Victor Morrel Aero L.L.C. 10 Hartford Lane Sangerville Maine 04479 207 924 5905 jakemorrel@yahoo.com
February OS 2016



### U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Dear Sir or Madam: This application is being submitted on my own behalfwithout council orconsulting services.

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Aero L.L.C., operator ofSmall Unmanned Aircraft Systems ("SUAS's) equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits SUAS's, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333.1.

As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive SUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 

### 3) controlled. The proposed exemption, 

### ifgranted, would allow Aero L.L.C. to conduct commercial operations ofsmall unmanned aircraft systems ("UAS") 

### meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333.Aero L.L.C. is an image processing companythat plans to exploitthe capabilities of Unmanned Aerial Systems to offer a multitude ofservices, including but not limited to:

Aerial Surveying Remote Sensing Event Photography/Videography Agriculture purposes Real Estate Photography Aerial filmmaking and photography Construction site inspections and monitoring Wildlife and forestry monitoring Educational and research operations
StatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval ofcommercial UAS operations.


### The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested:

- 14C.F.R. Part 21

- 14 C.F.R. 45.23 (b)

- 14 C.F.R. 61.23(a) and(c) -14 C.F.R. 61.101(e)(4) and (5) -14 C.F.R. 61.113(a) -14 C.F.R. 61.315(a)

- 14C.F.R. 91.7(a)- 14C.F.R. 9l.ll9(c)

- 14C.F.R. 91.121

- 14 C.F.R. 91.151(a)(1) -14 C.F.R. 91.405(a) -14 C.F.R. 91.407(a)(1)

- 14 C.F.R. 91.409(a)(1) and(2)

- 14C.F.R. 91.417(a) and (b)

Petitioner Experience Petitioner holds a Commercial Pilots License, single engine land and sea, instrument airplane(2217096), Flight lnstructor(2217096CFI), and Mechanic(2217096). Petitioner has a currentflight review and holds a Maine driver's license (2770083).

Unmanned Aircraft System

SUASs are oftentimes seen as superiorto helicopters dueto the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impactwhich promotes public safety.

This is a petition for exemption to enable Aero L.L.C. to operate a Blade Chroma equipped with threeaxis gimbals and using High-Def. cameras. This SUAS has a pre-programmed limitfor 400ft. AGL and a GEO fence while in Smart Mode with a distance limit of300ft. from the controller. These limits remove the possibility ofenteringthe Class B, Cand Dairspace thus enhancing the level ofsafety duringoperations. The Blade Chroma also has thefailsafe function ofthe autopilot system, which means when the communication between the Main controller and thetransmitter is disconnected, the outputs ofall command sticks from the controllerwill go tothe center position. Ifthe GPS signal is good enough, the system will automaticallytrigger Return to Home and will land safely ifthe communication is not re-established within a pre-programmed amount oftime from the factory.

The above specifications meetwith the Model Aircraft Operating Standards as set below: Aero L.L.C. will only operate its SUAS in line ofsight ofa pilot and/orobserver and will operate over private and public sites onlywith prior permission from property owner or owner's agent or legal authorities as allowed by law.Terminate flight when any unsafe condition exists. Operate with a minimum crewfor operations consisting of PIC and aVisual Observer in direct communication utilizing appropriate verbal, radio or cell phone as needed. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur priortothe 30 minute limit. The SUAS operated bythe petitionerweighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbal). The SUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Given the small size ofthe SUAS and the restricted operations environment, our SUAS operations adhere to the Reform Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverablethan larger aircraft running on combustible fuel, it operates at lower altitudeswith no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood ofdeath orserious bodily injury. With a small payload and maximum flighttime ofonly 30 minutes, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based imageryfor displayingthe characteristics of large, complex propertieswith several buildings and large trees. The process ofcharteringfull-sized aircraft for this purpose can be more costly than many potential clients can afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property.

a. No flight will be made with a Gross weight exceeding 55 pounds; b. All operations must occur no morethan 400ft. AGL, at an airspeed of no morethan 25 knots and no furtherthan% NM from the PIC; c. All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice at all times during all flight operations; d. Operations will be restricted to flights over private propertywith the permission ofthe property owner; e. All required permits will be obtained from state and local governments priorto operation;The petitioner respectfully request's exemption underSection 333 to enable Aero L.L.C. to operate efficient, limited, low-risk commercial SUAS operations forthe activities stated respecting at all timesthe space and privacy ofcitizens and propertywhilst keeping ourskies safe.
Sincerely,

Victor Morrel Aero L.L.C. Phone: 207 924 5905 Email: jakemorrel@yahoo.comEXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Aero 

### L.L.C. requests an exemption from the following regulations as well as any additional regulations that may technically apply tothe operation ofthe SUAS System:

14CFR Part 21, Airworthiness Certificates

This part establishes the procedures forthe issuance ofan airworthiness certificate, while the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the Blade Chroma under either or both ofthe following provisions:

