smart Battery Manual

................................ ................................ ............. 57

References

................................ ................................ ................................ ................................ ............ 57
Exemption References

................................ ................................ ................................ ........................... 58PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 10



## T he Applicant

The Applicant seeking this Exemption is R. J. Corman Railroad Group, LLC. , headquartered at;

101 R. J. Corman Drive Nicholasville, KY 40340

R. J. Corman Railroad Group, LLC serves all seven major North American railroads, as well as many regional and shortline railroads. Headquartered in Nicholasville, Kentucky, its field offices have spread across 24 states, reaching as far west as A rizona

.

These operations encompass an array of services, including railroad construction, 12 shortlines, 14 switching services, 21 derailment service divisions, 10 material yards, aircra ft maintenance, dispatching, distribution centers, signal construction, Railpower locomotive design, a dinner t rain, and roadway

worker safety

- training services.



### Commitment to Safety

A commitment to safety is key to any successful business. R. J. Corman Railroad Group is committed to operating within the National Airspace System safely and legally. It is for this reason that they have filed this Petition for Exemption in an effort to make their actions kno wn and to be sure they are operating within the rules and regulations set forth by the Federal Aviation Administration. Additionally, R. J. Corman Railroad Group will require all pilots to hold the appropriate licenses and certifications to operate their aircraft. Furthermore, the company’s intent on utilizing a licensed Pilot In Command shows their commitment to safety. A licensed pilot is not only required by current FAA rules but also provides for a heightened level of safety for the National Airspace as a pilot will have completed significant training in the National Airspace System and have knowledge of all Federal Aviation Rules. Plus, in addition to the Petitioner’s utilization of a licensed Pilot In Command, they will also be following
the condit ions set forth within the Conditions of the Exemption Section below (including pre

- flight training), which will provide an equivalent, if not superior level of safety as is provided by current rules.

Furthermore, because an OSHA safety rating is a key st atistic in the railroad industry, R. J. Corman Railroad Group has several safety initiatives in place. "Safety is our #1 priority" is one of R. J. Corman Railroad Group's core values. Additionally, the company recognizes employees and divisions for each

y ear of service with zero injuries or property damage. Along with that, every year, each of the company's field employees attends a week

- long safety procedure training seminar. In fact, the company that writes the safety training curriculum and conducts th e courses is now owned by R. J. Corman Railroad Group, showing the company's belief in safety and the importance of providing safety services to the railroad industry.

Finally, it should be noted that R. J. Corman Railroad Group also has an aircraft divisi on which houses an aircraft service department and aircraft maintenance company. The company currently owns two Bell Helicopters as well as two Learjets and employs four full

- time pilots and three other full

- time employees who hold pilots licenses. Furth ermore, their national headquarters has a runway and their officePETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 11

buildings are aircraft hangers. Clearly, R. J. Corman Railroad Group's continuous interaction with the National Airspace, their certified Pilots, and their FAA

- Certified businesses, show th e company's experience with aviation and understanding of the importance of the National Airspace System.



### Experience and Expertise

R. J. Corman has been a service provider to the railroad industry sinc e 1973. The company owns and operates 11 railroads. Additionally, the business also has an Aviation Services department as well as an entire Aircraft Maintenance company. They currently own two Bell helicopters and two Learjets and employ 4 full

- time pi lots as well as three other full

- time employees who hold pilots licenses. The campus for the company's national headquarters has a runway and their office buildings are aircraft hangars.

Clearly, R. J. Corman Railroad Group has an experienced staff with significant knowledge in the aviation industry. Furthermore, the R. J. Corman Railroad Group is unique in its immediate access to an FAA

Certified Maintence Company and a group of highly experienced pilo ts to draw more information about
Federal Aviation R ules and how to operate safely within the National Airspace System.

Additionally, the company has an array of talented employees, including Ben Gettinger, who holds a bachelor's degree in media communication (with an emphasis in video production) and has o ver 10 years of photography experience. This type of experience will be important in developing content for R. J. Corman Railroad Group. Plus, the company currently empl oys experts in various railroad

- related
service

- fields, including Train Derailment Re covery. In the past, R. J. Corman Railroad Group utilized helicopter s to assess damage and determine the best tools to clean up the wreck. Moving forward

, they will likely implement the use of UAV Technologies for much of the same uses. Having a trained staff that has previously assessed train derailments from the air will allow R. J. Corman Railroad Group to draw on their past experiences and utilize UAVs effectively.



### Privacy

Privacy is important in any business, but especially one in which imagery is captured. For this reason, R. J. Corman Railroad Group will use commonly accepted practices in order to secure imagery. A few of the practices they will put into action include; obtaining proper permissions and consent, notifying authorities of any pending flights that may cause call

- ins, keeping data on a secure computer system, notifying adjacent properties of impending flights, and the like. Additionally, they will also seek what is required by law to remain compliant and secur e in terms of data/imagery privacy.



## Publishable Summary

DMZ Marketing, LLC. files this petition for exemption on behalf of R. J. Corman Railroad Group, LLC.

, a railroad service provider that serves all seven major North American railroads, as well as many regional
and shortline railroads. R. J. Corman Railroad Group, LLC. is seeking exemption from certain paramete rsPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 12

of 14 C.F.R. in orde r to commercially operate sUAS within the United States in the following industries; Cinematography

, Insurance

, Railroad Services

, and Search and Rescue

. Specifically, R. J. Corman Railroad Group, LLC. requests exemption from the following Federal Aviation Administration rules;

1. 14 C.F.R 21(h): Airworthiness Certificates

2. 14 C.F.R. 27: Airworthiness Standards

- Normal Category Rotorcraft
3. 14 C.F.R. 43.7: Authorized Maintenance/Repair/A lteration Personnel

4. 14 C.F.R. 43.11: Dispositions of Records for Inspections

5. 14 C.F.R. 45.11: Making of Products

6. 14 C.F.R. 45.23(b): Display of Marks; General

7. 14 C.F.R. 45.27: Marking of the Aircraft

– Rotorcraft
8. 14 C.F.R. 45.29: Size of Marks
9. 14 CFR 61.3: Requirement for Certificates, Ratings, and Authorizations

10. 14 CFR §§ 61.23(a) and (c): Medical Certificates

– Requirements and Duration

11. 14 CFR 61.101(e) (4) and (5): Recreational Pilot Privileges and Limitations

12. 14 CFR 61.113(a) & (b): Private Pilot Privil eges and Limitations

– Pilot In Command
13. 14 C.F.R. 61.315(a): Privileges and Limits of Sport Pilot’s License

14. 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness

15. 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual
16. 14 C.F.R. 91.9(c): Civil Aircraft Marking, Placar ds

17. 14 C.F.R. 91.103: Preflight Action

18. 14 C.F.R. 91.105: Flight Crewmembers at Stations
19. 14 C.F.R. 91.109: Flight Instruction
20. 14 C.F.R. 91.113(b): Right

- of

- Way Rules
21. 14 C.F.R. 91.119: Minimum Safe Altitudes

22. 14 C.F.R. 91.121: Altimeter Settings
23. 14 C.F.R. 91 .151(a): Fuel Requirements for VFR Flight Conditions

24. 14 C.F.R. 91.203(a) and (b): Civil Aircraft

– Certifications Required

25. 14 C.F.R. 215: ATC Transponder and Altitude Reporting Equipment and Use
26. 14 C.F.R. 91.403: General
27. 14 C.F.R. 91.405(a): Maintenance R equired
28. 14 C.F.R. 91.407(a)(1): Operation after Maintenance or Alteration

29. 14 C.F.R. 409(a)(1) and (2): Inspections
30. 14 C.F.R. 91.417(a) and (b): Maintenance Records

The approval of this Petition for Exemption would allow for the commercial operation of smal l Unmanned Aircraft Systems by R. J. Corman Railroad Group, LLC. These commercial operations would strictly adhere to all Federal Aviation Administration rules and regulations not stated herein as rules requested for exempti on. The commercial operations flown by R. J. Corman Railroad Group, LLC. , if this Petition were granted, would be flown utilizing one of the following aircraft platforms; the DJI Insp ire 1

or DJI Matrice 100

. Specifically, the commercial operations utilizing t hese unmanned aircraft would

center around the following industry applications; Cinematography

, Insurance

, Railroad Services

, and
Search and Rescue

.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 13

Additionally, all the industry applications highlighted above would include one or more of the unmanned
aircraft noted above flying no more than 400 feet Above Ground Level (“AGL”) o r in airspace otherwise

spec ified in a granted C ertificate of Authorization (“COA”).

Furthermore, this Petition for Exemption should be granted to R. J. Corman Railroad Group, LLC. because
th e operation of the listed sUAS above will provide for commercial operations w hile maintaining an equivalent level of safety as would be provided by the above

- listed rules. Additionally, as will be highlighted below, the small Unmanned Aircraft utilized by R. J. Corman Railroad Group, LLC. will provid e methods of aerial

- data

- collection far safer than t he alternative of manned

- aircr aft

- collection of the same
data

- sets. Low altitude data

- collection flights, in close proximity to people and property, are far safer when accomplished using a battery

- pow ere d sUAS weighing less than 10 lbs., than with a combustion

engine

- powered, multi

- thousand

- pound, manned aircraft, with flammable fuel onboard.

Considering the seve n factors highlighted by the FAA as parameters for successful Section 333 Exemption
Petition s, including; Size, Weight, Speed, Operational Capability, Proximity to Airports, Proximity to Populated Areas, and Operations within Visual Line of Sight

, 6 this Petition supports the Petitioner’s

re quest for exemption rela ting to each operational and aircraft

- specific parameter . Specifically, the aircraft utilized by R. J. Corman Railroad Group, LLC. ar e in the small

- size category, they are below the 55 lbs. weight class, they travel at less than 100 mph, they are proven flight platforms based on previously granted petitions, all operations will be conducted at least 5 miles from an airport and over unpopulated areas (unless otherwise granted permis sion by the FAA in a granted Certificate of A uthorizatio n), and all flights will be conducted within Visual Line of Sight.

In addition, the data

- collectio n

- flights provided by the sUAS highlighted in this Petition

, will promote safer operations for professional service providers in the aforemention ed industries.



## Petitioner’s Contact Information

Petitioner:

R. J. Corman Railroad Group, LLC. Benjamin Gettinger
101 R. J. Corman Drive Nicholasville, KY 40340
859

- 881

- 2445 ben.gettinger@rjcorman.com



## Document Preparer:

DMZ Marketing, LLC. 1501 Parkview Cou rt Prairie du Sac, WI 53578 USA
Contact: Zach Fiene Phone: 608

- 370

- 2858 Email: dmzaerial@gmail.com Website: www.dmzaerial.comPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 14



## Proposed sUAS Operations

Small Unmanned Aircraft Systems

This Petition for Exemption under Section 333 will permit the Petitioner to operate the DJI Inspire 1 and
DJI Matrice 100

. Further operating characteristics, specifications, and other important craft

- specific
information on the DJI Inspire 1 and DJI Matrice 100 are covered in detail starting with Exhibit 5 . Each of these documents are publically circulated and have been previousl y vetted by the FAA in previously granted Petitions for Exemption under Sect ion 333. In the aircraft summaries below

, please see the references to previously granted petitions for the use of each specific aircraft type in commercial operations within the United States

.



