**Comment:** Petition for Exemption/Rulemaking

Robert Mendez Facility Intellect 1471 E. Commercial Dr. Meridian, ID 83642 208

-602

- 0442 facilityintellect@gmail.com

Section 333 Exemption Facility Intellect is seeking exemption for section 333. Weprovide Video, Scanning & Photographic surveying, coordination and inspection services through the use of UAS's. Our equipment utilizes still photography, scanning and full videography in support of our mission.

Wecurrently have full liability insurance, fly onl y VLOS, with a two man crew including a visual observer and a pilot. Both the visual observer and the pilot have been trained to man the vehicle's controls in the event of an emergency. Additionally all the flights are logged, remain under an altitude of 2 00 feet and with clearance of the local ATC. Crew members are fully trained to fly in such a way that it will minimize the risk to public safety, as well as the natural environment within our area. Their flight time, at this time, is in excess of 40 hours, without incident or an accident. All our equipment goes through a thorough maintenance & load checklist prior to take off, as well as utilizing an official preflight checklist.

Our equipment includes a 4 rotor quad copter, currently we utilize the DJI P hantom and Inspire 1 series, which carries a gimbal and a camera is not equipped to carry any individuals and remains under 25 pounds at takeoff. Flight times of the aircraft are 20

-25 minutes depending on the winds and weather. Landing always happens befo re we reach a 25% threshold within the battery's cells. The aircraft does not exceed a ground speed of 40 mph and is equipped to return to the GPS position of takeoff in the event of a failure.

**BENCH SET UP & TESTS**  All screws/bolts are tight  Timer alarm for flight time to not exceed 80% battery capacity set properly  Batteries are secure  Antennas are secure  Props balanced  Props aligned  Props not chipped  Check blades, arms, etc. for cracks/damage  Wi ring Tight  No excessive flexing of motors or booms  Booms/motors will not twist  Center of gravity is correct  Wa rning lights set for low battery if used  Batteries charged. Replace any battery which cycles below 80% of rated capacity

**QUICK PREFLIGHT CHECKLIST**  Landing zone clear Level copter with correct heading  Battery 4.1+ full, 3.8 depleted (do not use)  Camera on. SD card in.  Both TX

– all switches down  Copter on  Check GPS and Course lock checks  Video check  Photo check  Timers ready  Takeoff  Raise Landing Gear  Unplug 6 batteries upon landing

**TA KEOFF CHECKLIST**   Declare intentions for takeoff with ATC if required.  Engage GPS mode

– Double purple flash  Engage Course  Announce loudly: “CLEAR PROP”  Position the sticks in the lower left hand corners, then immediately raise the throttle 2 clicks and center the right stick.  Advance throttle to 1⁄4 power for 5 seconds. Assure all motors are operating.  Verify that left/right and forward/back stick movement engages the proper motors.  Verify data and video links are still operational  Announce loudly: “TAKING OFF”  Advance throttle to full. Copter must jump off of the ground.  Ascend to 3 meters. Center throttle stick. Should be single green flash. Verify wireless link, GPS hold, camera operation, gauges, etc. are working properly.  Verify course lock is operational by rotating 90 degrees and pushing forward on stick.  Verify copter stability. If unstable, land and reset gains, reca librate, or retest as necessary.  Raise landing gear  Proceed with manual mission  For autopilot operation Ascend to 10 meters manually then engage autopilot  Manual pilot/observer must monitor the informational LED and be ready to take over in manual mode when necessary.  Manual pilot to request copter flight battery voltage readout from camera operator periodically.

**LA NDING CHECKLIST**   Landing area clear  Lower landing gear  Note obstacles along flight path  Announce clearly and loudly: “LANDING”  First cut power to the aircraft  Note elapsed time of flight  Adjust any parameters (camera servo speed, exponential, etc)  Turn power off to transmitters, camera, goggles, m onitors, Rxs, etc.  Touch motors to verify temperatures are similar Complete flight log

o Date and time of flight

o Location

o Document Any issues

o Batteries used

o Time of Flight  Contact ATC if required