21.191 Experimental certificates. Experimental certificates are issued forthe following purposes:

a. Research and Development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operatingtechniques, or new uses for aircraft
.
b. Showing compliance with regulations. Conductingflighttests and other operationsto show compliance with the airworthiness regulations includingflights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to 

### show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit our commercial purpose as well. The aircraftwill not carry persons or property, will not carry fuel, and will onlyfly under strict operational requirements. Combined with the UA's lightweight design, being constructed of molded abs, we propose thatthe UA will be much safer than a conventionally certificated aircraft performingthe same mission. Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirements for airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph. 14CFR 45.23 Display of marks; general and 45.29 Size ofmarks These regulations provide that each aircraft must display uN" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The SUAS does not have an entrance in which the word ((EXPERIMENTAL" can be placed, and may not have a registration number assigned 

### to it by the FAA. Aero 

### L.L.C. propose to achieve an equivalent level ofsafety by includingthe word "EXPERIMENTAL" in a placard on top ofthe aircraft, where the PIC, VO and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel thatthe placard 

## discussed in the previous paragraph will providethe aircraft's registration information atthe ground station, finally, Aero L.L.C. will display atthe ground station a high contrast flag or bannerthat contains the words"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the bannershould be visible to anyonethat observes the aircraft and chooses to investigate its point oforigin.

14CFR 91.7 Prohibitsthe Operation ofan aircraft without an airworthiness certificate As no such certificate will be applicable in the form contemplated bythe FARs, this regulation is inapplicable.

14CFR 91.9 Civil aircraft flight manual, marking, and placard requirements This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intentofthis requirement is to ensure thatflight manual information is available tothe aircrew while operatingthe aircraft. Aero L.LC. requests an exemption tothis requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available to the crew duringflight operations. To obtain an equivalent level ofsafety and meetthe intent of 91.9, we proposethat a current Blade Chroma instruction manual, Chroma LED reference cards and a controller instruction manual must be available to the crew atthe ground station anytime the aircraft is in, or preparingfor, flight.

14CFR 91.119 Minimum safe altitudes: General The regulation states that over sparsely populated areas the aircraft cannot be operated closerthan 500ft. to any person, vessel, vehicle, or structure. Since thetypical mission ofthe SUAS would be photography orsurvey of persons, vessels, vehicles orstructures itwould be necessaryto operate closerthan 500ft. tothe items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-flight planning has been performed. The aircraftwill be operated at a low altitude allowing, ifa power unitfails, an emergency landingwithout undue hazard to persons or property on the surface. Therefore we maintain that due tothe small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in grantingthe exemption.

14CFR 91.121Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available 100 

### NM ofthe aircraft. The SUAS will always fly below400AGL and will not need to maintain cruising altitudes in orderto prevent conflict with otheraircraft. An AGL altimeter measurement above the launch and recovery point is transmitted via radio from the SUAS on-board computertothe display screen held bythe PIC, providing a constantly updated AGL readout.

14CFR 91.151 Fuel requirementsforflight in VFR conditionsThe regulation provides that no person may begin aflight in an airplane under day-VFR conditions unless there is enough fuel to flytothe first point ofintended landingand to fly afterthatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The SUAS is battery operated and the maximum duration offlight from a single battery charge is 30 minutes. Since the aircraftwill neverfly morethan 3/4 NM from the point of intended landing, afull batterycharge at launch, and the on-screen display ofbatterystate, will ensure thatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventative Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintainingthe aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. Our intentions are forthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approvethe aircraft for return to service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed by the PIC is limitedto repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer oftheir designated repair facility. The PIC will documentwork performed in a maintenance/log book thatwill be located atthe ground station during all operations. Aero L.L.C. feels that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.
Safety and Benefits ofthe UAS Aero 

### L.L.C. will be usingthe SUAS in avariety ofapplicationsthat generally require expensive full-size manned aircraftto complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offullsized manned aircraftfor electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, justto name afew. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafetyforthe pilots and crew. By grantingAero L.L.C.s requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS and will advance the public knowledge base for such operations.



### Conclusion As pointed out in this application, all the SUASs which the petitionerwould use, under authorization by the US DOT-FAA, are small, lightweight devices operated within the line ofsight ofthe PIC, less than 400ft. AGL and outside 5 miles from any airport, heliport, seaplane base, spaceport orother location with aviation activities, unless the ATC have been notified and have authorized each flight within a radius ofthis distance.All the SUASs have proven capability for controlled flight. They are devices offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain thatthe studies conducted until now by the FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the assurances on the airworthiness ofSUAs such as ours.
For the foregoing reasons, the exemptions requested herein should be granted and Aero L.L.C. should be permittedto conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission ofthis application and its contents is the best demonstrationthat indeed it is possible to pursue the authorization process so that some SUASs may be used for legitimate commercial activities and under reasonably safe conditions.