### DJI Inspire 1

The requested exemption will permit the Petitioner the right to use the DJI Inspire 1 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Ins pire 1 has a weight of 2

, 935 grams including the battery payload. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous V ertical & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see the Inspire

- Specific Exhibits below for more information on the DJI Inspire 1 craft, its specifications, abilities, and more. Additional ly, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Inspire 1 in the following listed Exemptions;

 Jeffery Greer

– Berkshire Hathaway Home Services

– Ex emption Number 11587/11587A  Phillip Stiles

– GPS Development, LLC dba SkyViewHD

– Exemption Number 11399/11399A



### DJI Matrice 100

The requested exemption will permit the Petitioner the right to use the DJI Matrice 100 Quadcopter for commercial use within the United States of America and under the strict adherence of FAA Guidelines,
ATO

- Issued COA’s, and the like. The DJI Matrice 100 has a maximum take

- off weigh t of 3

, 400 grams including technical payloads and batteries. Furthermore, this quadcopter is capable of a max flight speed of 22 meters per second and has the following abilities;PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 15

 Vertical Take

- Off  Vertical Landing  Hover

- Hold Position  Simultaneous Vertic al & Horizontal Movement  Maximum Flight Speed Abilities in every lateral direction

For easy reviewing, please see Matrice 100

- Specific Exhibits below for more information on the DJI Matrice 100 craft, its specifications, abilities, and more. Additionally, please consider the FAA’s previous review of these exhibits and granting of Petitions using these supporting documents for the commercial use of the DJI Matrice 100 in the following listed Exemption;

 Dan Pham

– Alert5 International, LLC.

– Exemption Numbe r 11814



### Unmanned Flight Crew

The unmanned flight crew ope rating R. J. Corman Railroad Group, LLC. flight crafts for purposes of commercial operations within the Uni ted States under this proposed Exe mption will consist of a Pilot I n Command (“PIC”) and a Visual Observer (“VO”).

Adhering to current FAA guidelines and precedent established in previously granted Section 333 Exemptions, the PIC will have, at minimum, a Recreational or Sport Pilot’s License and a Third Class
Medical Certificate or a valid U.S. Driver’s License

. 7 Additionally, both the PIC and VO will be trained in the operation of sUAS prior to commercial operations. Fur thermore, any new information surrounding the aircraft’s efficient, effective, or safe operations, will be disseminated by R. J. Corman Railroad Group,

LLC. to both the PIC and VO to ensure continued safe flights.

On top of t he general sUAS training, the PIC will also have completed, at a minimum, 25 hours of sUAS flight training with the specific sUAS craft they are using for their commercial operation and will be required to receive annual continued educatio n and training mo ving forward. A specific PIC Training Presentation is contained in the exhibits below and will accompany this Petition for Exemption.

The Visual Observer will also have completed specific trai ning relating to their duties during an unmanned flight. The t raining procedures that will be used to educate VO’s are contained in Exhibits 1
& 3 below.



### Unmanned Flight Conditions

As has been described above, the sUAS

- use proposed by the Petitioner in this Petition for Exemption
under Section 333

, revolves aroun d the following industries; Cinematography

, Insurance

, Railroad
Services

, and Search and Rescue

. Each of these industry applications will be described in further detail
below under the “ U nmanned Flight Operations ” Title.

Moving on from the specific use

- cases, it should also be noted that all commercial sUAS flights proposed in this Petition for Exemption will be conducted below 400 feet AGL or as otherwise permitted in aPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 16

granted Certifi cate of Authorization. Furthermore, all flights will be conducted within Visual Line of Sight, as is currently advised by the Federal Aviation Administration and Academy of Model
Aeronautics

. 6 Additionally, the PIC will o nly operate the Petitioner’s sUAS if weather conditions permit safe operations. The judgement of “Safe Weather Conditions” will be determined based on several standing classifications developed by the Federal Aviation Administration. These include operat ions being conducted under the Visual Meteorological Conditions (“VMC”) rules.

As stated previously in this Petition, R. J. Corman Railroad Group, LLC. will strictly adhere to the FAA’s

V isual F light R ule s, an d obviously, t o be following Vis ual Flight Rules, R. J. Corman Railroad Group, LLC. will have to first satisfy the Visual Meteorological Conditions associated with VFR flights. In particular, the Petitioner will be cognizant of the bounda ry between Visual Meteorological Conditions, which allow for Visual Flight Rules, and Instrument Meteorological Conditions, which require Instrument use. Specifically, R. J. Corman Railroad Group, LLC. will be considering th e VMC Minima pertaining to Visibility, Cloud Ceilings, and Cloud Clearances associated with airspace below 400 feet AGL, where the Petitioner’s sUAS will be flying. Thus, the Petitioner will only operate when visibility is at least 3 statute
miles from th e PIC and at a minimum of 500 feet below and 2,000 feet horizontally from a cloud

. 8

In addition to the particular flight conditions stated above, it should also be noted that the flight crew will always make an assessment o f the current situation for each, specific flight. This assessment will conclude with a determination of the relative safety of the flight and any risks or hazards that may be present. If this assessment finds that the flight will be too dangerous or tha t there are too many hazards or risks associated with the flight, the flight crew will not take off. Furthermore, in order to maintain the safety of the general public, flight operations utilizing the Petitioner’s sUAS will only take place after permissio n is granted to the Petitioner by the landowner, property owner, or other controlling representative. All current FAA regulations not covered within this petition will be followed as well as all local and state rules surrounding flights near or around peo ple. Additional information on the parameters dictating flights near people can be found below in the “ Proposed Conditions of the Exemption .”



### Unmanned Flight Operations

When conducting commercial flight operati ons under the pro posed applications in this Petition for Exemption , a commitment to safety will always be paramount. Additionally, with the goal of each flight to accurately collect valuable aerial data in an efficient manner, it will be vital for all fli ghts to be safe for several reasons, including;

 The safety of the Flight Crew will be necessary for continued flights.  The safety of the general public will be necessary for continued operations.  The safety of the aircraft will be necessary for continued c ommercial endeavors.

Furthermore, in an effort to supply the Cinematography

, Insurance

, Railroad Services

, and Search and

Rescue industries with valuable data, it will be imperative for all R. J. Corman R ailroad Group, LLC. flights to be conducted in a safe and professional manner so as to not risk the safety of the flight crew, generalPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 17

public, or aircraft

, as well as to avoid damaging people or property operating in the National Airspace System or on the ground below.

To ensure the safe and professional execution of each sUAS flight, all flights will be conducted utilizing at
least a two

- person flight crew. This flight crew will consist of an adequately

- trained (“ Unmanned Flight
Crew ” ) PIC and VO. For specifics pertaining to the standard operating procedures utilized by the Petitioner under the proposed Petition for Exemption and for more details on training, please see
Exhibits 1

- 4

. 

## Aircraft and Equivalent Level of Safety

As is stated in the FAA’s Section 333 Exemption Guidelines, Petitioners for Exemption must show that their proposed commercial, sUAS operations provide a level of safety at least equal to that provided by
th e rule from which the Petitioner seeks an exemption

. 6 As will be highlighted below, the request for this Exemption by the Petitioner is fortified by its commitment to safety. Furthermore, the operation of sUAS by the Peti tioner, using the previously stated flight crafts and operating within the above

- stated

use

- cases under the rules, regulations, and limitations stated herein, should be permitted under the proposed exemption. Reasoning for this can be derived from the str ict adherence to existing regulations from the Federal Aviation Administration as well as the adoption of the following conditions ; each providing at least an equivalent level of safety as is provided by the exist ing rule.


## National Security

In addition to the arguments supporting the Petitioner’s exemp tion from certain rules contained in 14
C.F.R. , it is also important to note that the granting of this petition and in turn, permission for the
Petitioner to conduct commercia l sUAS flights, will not present a national security threat. As has been stated in this Petition

, and

, as is precedent from the F ederal Aviation Administration , the PIC of a sUAS must hold, at minimum, a Recreational or Sport Pilot’s Cer tificate, meaning he or she has already been subject to a security screening by the Department of Homeland Security. 9

This provision, relating to the acquisition of a Recreational or Sport Pilot’s Certificate, points to checks already provided by the FAA and Department of Homeland Security in ensuring secure aircraft operations. As is stated by the Aviation and Transportation Security Act, the Transportation Security Administration (“TSA”) must assess information in orde r to identify individuals that may pose a threat to transportation security and coordinate countermeasures with other Federal Agencies such as the FAA. Therefore, due to the fact it is a requirement for all PICs to be at least Recreational or Sport Pilot Certified, it can be assumed that adequate security checks by the TSA and FAA have taken place prior to a sUAS Pilot conducting commercial operations.


## Proposed Conditions of the Exemption

As is noted by the Federal Aviation Administration in their, “S ection 333 Petition Guidance & Checklist” 3 form, Section 333 Exemption Petitioners are strongly advised to, “Carefully review the Conditions andPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 18

Limitations Section in the most recently granted exemptions.” 3 Due to this, the following Conditions of the proposed Exemption closely follow this guidance and mirror many of the same conditions previously noted by other exemption petitioners. The following list will highlight these conditions and establish a framework from which the petitioner, R. J. Corman Railroad Group, LLC. , will conduct their commercial sUAS operations under a granted petition for exemption.

1. Proposed operat ions using s mall Unmanned Aircraft S ystems in the United States under the granted form of this Petition for Exemption will be limited to the following aircraft, which all weigh less than 55 pounds including batteries and operational/technical payloads; DJI Inspire 1
and DJI Matrice 100

. Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will have to be added to an amended version of this petition or a new Petition for Exemption must be filed with the new flight platform (s)

.

2. The proposed use

- cases/applications contained within this Petition for Exemption under Section 333 are as follows; Cinematography

, Insurance

, Railroad Services

, and Search and Rescue

.

All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an

ATO

- issued Certificate of Waiver or Authorization.

3. All flights conducted by R. J. Corman Railroad Group, LLC. will be below 400 f eet AGL, operated within Visual Line of Sight, and have a live, GPS

- based, read

- out of altitude during the flight. Furthermore, each flight will beg in with a “Zero Altitude” start

- point, thus creating an accurate
AGL calculation.

4. All flights conducte d by the Petitioner will be controlled by a trained flight crew consisting of a licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All f lights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 mph) airspeed maximum, highlighted by the FAA in their guidelines.

6. All flights conducted by R. J. Corman Railroad Group, LLC. will be conducted within Visual Line of Sight, during daytime flying hours, and adhere to Visual Flight Rules under the Visual Meteorological Conditions associated with 400 foot AGL airspace.

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification standards set by the Federal Aviation Administration (i.e. Minimum

- Sport Pilot’s Certificate and Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities relating to safe sUAS operatio ns, such as;

a. Evasive Maneuvers
b. Emergency Actions

c. Fail

- Safe Knowledge
d. Flight SkillsPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 19 i. Maintaining adequate distances from;

1. People

2. Property
3. Structures
4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). Addition ally, a record of the PIC training will be documented and made available upon request by the Administrator.

9. Training operations will only be conducted during dedicated training sessions. During training, all persons not essential for flight operations wi ll be deemed nonparticipants, and thus, the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14
C.F.R. 91.119.

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspa ce for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be allowed to operate the camera or other instruments on the sUAS during flight operations. Instead, a third person will have to serve as a camera operator if the flight crew seeks a dedicated pilot and dedicated camera operator.

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, once the PIC is named and a flight is begun, the PIC will not be able to transfer h is/her designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for the duration of the flight.

12. Each commercial sUAS flight performed by R. J. Corman Railroad Group, LLC. will be planned for ahead of the flight date. This will be to ensure adequate time for all participants to prepare and to obtain all the necessary permissions (landowners , homeowners, property owners, etc.) if any are needed. All flights will be preceded by a meeting at least one day before the flight at which all participants of the flight will be present. This is to ensure adequate knowledge and preparedness prior to t he sUAS flight.

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft prior to flight. The PIC will likely have the most experience of anyone on the flight crew and will be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to find an error in the flight craft or any of the associated systems, including the Ground Control System for example, he/she would ground the flight until adequate maintenance is completed and the aircraft is once again safe to fly. All maintenanc e on flight crafts utilized by the Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating them.

14. Relating to the above Condition, anytime a flight

- critical component is replaced or anytime there is mission

- criti cal maintenance on the craft, the PIC will conduct a flight test of the systemPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 20

before completing the intended, commercial mission. Once again this flight test will be logged by the PIC.

15. Routine maintenance a nd inspections of the sUAS will be logged by t he PIC in accordance with the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft component maintenance, overhaul, replacement, inspection, and life limits, which are part of the supporting documents for each aircraft be low in the aircraft

- specific exhibits . The logging of these maintenance/inspection checks will be included in the aircraft records and include the total time of service and description of work.

16. All sUAS flights will be conducted within Visual Line of S ight (“VLOS”) of both the PIC and VO at all times. Furthermore, VLOS means visual observance unaided by any device other than corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for purposes of VLOS flights), binoculars , and the like will not be permitted. Also, both the PIC and VO should be in constant, verbal communication range. The use of other devices to communicate out of verbal range are not permitted. These devices would include, cell phones, text messaging, w alky

- talkies, and the like.

17. No commercial flight missions will be executed unless it can be determined that the flight crew can complete their mission from take

- off through landing, with a reserve of 25% battery life. The Petitioner’s newest flight cra fts have adaptive battery monitors and

, for this reason

, this condition will be an automated process as the Petitioner can set the default Advisory and Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted battery a nd engage him/her to fly home and land with 25% remaining power. For all R. J. Corman Railroad Group, LLC. systems without this automated feature, a watch will be used to monitor flight times to ensure a safe return home wit h adequate battery power. However, due to the revolving adoption of the newest flight platforms and the current stock of new generation flight crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize a Smart Batt ery System.

18. In the case of an unexpected obstacle or in

- flight issue, each sUAS the Petitioner operates will have the ability to abort a mission and take corrective actions.

19. The sUAS utilized by R. J. Corman Railroad Gro up, LLC. will be programmed so that if the sUAS loses signal with the PIC or Ground Control Station during flight, the system will return to a preprogrammed GPS location located within the operating area containing the flight crew. Furthermore, this fail safe can also be used in controlled situations, meaning the failsafe will be able to be engaged should something happen on the ground that disallows the PIC from bringing the sUAS back in a normal fashion. Additionally, in both situations described above, where the failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio

- link signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ability to land itself. This allows safe operation s of the aircraft even in troublesome situations, such as signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown location.

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and availab le to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 21

Furthermore, these documents will be available for review by the Administrator or other law enforcement officials upon request and are additionally contained in Exh ibit 1, with appropriate links to the specific flight manuals of each flight craft requested in this Petition for Exemption.

21. It is always important to specify precedent when determining operating practices. For this reason, if a discrepancy exists bet ween the conditions laid out in this Petition for Exemption and the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will take precedent over the conditions laid out in this Petition. Furthermore, if there are no discre pancies between the Petition and Grant of Exemption, the Petitioner will follow the procedures outlined in the Operating Documentation below. Additionally, if any changes are made to the Operating Procedures and Documentation contained in this Petition fo r Exemption, the Petitioner will present the updated documents upon request from the Administrator. Also, should the Petitioner determine that an update or change to the procedures or documentation would affect the basis of the approved version of this Pe tition for Exemption, the Petitioner will either file for an amendment to the existing Exemption or create a new Petition with the
revisions.

22. As has been noted, the Petitioner will obtain written and/or oral permission from the landowners, farmers, pro perty owners, or otherwise authorized agents for flights above their property.

23. The Petitioner will also obtain all required permissions and permits from territorial, state, county or city jurisdictions, including;

a. Law Enforcement b. Fire Departments

c. Munici pal Agencies, or; d. Other Appropriate Governmental Bodies

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an A ir Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March of 2015 for flights below 2 00 feet to all Section 333 Exemption holders or under a future ATO

issued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption.

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspac e requirements established by the FAA and/or an ATO

- issued COA, including;

a. Class of Airspace b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference point a s noted on a current FAA

- published aeronautical chart unless a letter of agreement withPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 22

that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with a NOTAM as required by the Operator’s COA.

28. As stated previously, th e Petitioner will follow VMC guidelines for VFR flights and as such, will fly only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while maintaining an adequate distance of no less than 500 feet below, or less than 2,000 f eet horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide or as otherwise advised in an ATO

- issued COA.

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number whi ch will be as large as practicable given the relatively small size of the aircraft. The FAA has previously stated that so long as the markings are as large as practicable given the size of a sUAS, an equivalent level of safety can be achieved.

31. All ai rcraft utilized by the Petitioner operate via radio frequency, which is governed by the Federal Communications Commission (“FCC”). For this reason, prior to commercial operations under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum used to operate and control its sUAS complies with FCC or other appropriate government oversight agency rules and regulations.

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner.

33. The concentration of a PIC is necessary for safe operations. It is for this reason that the Petitioner will not allow any sUAS operations while a PIC is in a movi ng device or vehicle. These vehicles would include things like;

a. Cars/Trucks/SUVs
b. Boats

c. Tractors d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all nonparticipating people, vessels, vehicles, and structures, unless th e following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying shrapnel or debris should there be an accident. Furthermore, should a nonparticipant leave this safe

- zone, the PIC will end the flight.

b. T he Petitioner has been granted permission to operate near a vessel, vehicle, or structure by the owner/controller of these properties. In addition to permission, the PIC will also have to perform a risk assessment of the situation and potential obstacles/ flight hazards and determine the safety of the flight. If it is determined that the hazards present no risk, the PIC can start the mission.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 23

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, accident, or f light operation that occurred outside the horizontal and vertical boundaries of the operational area as defined by the COA under which the flight was operating. Furthermore, the Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, each PIC that is designated as being a potential ca ndidate for flying a sUAS while towing an object will be required to undergo additional training, on top of their required training and certifications, that will consist of 10 hours of training flights while towing objects. These objects will be dummy ban ners that weigh no more than the max weight allowable to satisfy the max takeoff weight specifications as highlighted by the manufacturer for each flight craft. Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC adequate training time and experience while towing objects with specific flight crafts. This will be necessary to familiarize each PIC with each specific flight craft in order to learn how specific flight craft respond to towing objects, particularly with regard to downwash and wind. Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours must be in the max wind tolerances as specified by the manufacturer for each flight craft. Training in these conditions will hone the skills of each PIC and allow them to operate in the worst case scenario for towing objects, which is high wind. When conducting actual commercial flights while towing objects, the Petitioner will not conduct flights in conditions where sust ained winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for each aircraft.



## Exemptions Requested & Applicable Condition s/Reasoning

14 C.F.R 21(h) : Airworthiness Certificates

Subpart (h) of Part 21 from the Code of Federal Regulations Title 14, Chapter 1, prescribes procedural requirements for the issuance of Airworthiness Certificates. Proposed Conditions 1, 2, 3, 4, 5, 15, 24, 27, 28, and 33 are all applicable to this particular Regulation and the FAA has found in favor of exempting previous Petitions #11062, 11063, 11064, 11065, 11066, and 11067 for this portion of 14 C.F.R. Furthermore, it is the belief of the Petiti oner that a sUAS operating without an Airworthiness Certificate but within the conditions stated above would provide an equivalent level of safety to an aircraft operating with an airworthiness certificate not subject to the above conditions or limitations

. Additionally, all the sUAS proposed within this Petition for Exemption are small, weigh less than 10 lbs

. , have a flight speed of less than 100 mph, carry no pilots or passengers, carry no flammable fuel, are
electric

- powered, are operated below 400 feet, are operated at least 5 miles from an airport, and are flown within unaided, visual line of sight of a trained and licensed Pilot In Command. Plus, with built

- in
fail

- safes that include GPS Guidance technologies, Return to Home Features for lost signal a nd low battery emergencies, and for the ability to regain radio connection with the craft after a fail

- safe is engaged, it is clear the proposed aircraft have safety features equivalent to and superior to conventionalPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 24

aircraft that hold airworthiness certi ficates. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 21(h).



### 14 C.F.R. 27 : Airworthiness Standards

- Normal Category Rotorcraft

Title 14, Part 27 of the Code of Federal Regulations creates the procedural requi rements for airworthiness certification of Normal Category Rotorcraft. Due to the fact that the proposed aircraft contained within this Petition for Exemption are multi

- rotor aircraft, the Petitioner seeks exemption
from 14 C.F.R 27 for the same reasons s tated in the request for exemption from 14 C.F.R. 21(h).



### 14 C.F.R. 43.7 : Authorized Maintenance/Repair/Alteration Personnel

Title 14, Part 43, Section 43.7 of the Code of Federal Regulations regulates personnel authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. Proposed conditions 13 and 14 are applicable to this particular regulation and the FAA has found in fa vor of previous Exemption #11208 pertaining to this rule. Furthermore, it is the opinion of the Petitioner that the stated rule would create a burden as the Petitioner would have to find a regularly authorized conventional mechanic or otherwise licensed p ersonnel to sign off on an unconventional flight craft’s maintenance. More clearly, it would be difficult to find a mechanic that specializes in Cessna Repair that is also an expert in small
radio

- controlled multi

- rotors.

Additionally, it is likely that the operator of the sUAS (the PIC) would be more knowledgeable on the interworking’s of their sUAS than a regular mechanic as they likely have past RC flying experience. Particularly, the PICs working for the Petitioner will always have at least 25 hours of RC craft experience, in which time they will likely have to repair a prop for example. Due to the relative ease of replacing props on a multirotor (screw the broken one off and replace with a new one) it is not necessary for a
certified or authorized individual to sign off on the repair. Instead, the repair can easily be done by authorized personnel working for the Petitioner so long as the conditions and procedures stated above,
are followed. For these reasons it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.7.



### 14 C.F.R. 43.11 : Dispositions of Records for Inspections

Title 14, Part 43, Section 43.11 of the Code of Federal Regulations pertains to the disposition of Records for Inspections. Proposed condition number 13 pe rtains to this particular regulation and the FAA has found in favor of previous Exemption #11208 which contained this rule. For the reasons stated in Condition 13 (“Proposed Conditions of the Exemption”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 43.11.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 25



### 14 C.F.R. 45.11 : Making of Products

Title 14, Part 45, Section 45.11 of the Code of Federal Regulations pertains to the manufacturing of aircraft and major aircraft components, including, but not limited, aircraft bodies, aircraft engines, and aircraft propellers. This particular rule requires various procedures for marking each component with fireproof markings and, in a manner acceptable to the Federal Aviation Administration, for purposes of
identification. Proposed Condition for Exemption #30 above, pertains to this particular regulation and the FAA has ruled on it in previous Exemption #11208. For the reasons stated in Condition #30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt
from 14 C.F.R. 45.11.



### 14 C.F.R. 45.23(b) : Display of Marks; General

Title 14, Part 45, Section 45.23(b) of the Code of Federal Regulations states that;

 “ When marks include only the Roman ca pital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockp it, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.”

In a previous grant of exemption (Exemption #11062) it was determined b y the FAA that the exemption of sUAS operators from this provision was warranted so long as the aircraft, “have identification (N

Number) markings in accordance with 14 C.F.R. 45 (c) if the markings are as large as practicable.” As is stated in Proposed C ondition #30 above, the Petitioner will mark their aircraft with markings as large as practicable and therefore should be exempt from 14 C.F.R. 45.23(b).



### 14 C.F.R. 45.27 : Marking of the Aircraft

– Rotorcraft

According to Title 14, Part 45, Section 45.2 7, of the Code of Federal Regulations, the operator of a rotorcraft;

 Must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail, the marks required by 14 C.F.R. 45.23.

For the same reasons stated in the request for exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.27. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner res pectfully asks for exemption from 14 C.F.R. 45.27.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 26



### 14 C.F.R. 45.29 : Size of Marks

According to Title 14, Part 45, Section 45.29, of the Code of Federal Regulations, the operator of an aircraft;

 Must display on markings on the aircraft meeting the size requirements of this section  2

- 12 inches high depending on the aircraft type  Width 2/3s wide as the characters are high  1/6 th as thick as the characters are high  Not less than 1/4 th the character width  Uniform

For the same reasons stated in the request fo r exemption from 14 C.F.R. 45.23, the Petitioner believes it should be exempt from 14 C.F.R. 45.29. More clearly, due to Condition #30 above, which states that the Petitioner will mark their aircraft with markings as large as practicable, the Petitioner r espectfully asks for exemption from 14 C.F.R. 45.29.



### 14 C

. F

. R

. 61.3 : Requirement for Certificates, Ratings, and Authorizations

Title 14, Part 61, Section 61.3, of the Code of Federal Regulations pertains to the need for a Private Pilot’s license to ope rate an Unmanned Aerial Vehicle. The Petitioner seeks exemption from this rule to the extent that this rule requires a sUAS operator to hold a Private Pilot’s License. Clearly, the goal of this particular rule is to ensure the skill of any Pilot In Comma nd matches the operating area in which they are flying. However, it is the Petitioner’s belief that the measure of a Private Pilot’s License and the training that went into it is not necessarily connected to that Pilot’s ability to operate a small

unmann ed aircraft at low altitudes. Particularly, the requirement of a Private License yields potential
PICs that have been trained in multi

- thousand pound, manned aircraft, flying at high altitudes in comparison to 10 lbs. or less, battery

- powered craft, opera ted at 400 feet AGL or below. For this reason, it is the belief of the Petitioner that they be exempt from this rule as the requirement of a Private Pilot’s license is unnecessary. Furthermore, it is sta ted as such on the FAA website. 7

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

The authorization of Recreational and Sport Pilot Certificates as an alternative to a P rivate License points to a Private License as being a non

- requirement according to the FAA’s integration office. This further evidence shows that the Petitioner should be exempt from the aforementioned regulation. Clearly, the Petitioner’s requirement of all PICs (Proposed Condition #4) to hold at least a Recreational or SportPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 27

Pilot’s Certificate yields an authorized level of training according to the FAA’s own website and in turn, shows that such a requirement by the Petitioner offers an equivalent level of safety as is provided by existing rules.

Furthermore, Proposed Conditions #4, 6, 7, 8, and 9, among others, show the Petitioner’s commitment to safety and arguments for exemption from this rule.



### 14 C.F.R. 61.23(a) and (c) : Medical Certificates

– R equirements and Duration

According to Title 14, Part 61, Section 61.23 (a) & (c), of the Code of Federal Regulations, the operator of an aircraft is required to hold a Medical Certificate in various Pilot In Command Situations. As is stated in Proposed C ondition #4 above, the Pilot in Command will have at least a Sport’s Pilot’s License and at least a valid U.S. Driver’s license, which has been ruled by the FAA in previously granted exemptions as a suitable alternative to a valid medical certificate for t he authorized flights of unmanned systems. Furthermore, the FAA has posted on its website this new policy. 7 Due to Condition #4 above and the current FAA Policy displayed below, the Petitioner believes it should be grante d exemption from 14 C.F.R. 61.23(a) and (c).

“ The FAA also made two other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previ ously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.

 A third class medical certificate is no longer required

. Now, a Section 333 operator only needs a valid driver’s license to satisfy the medical requirement. This change is consistent with the agency’s approach for sport pilot certificate holders, who may fly light sport aircraft with a driver’s license and n o FAA medical certificate. ”



### 14 CFR 61.101(e) (4) and (5) : Recreational Pilot Privileges and Limitations

In Title 14, Part 61, Section 61.101(e) (4) & (5), of the Code of Federal Regulations, the FAA states that;

Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— for compensation or hire or in furtherance of a business.

As can be seen on the FAA’s website (https://www.faa.gov/news/updates/?newsId=82485);

“ The FAA also made t wo other changes to the Section 333 exemption process last week:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least aPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 28

privat e pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate.”

With the intention of Section 333 Exemptions being the integration of commercial unmanned systems into the National Airspa ce System, it is clear that the allowed pilot certificates now authorized by the FAA do not adhere to 14 C.F.R. 61.101 (e) (4) and (5) and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.101 (e) (4) and (5) because thi s Petition for Exemption is for the expressed purpose of conductin g commercial operations of sUAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition #4 above, it is the intention of the Peti tioner to provide commercial sUAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate. Therefore, in all likelihood, many PICs employed by the Petitioner wil l have these specific Certificates and as such, will need to be able to fly for compensation.

Furthermore, as is stated on the FAA’s own website and as is highlighted below ;

“ The FAA also made two other changes to the Section 333 exemption process last w eek:

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate. Previously, Section 333 operators were required to have at least a private pilot certificate. The newly added certificates are easier to obtain, and therefore less costly, than a private pilot certificate. ”

Therefore, it is highly likely that many potential PICs will have these Certificates as they are less costly and easier to obtain than a commercial Pilot’s License as an example. Fo r these reasons, it is clear that the Petitioner should be granted an exemption from 14 C.F.R. 61.101 (e) (4) and (5).



### 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations

– Pilot In Command

Title 14, Part 61, Section 61.113 of the Code of Federal Regulations states that;

Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire ; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.

Clearly this specific regulation conflicts with the Petitioner’s desire to provide commercial sUAS flights in the United States. Furthermore, some of the Petitioner ’s PICs will have Private Pilot Licenses and as such they will be operating an aircraft (the sUAS) for compensation or hire under the proposed Petition for Exemption.

With the intention of Section 333 Exemptions being the integration of commercial unmanne d systems into the National Airspace System, it is clear that the allowed pilot certificates now authorized by the FAA, including a private pilot’s license

, do not adhere to 14 C.F.R. 61.113 and thus, it is the belief of the Petitioner that they should be exempt from 14 C.F.R. 61.113 because this Petition for Exemption is forPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 29

the expressed purpose of conducting commercial operations of s UAS in an effort to earn compensation and/or further the business of the Petitioner. As is stated in Proposed Condition # 4 above, it is the intention of the Petitioner to provide commercial s UAS flights to customers through the use of a flight crew, consisting of a Pilot In Command that holds at least a Recreational or Sport Pilot Certificate (but who may also hold a Private License). In addition, the FAA has granted over 800 Section 333 Exemptions to businesses and individuals looking to provide commercial/compensation

- based sUAS flights.

Furthermore, looking at 61.113 (b), which states; A private pilot may, for compensat ion or hire, act as pilot in command of an aircraft in connection with any business or employment if:

 The flight is only incidental to that business or employment; and  The aircraft does not carry passengers or property for compensation or hire.

The Peti tioner seeks exemption from these rules as it is the Petitioner ’ s goal to fly s UAS missions for compensation or hire. Additionally, the specific provision pertaining to not flying aircraft that carry property for compensation or hire is something the Peti tioner would like to be exempt from as well

. Various forms of property may be carried on a s UAS, including; Camera Systems, Digital Imagery,
Sensors , and the like.

For all these reasons

, the Petition er seeks exemption from 14 C.F.R. 61.113 (a) and (b).



### 14 C

. F

. R . 61.315(a)(c): Privileges and Limits of Sport Pilot’s License

In Title 14, Part 61, Section 61.315(a), of the Code of Federal Regulations, the FAA states that;

If you hold a sport pilot certificate you may act as pilot in command of a light

- sp ort aircraft, except as specified in paragraph (c) of this section. Paragraph (c) reads the following;

You may not act as pilot in command of a light

- sport aircraft:

(1) That is carrying a passenger or property for compensation or hire.

(2) For compensati on or hire.

(3) In furtherance of a business.

(4) While carrying more than one passenger.

(5) At night.

(6) In Class A airspace.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 30

(7) In Class B, C, and D airspace, at an airport located in Class B, C, or D airspace, and to, from, through, or at an airport having an operational control tower unless you have met the requirements specified in §61.325.

(8) Outside the United States, unless you have prior authorization from the country in which you seek to operate. Your sport pilot certificate carries the limit “Holder does not meet ICAO requirements.”

(9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson.

(10) In a passenger

- carrying airlift sponsored by a charitable organization.

(11) At an altitude of more than 10, 000 feet MSL or 2,000 feet AGL, whichever is higher.

(12) When the flight or surface visibility is less than 3 statute miles.

(13) Without visual reference to the surface.

(14) If the aircraft:

(i) Has a VH greater than 87 knots CAS, unless you have met th e requirements of §61.327(b).

(ii) Has a VH less than or equal to 87 knots CAS, unless you have met the requirements of §61.327(a) or have logged flight time as pilot in command of an airplane with a VH less than or equal to 87 knots CAS before April 2, 20 10.

(15) Contrary to any operating limitation placed on the airworthiness certificate of the aircraft being flown.

(16) Contrary to any limit on your pilot certificate or airman medical certificate, or any other limit or endorsement from an authorized inst ructor.

(17) Contrary to any restriction or limitation on your U.S. driver's license or any restriction or limitation imposed by judicial or administrative order when using your driver's license to satisfy a requirement of this part.

(18) While towing any object.

(19) As a pilot flight crewmember on any aircraft for which more than one pilot is required by the type certificate of the aircraft or the regulations under which the flight is conducted.

The Petitioner requests exemption from numerous provisions contained in 14 C.F.R. 61.315 (a)(c). Particularly, the Petitioner requests exemption from the following subparts of 14 C.F.R. 61.315 (c); 1, 2, 3, 9, and 18. Furthermore, the Petitioner believes that the remaining subparts (4, 5, 6, 7, 8, 10, 11, 12,
13 , 14, 15, 16, 17, and 19) will be adhered to via proposed conditions conta ined in “ Proposed Conditions of the Exemption ” above. Specifically, subparts 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, and 19 are

cov ered by Proposed Conditions 1, 6 & 24, 6, 6, 1, 1, 3, 6 & 28, 6 & 28, 5, 25, 25, and 4 respectively.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 31

Additionally, pertaining to subparts 1, 2, 3, 9, 18, and 19, the Petitioner seeks exemption due to both unnecessary burdens on the Petitioner as well as a n equivalent level of safety as is provided by these existing subparts of 14 C.F.R. 61.315 (a)(c). Arguments for each subpart are contained below.

Subpart (1) of 14 C.F.R. 61.315 (c) states that a Sport

- Certified Pilot may not operate an aircraft if that aircraft is carrying passengers or property for hire/compensation. This is an unnecessary burden on the Petitioner as;

1. They will not be carrying any pass e ngers as they are flying Unmanned Systems, and;
2. There will be situations in which the Petitioner carr ies property for compensation.

The most likely of these situations will happen when a Petitioner is carrying a device or measurement tool owned by another person for compensation. This may includ e an imaging sensor owned by a third party for example. If a third party company owns the actual sensor but wants the Petitioner to utilize the tool on the Petitioner’s aircraft, the Petitioner will be flying with property for compensation. This compensation is related to the risk of loss while the camera is oper ating on the Unmanned System as well as the aerial perspecti ve achieved by the sensor on a s UAS that would otherwise be impossible to obtain if th e partner company only had the sensor. This example is common in many industries in which ground tools (such as cameras) are utilized on unmanned systems. Without exemption from this rule the Petitioner would have to either purchase the 3rd par ty sensor for use on their own s UAS or forego the compensation opportunity because they cannot carry the client’s tool a nd thus, not get the information the client desires. For this reason, it would be a significant burden to utilize a s UAS commercially without the ability to carry multiple sensors that may not be personally owned by the
Petitioner.

Furthermore, it is the belief of the Petitioner that an equivalent level of safety would be provided if exempt from this rule because of the extensive trai ning the PIC would have on the s UAS prior to flying commercially. This training will be in excess of the existing requireme nt to have at least a Sport Pilot’s or Recreational Certificate . Thus, the PIC will have sufficient manned aircraft and unmanned aircraft
traini ng to successfully operate the s UAS without endangering the public. The training procedures and training mater ials for the PIC can b e found in Exhibits 1 and 4 below.

In addition to subpart (1) of 14 C.F.R. 61.315 (a)(c), the Petitioner also requests exemption from subpart (2) which states that an operator with a Sport Pilot’s License may not operate an aircraft for compensation. As has been highlighted previously, the directive from Congress passed to the FAA via the FAA Modernization and Reform Act of 2012 was to integrate commercial UAV operations into the National Airspace System. Furthermore, in numerous p reviously filed and granted Petitions for Exemption under Section 333, it has been stated by the FAA that;

 The agency now allows operations under these exemptions by people who hold a recreational or sport pilot certificate.

This statement, combined with the initiative behind Section 333 exemptions (the commercial integration of UAV operations in the National Airspace System) shows that the FAA has found in favor of the idea that commercial UAV operations can be conducted by people who hold a recreational or sport pilot certificate. Additionally, this same argument can be made in regard to subpart (3) of 14 C.F.R.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 32

61.315 (a)(c), which states that a Sport

- Certified Pilot may not operate an aircraft in furtherance of a business. The FAA defines “Furtherance of a Business” as;

 A flight, even if incidental to your employment or the business you intend to conduct, and not required by your business or employment, would be considered “in furtherance of a business.” 10

Clearly, base d on this description, an aerial operation that is “in furtherance of a business” would be considered a lesser form of commercialization than flights for hire or compensation as these types of flights are incidental to a business as opposed to directly rel ated to the business, which is what a flight for compensation would likely be. Therefore, it is the belief of the Petitioner that they be exempt from this rule for the same justification as is proposed regarding 14 C.F.R. 61.315 (a)(c) (1) and (2).

On t op of subparts (1), (2), & (3) of 14 C.F.R. 61.315 (a)(c), the Petitioner also seeks relief from subpart (9) which states that a Sport

- Certified Pilot may not operate an aircraft to demonstrate that aircraft for sale. The Petitioner seeks exemption from th is rule as they will be carrying an inventory/stock/fleet of UAV aircraft in an effort to operate a commercial service business. Furthermore, this inventory/stock/fleet will turnover from time to time as new aircraft are added and old aircraft are release d by the company. In this event it will be important for the Petitioner to have the capability of showing off the aircraft to prospective buyers so that they can get the best price for their used systems. Plus, with PICs already being heavily trained and experienced with commercial flights, there is no added risk to allowing a qualified PIC to demonstrate the aircraft for sale to prospective buyers. The demonstration after all would be equivalent or less dangerous than a commercial flight that the PIC al ready performs on a frequent basis as part of their job as a commercial s UAS Pilot.

The Petitioner also seeks exemption from 14 C.F.R. 61.315 (c) (18) which states that a Sport

- Certified Pilot may not operate an aircraft while towing an object. It is th e belief of the Petitioner that they be exempt from this rule as the maximum takeoff weight of their aircraft will never exceed the max takeoff weight specifications highlighted by the manufacturer. These max takeoff weights are the maximum weight these a ircraft can carry (including themselves) and still fly effectively. Thus, any object being towed by the aircraft will have to weigh equal to or less than the maximum allowable weight in order to maintain or come under the max takeoff weight specifications highlighted by the manufacturer. Additionally, Proposed Condition 36 f rom the “ Proposed Conditions of the Exemption ” above, highlights reasoning as to why the Petiti oner believes their commercial s UAS flights in which objects are towed, would provide an equivalent level of safety as is provided by the existing rule. Particularly, the required and additional training necessary for a PIC to become an Object Towing PIC shows the skills that would be required to tow objects.

Furthermore, with the continued innovation in the world of sensors, it will be necessary for the Petitioner to be able to tow objects, such as tow

- behind sensors, in order to remain competitive with their competition. Tow

- behind sensors might m easure air quality , capture imagery, or perform various other data collection methods. Competing vehicles for these tow

- behind sensors would include ATVs, Motorcycles, Manned Aircraft, and the like. All of these potential alternatives are more expensive to operate, more dangerous to operate, and dirtier to operate. Each alternative would cost multiple thousands of dollars to purchase, are larger, powered by combustion engines, and carry flammable fuel. Additionally, they produce negative effects on the environment. For the reasons stated above, the Petitioner believe s they should be exempt from 14 C.F.R. 61.315 (c) (18).PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 33



### 14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

Title 14, Part 91, Section 91.7 (a) of the Code of Federal Regulations states; no pe rson may operate a civil aircraft unless it is in an airworthy condition. Proposed Condition #13 pertains to this particular regulation and the FAA has found in favor of previous Exemption #11062, 11063, and 11064, which
contained this rule. For the reas ons stated in Condition 13 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.7 (a) and the proposed condition offers an equivalent level of sa fety as is currently provided by the existing rule.



### 14 C.F.R. 91.9(b)(2) : Civil Aircraft Flight Manual

Title 14, Part 91, Section 91.9 (b) (2) of the Code of Federal Regulations states;

No person may operate a U.S.

- registered civil aircraft for which an Airplane or Rotorcraft Flight Manual is not required by Part 21.5 of this chapter, unless there is available, in the aircraft, a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination th ereof

. Proposed Condition #20 pertains to this particular regulation and the FAA has found in favor of previous Exemption s #11062, 11063, and 11064, which contained a request for exemption from this rule. For the reasons stated in Condition 20 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (b) (2). Furthermore, the proposed condition offers an equivalent level of safety as is currently provided by the existing rule as the Operating manuals about which this rule pertains are available to the operator at all times on the ground, just as they would be if the aircraft was carrying the operator. Thus, any information the operator desires abo ut the aircraft or its operating guidelines, can be found within documents within arm’s reach of the operator or on a digital device, such as a Smart Phone or tablet , easily accessible to the operator.



### 14 C.F.R. 91.9(c) : Civil Aircraft Marking, Placards

Title 14, Part 91, Section 91.9 (c) of the Code of Federal Regulations states; No person may operate a
U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. Proposed Condition #30 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Condition
30 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.9 (c). Furthermore, the proposed condition offers an equivalent level of safety as is

curre ntly provided by the existing rule as the FAA has previously determined that exemption from these requirements is warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart c, if the markings are as large as practicable.” 11PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 34



### 14 C.F.R. 91.103 : Preflight Action

Title 14, Part 91, Section 91.103 of the Code of Federal Regulations states;

Each pilot in command shall, before beginning a flight, become familiar wi th all available information concerning that flight. This information must include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight ca nnot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this sect ion, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Proposed Conditions # 3, 6, 12, 1 6, 17, 20, 22, 23 , 24, and 28 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reasons stated in Conditions 3, 6, 12, 16, 17, 20, 22, 23, 24, and 28 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.103. Furthermore, the proposed conditions offer an equivalen t level of safety as is currently provided by the existing rule as Preflight Planning is integral to the Petitioner’s sUAS flights and each mission will be carefully planned, taking into consideration weather, power requirements, aircraft operating guideli nes, and more, as seen in the proposed conditions above.



### 14 C.F.R. 91.105 : Flight Crewmembers at Stations

Title 14, Part 91, Section 91.105 of the Code of Federal Regulations states;

(a) During ta keoff and landing, and while en route, each required flight crewmember shall

—
(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the cr ewmember station.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 35

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.

Proposed Condition #4 pertains to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11185. For the reason stated in Condition #4 (“ Proposed Conditions of the Exemption ”) above, it i s the belief of the Petitioner that they be exempt from 14 C.F.R. 91.105. Furthermore, 14 C.F.R. 91.105 doesn’t really apply to the Petitioner ’s aircraft as all the aircraft requested b y the Petitioner weigh below 10 lbs. and do not carry a physical crew. As such, there is no cockpit or other operating area within the vehicle where a prospective crewmember would harness themselves in. Instead, all operations of the sUAS are executed from the ground from a designated operating area, in which, each crewmem ber has an assigned position at which they will stand during the operation. Generally, this standing area would be near the ground station for the PIC and in a pre

- designated area (which is determined by the PIC) for the VO. Utilizing pre

- determined stan ding areas for both the PIC and VO will ensure safe operating procedures of the Unmanned Vehicle.



### 14 C.F.R. 91.109 : Flight Instruction

Title 14, Part 91, Section 91.109 of the Code of Federal Regulations states;

(a) No person may operate a civil airc raft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

—
(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certifica te with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight re view required by§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by § 61.57 when

—
(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 36

(3) The instructor is c urrent and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b) , and has logged at least 25 hours of pilot

- in

- command flight
time i n the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless

—
(1) The other control seat is occupie d by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent
observer in t he aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- e ngine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

—
(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulati ng the controls has at least a private pilot certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on t hat certificate, or for apart 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in
command of th e aircraft.

Proposed Conditions #4, 7, 8, and 9 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemptions #11062, 11063, and 11064. For the reas ons stated in Conditions #4, 7, 8, and 9 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.109.



### 14 C.F.R. 91.113(b) : Right

- of

- Way Rules

Title 14, Part 91, Section 91.113(b) of the Code of Federal Regulations states;

(b) General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well
clear.

Prop osed Conditions #6 and 32 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule, including Exemption #11238. For the reasons stated in Conditions #6 and 32 (“ Proposed Conditions of the Exemption ”)PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 37

above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.113(b). Due to the fact that all the Petitioner’s sUAS operations will take place under the guida nce of a PIC and VO within Line of Sight of the aircraft, it is the belief of the Petitioner that their proposed operations offer an equivalent level of safety as is provided by the existing rule.



### 14 C.F.R. 91.119 : Minimum Safe Altitudes

Title 14, P art 91, Section 91.119 of the Code of Federal Regulations states;

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landi ng without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horiz ontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any

p erson, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Proposed Conditions #3, 6, 25, 26, 28, 29, and 34 pertain to this particular regulation and the FAA has found in favor of previous Exemptions which contained a request for exemption from this rule. For the reasons stated in Conditions #3, 6, 25, 26, 28, 29, and 34 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.119.

Each of the Proposed Conditions above create sUAS operations with equivalent safety to what the typical manned mission under 14 C.F.R. 91.119 would provide. Remember, when comparing to manned operations with manned flight craft, a sUAS is much smaller and light

- weight. Consider the fact that a manned aircraft weighs thousands of pounds, carries flammable fuel, and is powered by a combustionPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 38

engine. Clearly, carrying out a mission utilizing a sUAS would provide for a safer operation than would a conventional aircraft under 14 C.F.R. 91.119.



### 14 C.F.R. 91.121 : Altimeter Settings

Title 14, Part 91, Section 91.121 of the Code of Federal Regulations states;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departu re airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under§§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate
number o f feet specified below, according to the current reported altimeter setting:PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 39

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27. 91 through 27.42 2,500

27.41 through 26.92 3,000

Proposed Condition #3 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule base d on the idea that an equivalent level of safety could be provided so long as the Unmanned Aircraft was operated below 400 feet AGL, within Visual Line of Sight, and operated with a live, GPS

- based, Altitude
read

- out. For the reasons stated in Condition # 3 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.121 because they are receiving a live,
GPS

- Altitude, read

- out on each flight, they are ope rating below 400 feet AGL, and they are operating within Visual Line of Sight. Furthermore, as can be seen in Proposed Condition #3, each flight conducted by the Petitioner will begin with a zero

- altitude start point.



### 14 C.F.R. 91.151(a) : Fuel Requirem ents for VFR Flight Conditions

Title 14, Part 91, Section 91.151(a) of the Code of Federal Regulations states;

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Proposed Condition #17 pertains to this particular regulation and the FAA has found in favor of previous Exemptions, particularly Astraeus Aerial, which contained a request for exemption from this rule based on an equivalent level of safety being provided by a sUAS when ending a flight with at least 25% battery life remaining. Clearly, a percent battery life remaining is a better measure for safety when using a sUAS because the current battery capacities achieved by these types of v ehicles (including all the sUAS proposed in this Petition for E xemption) often do not allow for flight times of over 25 minutes, which isPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 40

far less than even the reserve time limits mandated by 14 C.F.R. 91.151(a). For the reasons stated in Condition #17 (“ Proposed Conditions of the Exemption ”) above, it is the belief of the Petitioner that they be exempt from 14 C.F.R. 91.151(a) because they can achieve an equivalent level of safety by terminating their flights with 25% battery life remaining.



### 14 C.F.R. 91.203(a) and (b) : Civil Aircraft

– Certifications Required

Title 14, Part 91, Section 91.203(a) and (b) of the Code of Federal Regulations states;

(a) Except as provided in§ 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An app ropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under§ 21.197(c) of this chapter, appropria te sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to t he aircraft under part 47 of this chapter

. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation withi n the United States, the second copy of the Aircraft Registration Application as provided for in§ 47.31(c) , or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness cer tificate required by paragraph (a) of this section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Proposed Condition #20 pertains to this particular regulat ion and the FAA has found in favor of previous Exemptions, particularly Exemptions #11062, 11063, and 11064, which contained a request for exemption from this rule. Additionally, all required paperwork will be available to the PIC and VO on the ground as these are Unmanned Systems as opposed to manned aircraft. This paperwork may be in
hard

- copy form or available through a link on the internet, such as a Google Drive account for example.



### 14 C.F.R. 215 : ATC Transponder and Altitude Reporting Equipment a nd Use

Title 14, Part 91, Section 91.215 of the Code of Federal Regulations states;

(a) All airspace: U.S.

- registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter , ATC transponder equipment installed must meet the performance and environmentalPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 41

requirements of any class of TSO

- C74b (Mode A) or any class of TSO

- C74c (M ode A with altitude reporting capability) as appropriate, or the appropriate class of TSO

- C112 (Mode S).

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) thr ough (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C

- 112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot increments. This requirement applies

—
(1) All aircraft. In Class A, Class B, and Class C airspace areas;

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally
certificated with a n engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provid ed such operations are conducted

—
(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower; and

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider

—
(i) In all airspace of the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspac e at and below 2,500 feet above the surface; and

(ii) In the airspace from the surface to 10,000 feet MSL within a 10

- nautical

- mile radius of any airport listed in appendix D, section 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated for that airport.

(c) Transponder

- on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 42

(d) ATC authorized deviations. Requests for ATC authorized deviations must be made to the ATC facility having jurisdiction over the concerned airspace within the time periods specified as follows:

(1) For operation of an aircraft with an operating transponder but without operating automatic pressure altitude repo rting equipment having a Mode C apability, the request may be made at any time.

(2) For operation of an aircraft with an inoperative transponder to the airp ort of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made or both, the request may be made at any time.

(3) For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation.

Proposed Conditions #3, 25, 26, and 27 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions, and particularly all the reporting requirements cont ained in an
ATO

- Issued COA, the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with reporting standards as set forth in the rule.



### 14 C.F.R. 91.403 : General

Title 14, Part 91, Se ction 91.403 of the Code of Federal Regulations states;

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter

. (b) No person may perfor m maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter

. (c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions
for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator underpart 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

(d) A person must not alter an aircraft based on a supplemental type certificate unless the owner or operator of the aircraft is the holder of the supplemental type certificate, or has written permission
from the holder.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 43



### 14 C.F.R. 91.405(a) : Maintenance Required

Title 14, Part 91, Section 91.405(a) of the Code of Federal Regulations states;

Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by followi ng the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 91.407(a)(1) : Operatio n after Maintenance or Alteration

Title 14, Part 91, Section 91.407(a)(1) of the Code of Federal Regulations states;

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—
(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



### 14 C.F.R. 409(a)(1) and (2) : Inspections

Title 14, Part 91, Section 91.409(a)(1) and (2) of the Cod e of Federal Regulations states;

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—
(1) An annual inspection in accordance with part 43 of this chapter a nd has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 44

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of safety as is provided by the existing rule and ensure adequate compliance with maintenance st andards as set forth
in the rule.



### 14 C.F.R. 91.417(a) and (b) : Maintenance Records

Title 14, Part 91, Section 91.417(a) and (b) of the Code of Federal Regulations states;

(a) Except for work performed in accordance with§§ 91.411 and 91.413 , each re gistered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other requ ired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.
The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return
to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft w hich are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time a nd date when the next action is required.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 45 (vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retai n the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specifie d in paragraph (a)(2) of this section shall be retained and transferred
with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter
shall be retained until the defects are repaired and the aircraft is approved for return to service.

Proposed Conditions #13, 14, and 15 pertain to this particular regulation. Clearly, by following the aforementioned Proposed Conditions the Petitioner can provide an equivalent level of saf ety as is provided by the existing rule and ensure adequate compliance with maintenance standards as set forth
in the rule.



## Privacy

When discussing the use of s mall Unmanned Aerial Vehicles, the question of privacy frequently comes up. The reason fo r this is clear as small unmanned aircraft, despite their incredible uses as a tool, also have the potential to be used for nefarious activities, such as spying for example. This presents a risk to the personal privacy of individuals. Furthermore, in les s extreme cases of invasion of privacy, a small unmanned craft might accidently capture imagery that would comprise someone’s privacy. Due to these potential privacy risks it is imperative for operators of small unmanned craft to use their aircraft

respon sibly and focus on mitigating any of the potential privacy risks their aircraft creates. The Petitioner is particularly aware of the privacy concerns of individuals and due to this is extremely focused on providing privacy not only for individuals, but al so for customers.



## Public Interest and Safety

According to the Federal Aviation Administration Guidelines for Section 333 Exemptions there are three main criteria a successful Petition for Exemption under Section 333 should have;

1. The Petitioner must sub mit a request for exemption from a rule or set of rules contained in 14
C

. F

. R

. that the Petitioner believe s will be a burden for their operations.

2. The Petitioner must provide a level of safety at least equal to that provided by the rule from
which the Pet itioner is seeking a n exemption, and;

3. The Petitioner’s request must be in the Public Interest.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 46

To satisfy these main guidelines, the following information will cover the justification of the proposed commercial operations under Section 333 requested by th is Petition. More clearly, the following arguments will show how each of the proposed applications/use

- cases are in the public interest and promote safety.

Specifically, the sUAS flights proposed in this petition will increase safety for the following app lications; Cinematography, Insurance, Railroad Services , and Search and Rescue. Furthermore, it wi ll be seen that
the use of sUAS by the Petitioner will also promote safety and reduce negative environmental impacts. This will be achieved because of the lower risks associated with a small, plastic, battery

- powered sUAS,

as compa red to a manned, multi

- thousand

- pound, combustion

- engine

- powered, flammable

- fuel

carrying aircr aft. Plus, with most sUAS data

- capture happen ing at low altitudes, because of the
enhanced da ta resolution possible at low altitudes, customers of sUAS services are getting better, more accurate data, while at the same time the public is avoiding the potentially hazardous practice of ultra

low

- flying manned aircraft.

Clearly, the combination of better, more accurate data, coupled with the enhanced safety of a sUAS over manned aircraft, produces a viable commercial operation that promotes the public interest.
Evidence of this can be found in the ind ustry

- specific examples below

. In addition to the aforementioned safety benefits and promotion of public interest s, it should also be noted that all the sUAS aircraft utilized by the Petitioner satisfy the directives passed to the Federal Aviation Administration by Congress in t he Reform Act of 2012 . Specifically, all of the Petitioner’s aircraft satisfy the size, weight, speed, operating capabilities, proximity to airports, proximity to populated areas, and visual li ne of sight rules and requirements laid out by Congress.

Furthermore, due to the FAA precedent of requi ring, at minimum, a Sport Pilot Certificate, the FAA can be assured that all commercial flights proposed in this Petition do not pose a threat to Natio nal Security as all PIC’s will have already been vetted by the Department of Homeland Security. For these reasons and for the numerous arguments contained herein, this Petition for Exemption provides strong justification for approval of commercial operati ons for the above

- stated sUAS in the above

- stated applications and use

- cases under Section 333, pursuant to the operating procedures and requirements
described herein.

Furthermore, contained in the FAA Modernization and Reform Act of 2012 was Congress’ c lear initiative to integrate commercial sUAS flights into the National Airspace System. With this initiative it is definitive that Congress believ es that the integration of commercial sUAS into the National Airspace System is within the Public Interest as they are, obviously, elected representatives of the public assigned with the duty of driving policy that promotes the Public Interest. Thus, in addition to the industry

specific examples below, it should also be considered t hat the integration of all sUA S , pursuant to their safe integration to the NAS and providing of at least an equivalent level of safety as is provided by the current FAA rules, is inherently within the public interest.

Please look below to find more detailed descriptions as to why each of the applications highlighted above can provide a benefit to the public as a whole and r easons why the exemption would not adversely affect safe ty

.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 47



### Cinematography

The Aerial Cinematography Industry is an industry that has been operating for many years to capture
cinema

- quality footage from low altitudes. Initially

, this type of cinemato graphy was captured using
fixed

- wings and helicopters, but in more recent years, the business has started to utilize UAVs. The reason the industry has transitioned to these small aircraft is because newer UAV systems have been able to capture the quality video the industry is looking for but at a much lower cost and with significantly lower risks.

One of the reasons manned aircraft cinematography is so expensive is because of the dangers
associated with flying a 6,000

- pound aircraft, filled with flammable fuel, powered by a combustion engine, at low altitudes a nd over people. The insurance costs alone for these types of activities are high and accidents have happened in the industry. Some of these accidents have even lead t o casualties. A couple years ago, 10 people died when two helicopters crashed while fil ming the French Realty Show, “Dropped.” 13

Whenever you have manned aircraft operating at low altitudes there are added risks. These risks include ground structures, confined spaces, and more. Additionally, when you have manned aircraft, any accidents a re much more catastrophic than if you had the same situation with unmanned aircraft. Once again, this is because of the size and flammable fuel carried on

- board manned aircraft. A small Unmanned Aircraft does not have these attributes, plus, because ther e are no people on board, the chances of causalities is lower because there is no pilot.

It is important to remember that the weight of the UAVs utilized by the Petitioner will weigh no more
than 10 pounds and contain no crew, flammable fuel, or combustio n engine. This limited weight and size will significantly reduce the potential for casualties or mass property damage in the case of a crash.

F urthermore, the use of electric

- power by the Petitioner’s UAVs is much more environmentally

- friendly
than that of a manned aircraft, which is carrying a significant amount of unnecessary weight using
carbon

- based fuel sources. Therefore, in addition to the increased safety obtained by a UAV performing aerial cinematography, there is also the added public benefit o f a healthier environment.

Furthermore, while traditional aerial cinematography utilizing conventional aircraft can perform in close proximity to people and property, it should be pointed out that a UAV is even safer than the traditional
methods becau se of the limited size, weight, speed, operating conditions, and safety features included on the proposed aircraft within this petition. Additionally, as is highlighted in the FAA Modernization and Reform Act of 2012, the integration of UAS into the Natio nal Airspace System is inherently in the public interest so long as it can be accomplished with at least an equivalent level of safety as is currently provided by existing FAA rules and regulations.

On top of this, the utilization of sUAS in the Aerial C inematography Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircraft. The reasoning for this can be seen below;

 Dull

– Aerial Cinematography is an industry that requires repetitive flights. There are often multiple takes of the same scene in order to get the perfect shot with the perfect lighting. For this reason, the same flight has to occur several times in a short time period. This isn’tPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 48 necessarily efficient for a manned aircr aft because it needs to stay aloft during filming and due to this, wastes time and fuel waiting for successive shots. A UAV on the other hand can land in between shots and use significantly less power. Plus, because of the inherent risks of flying at low altitudes for manned aircraft (structures, people, obstacles, etc.), repetitive shots require repe titive risky flight operations. In instances where R. J. Corman Railroad Group is capturing aerial content for marketing purposes, it would be much more cos t

efficient and safe to utilize a UAV than to use a manned aircraft.

 Dangerous

– Aerial Cinematography is almost always done at very low altitudes, which is very dangerous airspace for large, manned aircraft. There are more obstacles to consider at
l ow altitudes and less margin for error. Therefore

, aerial cinematography flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a
crash. In the Railroad Industry, flight operations may involve confined spaces and various obstacles. Railroad tunnels as an example would be a location i n which a manned aircraft would not fly. Additionally, an railroads that travel through the mountains or through forests would include many natural obstacles, such as tree, boulders, cliffs, and the like.
Each of these feature increases the risk associat ed with manned aircraft as pilots need to be hyper

- alert in order to avoid an accident.

 Dirty

– Some aerial cinematography is extreme in nature and ma y include things like fire, smoke, noxious fumes, or the like

. In the case of a train derailment , various "dirty" hazards could be present. In these situations it may be best to utilize an unmanned craft to assess the situation before sending humans into the scene. In the case of a derailment of a train carrying hazardous or explosive cargo, it may be necessary to send an unmanned aircraft in to assess the nature of the situation before exposing humans to a potential explosion or poisonous environment.

 Deep

– Some aerial cinematography might require capabilities that only an unmanned
aircraft can perform, such as flying in extremely close proximity to structures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason an unmanned aircraft w ould be required.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Aerial Cinematography Industry as being within the public interest.

 Exemption Numbers:

o 11540PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 49

o 11153

o 12031



### Insurance

Another industry that stands to gain from the utilization of sUAS aircraft is the insurance industry. One
of the reasons for this is the obvious benefit an aerial perspective can be when assessing an insured

asset. The ability to get above the insured asset allows for a clearer perspective of the situation and provides a bird’s eye view of the conditions below . This allows for more accurate insurance est im ates and payouts.

T h e use of UAVs and software allow s for more efficient and automated practices. As an example, a software progra m that can utilize image recognition technology to estimate losses would be much more
automated

, and potentially more acc urate
, than a team of adjusters who all might have slightly different biases when making assessments. Over the past couple year s, several insurance companies and service providers have developed image software to assess various insured assests, such as bu ildings, houses, agricultural crops, roofs, and more. Additionally, several companies have also developed various ways of using sensors on UAV systems to provide asset owners with a way to inspect their assets for insurance purposes and compliance. Some of these companies have specifically focused on infrastructure, such as wind turbines, dams, water towers, and the like. Moving forward, R. J. Corman Railroad Group, LLC. would like to provide these same types of inspection/assessment services for

ope rato rs in the Railroad Industry to provide railroads with important information relating to their
assets and infrastructure.

For example, due to the fact R.J. Corman Railroad Group specializes in Train Derailment Services, they could easily provide various a erial assessments after a derailment in order to record the scene and collect valuable information for any future insurance claims or litigation. Furthermore, because R. J. Corman already uses manned

- helicopters within their business, they have unique exp erience as it pertains to assessing railroads from the air.

Finally , the Insurance application points to the use of sUAS according to the 4D’s of UAV Intervention

.
 Du ll

– The insurance application often requires repeated flights of the same area or on

- demand flights. In the case of a train derailment, multiple passes over a specific flight area may be required. In some situations

, the environment may be hazardous to manned aircraft, including situations in which there is an abundance of ground

- based obstacles such as trees, rock outcroppings, or the like. Due to the need for repeated passes, this type of flight repeatedly exposes manned a ircraft to ground

- based hazards.

 Dangerous

– Insurance flights can also be dangerous. Consider a train derail ment. If R. J. Corman Railroad Group were to fly over a derailed train in an effort to collect valuable data, there may be many dangers, including; fires, smoke, hazardous spills, or the like. These hazardsPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 50

can make for an extremely dangerous situation a nd if you couple them with enviromental hazards such as extreme terrain, it can be very dangerous for manned aircraft.

 Dirty

– Consider a hazardous spill that came as a result of a d erailed train . This example is an insurance event in which an adjus ter is going to want to assess the damage while avoiding a dangerous environment. Noxious fumes may be in the area and as such, the adj uster might
want the area flown with a sUAS.

 Deep

– Once again, sUAS all ow for operators to capture high

- resolution data at low altitudes. This is true in the Insurance Industry as well and low altitude flight can be especially dangerous
for manned air craft. In particular, any high

- resolution data

- collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Additionally, the following previously granted exemptions point to the FAA’s acceptance of sUAS use in the Insurance Industry as being within the public interest.

 Exemption Numbers:

o 11293

o 11857



### Railroad Services

The Railroad Service Industry is at the core of R. J. Corman Railroad Group, LLC. Moving forward, R. J. Corman Railroad Group would like to provide various aerial services to operators within the railroad industry. Among these services, R. J. Corman may provide services relating to infrastructure inspections, train derailment assessment, marketing, and other related services.

It is the belief of R. J. Corman Railroad Group, LLC. that th ey can provide h igh

- quality, high

- resolution imagery that can assist those in the Railroad Industry better service their infrastructure and promote
their businesses.

In terms of Railroad management, imagery

- data and 3D modeling can help railroads gain confidence in their operations and efficiency in their practices. In particular, aerial imagery can be used for various forms of compliance, be it organiz ational compliance relating to safety or other benchmarks or whether it be compliance with outside parties, such as insurance companies, banks, or government agencies.

Furthermore, aerial imagery provided by a UAV can assist in various railroad service ef forts, such as infrastructure inspection, train derailment assessments, and the like. Additionally, in the event of an environmentally

- impactful derailment, aerial services related to environmental protection can be
executed in an effor t to minimize a pot entially haza rdous situation. Finally, in various repair or clean

- upPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 51

situations that require the use of large equipment, an aerial perspective, provided by a UAV, can be valuable as it pertains to that piece of equipment’s move ment around the job site, en suring it doesn't come into contact with any obstacles or other equipment.

Railroads are a vital transportation network throughout the United States. They transport products and people and provide a cost

- effective means of moving material from Point A t o Point B. The upkeep of
these rail

- lines is important for our economy as the flow of many goods across the country are dependent on the railroads. For this reason, it i s the belief of the Petitioner t hat providing aerial services to the railroad industry is within the public good. Furthermore, by following the c onditions
with in this exemption petition and the rules and regulations of the FAA, it is the belief of t he Pet itioner that they can pro vide railroad services while m a i ntaining an equivalent level of safety as is provided by existing rules

. Referring back to the 4 D analysis of UAV use, it is clear that the Railroad Services Industry would benefit
from the use of UAV systems over manned aircraft because;

 Dull

– Railroad Service flights may require a lot of repetition and/or rapid deployment of a data capture device to ensure data is captured at the right time. A railroad company looking to quell
runoff issues into local lakes and streams after a train derailment for example, may want to examine 3D maps as soon as possible after a derailment

. Having this imagey can help them document exactly what happened and have concrete information in the future if any of it is
needed for insurance purposes or litigation. Cap turing 3D imagery can be a mono ton ous task as it requires a robotic

- like flight route, which is best executed when using a flight computer and
GPS module onboad a sUAS

.

 Dangerous

– Railroad Service flights can be dangerous. Consider an aerial service flight over a
derailed train

. If R. J. Corman Railroad Group were to fly over a derailed train in an effort to collect valuable data, there may be many dangers, including; fires, smoke, hazardous spills, or the like. These hazards can make for an extremely dangerous situation a nd if y ou couple them
with enviroment and terrain hazards , it can be very dangerous for manned aircraft.

 Dirty

– Consider a hazardous spill that came as a result of a d erailed train . This example is a
Railroad Service event in which a railroad repair companies and engineers are going to want to assess the damage while avoiding a dangerous env ironment

.

 Deep

– Once again, sUAS allo w for operators to capture high

- resolution data at low al titudes.
This is true in the Railroad Service Industry as well

, and low altitude flight can be especially dangerous for manned air craft. In particular, any high

- resolution data collection at low altitudes and in confined areas can be impossible for manned aircraft as their maneuverability is such that the confined area is too small for safe flight.

Therefore, the promotion of the public interest described above

, coupled with the enhanced safety provided by sUAS flights in the Railroad Service Industry, strongly supports the granting of this petition.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 52

Furthermore, the followi ng previously granted exemption point to the FAA’s acceptance of sUAS us e in
the Railr o ad Industry as being within the public interest.

 Exemption Numbers:

o 11206



### Search and Rescue

The Search and Rescue Industry is an industry in which small unmanned aircraft will play a vital role moving forward. This industry is kno wn for its rapid response times which are needed in order to save lives. Furthermore, the situations and environments common in this industry require documented visual observance over broad areas. Currently, much of this is done using aerial imaging from a manned aircraft. The imagery captured on these flights is vital not only when it comes to finding lost people but also in documenting areas that have already been searched. In a searching effort this is important
because searchers don’t want to waste time looking in areas that have already been searched.

Utilizing a UAV allows for searchers to get an aerial vantage point as well as document areas that have been searched accurately. For instance, a search crew could map the areas of interest using t heir UAV, stitching the images they get from the camera and have a georeferenced map of the area in question. In most cases this map is laid over Google Earth and can clearly mark an area that has already been searched. Additionally, because the map is g eoreferenced, the user can pinpoint locations or objects of interest and pull a latitude and longitude for a more detailed search. This is a highly valuable attribute of stitched imagery from a UAV.

In addition, a UAV can provide a superior vantage point for searchers operating on the ground. The UAV utilized by the Pet itioner offers long

- range, high

- definition FPV

, which can be used by a team leader to relay to his ground searchers where to move next and if he sees anything of interest from the air.

T he Petitioner seeks exemption under Section 333 in an effort to gain the right to provide services to the Search and Rescue Industry in order to help in situations where a visual inspection from the air is necessary. The Petitioner seeks this exemption be cause they believe the use of unmanned aircraft in this industry will provide a public good while maintaining the safety of the National Airspace System.

The Petitioner’s UAV is rapidly deployable meaning it can help in time

- sensitive rescue efforts.
Ad ditionally , with its ability to take high

- definition video and pictures while georeferencing all of its images, the Petitioner’s UAV can be a valuable asset to a Search and Rescue Team. Plus, with the aerial perspective this type of UAV can provide, the c hances of finding a lost or periled individual increase. Clearly, finding and saving lost people is a public good and one that can be bolstered through the use of

a UAV.

Furthermore, utilizing a UAV for this type of work is a safer alternative when com pared to manned aircraft. This is the case because often these flights will happen at low altitudes where the risk of collision with ground

- based features, obstacles, or the like

, are greatest. A manned aircraft is not as well suited for these flying env ironments because they are bigger than sUAS, they carry a crew, they are not as maneuverable, and they carry flammable fuel. When you couple this with their higher costs toPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 53

operate, it is clear that an unmanned craft can provide value in terms of cost sa vings and enhanced safety to the Search and Rescue Industry.

On top of this, the utilization of sUAS in the Search and Rescue Industry falls in line with the 4D’s of UAS Intervention, which points to the Public Interest of using UAVs over manned aircra ft. The reasoning for this can be seen below;

 Dull

– The Search and Rescue Industry is an industry that requires dull flights. Often, especially
with fixed

- wing aircraft, a pilot must fly his plane over a specific area of interest in a very specific
and straight

- line pattern. This is to ensure complete coverage of the search zone. This causes the pilot to fly the s ame straight

- line routes, one next to the other, over and over. The
“dull ness” of this type of flight can lead to accidents. With a sUAS, t he Petitioner has the ability to utilize preprogrammed flight routes, which can automate the process and allow for safe operations.

 Dangerous

– Aerial Search and Rescue Imagery is often captured at low altitudes, which is very dangerous airspace for la rge, manned aircraft. There are more obstacles to consider at low altitudes and less margin for error. Therefore, Search and Rescue flights using manned aircraft are more dangerous than if the same manned aircraft were operating at higher altitudes with less obstacles and more space. Thus, an unmanned craft is a safer alternative as it is more maneuverable in confined spaces and less damaging in the case of a crash as it weighs significantly less and doesn’t carry a crew or flammable fuel.  Dirty

– Aer ial Search and Rescue Imagery is sometimes captured in hazardous environments. While the Petitioner’s UAV system would be maintaining a safe distance from these potential hazards and remaining within line of sight, it is important to consider that mistake s can happen in unpredictable situations. For instance, if a UAV is being used to provide a live

- feed view of a rescue situation, there may be a host of unpredictable hazards such as rock

- falls, avalanches, or
the like. In each of these situations it wou ld be better to have an expendable UAV system rather
than a manned aircraft with lives onboard.

 Deep

– Some Search and Rescue imaging may require capabilities that only an unmanned aircraft can perform, such as flying in close proximity to natural fe atures or other obstacles at low speeds. This type of application would be impossible for most manned aircraft and if not impossible, fairly dangerous. For this reason

, an unmanned aircraft would be required.

Additionally, the following previously gr anted exemption points to the FAA’s acceptance of sUAS use in the Search and Rescue Industry as being within the public interest.

 Exemption Number:

o 11419PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 54



## Regulations Requested for Exemption

Appendix 1: Regulations Requested for Exemption

– List

https://drive.google .com/file/d/0B8sknt2zpxhMajc4dHA2bjE4bjg/view?usp=sharing



## Exhibit List

Exhibit 1: R. J. Corman Railroad Group, LLC. Operations Manual

https://drive.google.com/file/d/0B8sknt2zpxhMM0ZzTEFBMDhGUWM/view?usp=sharing



### Exhibit 2: R. J. Corman Railroad Group, LLC. Logbook Example

Below is a logbook example from the app that is running the Flight Logs for the Petitioner’s aircraft. The specific flight logs pictured are just an example and not specific to the Petitioner’s prior flights. In addition to the logbook, please see the linked video ( http s://www.youtube.com/watch?v=4afE

- rd6xoY ) that shows how the flight logs can be played back utilizing the same logging app for each flight.PETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 55



### Exhibit 3: R. J. Corman Railroad Group, LLC. Visual Observer Training Procedures & Guide

Visual Observer Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Visual Observer Training Guide

https://drive.google.com/file/d/0B8sknt2zpxhMbElBZTcwUi02aHM/view?usp=sharing



### Exhibit 4: R. J. Corman Railroad Group, LLC. Pilot In Command Training Guide

Pilot In Command Training Procedures

https://drive.google.com/file/d/0B8sknt2zpxhMNFllQVJZdHVsQ0E/view?usp=sharing



### Pilot in Command Tr aining Guide

https://drive.google.com/file/d/0B8sknt2zpxhMREF0OHZLZ25Jc2M/view?usp=sharing



### E xhibit 5 : DJI Inspire 1

http://www.dji.com/product/inspire

- 1



### Exhibit 6 : DJI Inspire 1 User Manual

http://download.dji

- innovations.com/downloads/inspire_1/en/ Inspire_1_User_Manual_v1.2_en.pdf



### Exhibit 7 : DJI Inspire 1 Quick Start Guide

http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_ 1_Quick_Start_Guide_en.pdfPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 56



### Exhibit 8 : DJI Inspire 1 Features

http://www.dji.com/product/inspire

- 1/feature



### Exhibit 9 : DJI Inspire 1 Specifications

http://www.dji.com/product/inspire

- 1/spec



### Exhibit 10 : DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire

- 1/flight

- control



### Exhibit 11 : DJI Inspire 1 Smart Battery Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en .pdf



### Exhibit 12 : DJI Matrice 100

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100



### Exhibit 13 : DJI Matrice 100 User Manual

http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf



### Exhibit 14 : DJI Matrice 100 Features

http://dev.dji.com/en/products/flying

- platforms/matrice

- 100/features



### Exhibit 15 : DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flyin g

- platforms/matrice

- 100/specsPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 57



### Exhibit 16 : DJI Matrice 100 Smart Battery Manual

http://download.dji

innovations.com/downloads /dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf



## References

1.) 

### NTSB. Michael P. Huerta, Administrator, Federal Aviation Administration v. Raphael

Pirker . Washington, DC: National Transportation Safety Board, 17 Nov. 2014.
PDF. Aircraft De finition.

2.) 

### Administration, Federal Aviation. "FAA Streamlines UAS COAs for Section 333." FAA.gov

.

Federal Aviation Administration, 24 Mar. 2015. Web. 5 Nov. 2015.

3.) 

### Administration, Federal Aviation. "Section 333 Petition Guidance & Checklist." (n.d.): n.

pa g. FAA.gov . Federal Aviation Administration. Web. Conditions for a successful Exemption.

4.) 

### Watts, Adam C., Vincent G. Ambrosia, and Everett A. Hinkley. Unmanned Aircraft

Systems in Remote Sensing and Scientific Research: Classification and Consideration of Use . Basel, Switzerland:

w ww.mdpi.com/journal/remotesensing, 8 June 2012. PDF. "D's" of Unmanned
Aircraft Use.

5.) 

### SKYbrary. "Unmanned Aircraft Systems."

- SKYbrary Aviation Safety. N.p., n.d. Web.

20 July 2015.

6.) 

### Administration, Federal Aviation. "Public Guid ance for Petitions for Exemption under

Section 333." FAA.gov . Federal Av iation Administration, n.d. Web.

7.) 

### "FAA Summary Grants Speed UAS Exemptions." FAA Summary Grants Speed UAS

Exemptions. Federal Aviation Administration, n.d. Web. 20 July 2015. Permittin g Recreational and Sport Pilot Certificates.

8.) 

### FAR Part 91

- Basic VFR Weather Minimums, Code of Federal Regulations § 91.155

(2004). Print.

9.) 

### Administration, Transportation Security. "Vetting of Airmen Certificates and General

Aviation Airport Access and S ecurity Procedures." Department of HomelandPETITIONER

– R. J. Corman Railroad Group, LLC. DOCUMENT PREPARER

– DMZ Marketing, LLC. 58 

### Security . Office of Inspector General, 7 July 2011. Web. 5 Nov. 2015.

10.) 

### MacPherson, Rebecca B. "U.S. DOT / FAA

- Office of the Chief Counsel." Letter to Mr.

Timothy John Gilbert. 25 Feb. 2011. MS. 800 Independenc e Ave. S.W., Washington, DC, Maryland. Clarification on "Furtherance of a business."

11.) 

### Federal Aviation Administration . "Exemption No. 11062A Regulatory Docket No. FAA

2014

- 0352." Department of T ransportation, 23 July 2015. PDF

.

12.) 

### Jensen, Warren, PhD. Gro und

- Based Visual Observer/Crewmember Training for UAS

.

New York, NY: Slideserve.com, 9 July 2008. PPT. Visual Observer and Pilot In Command Training Guidance and Format.

13.) 

### "Olympic Medalists among 10 Dead as Reality TV Choppers Collide." NBC News . NBC,

n.d

. Web. 20 July 2015.


## Exemption References

Exemption # 11467

Exemption # 11905

Exemption # 11797

Exemption # 12031

Exemption # 11865

Exemption # 11364

Exemption # 11587

Exemption # 11857

Exemption # 11293

Exemption # 11814

Exemption # 11540

Exemption # 113 45