August 26, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave nue , SE Washington, DC 20590



### Oregon Coast Drones

Section 333 Petition to Operate Small Unmanned Aerial Systems

Prepared by:
Ian Broad

1614 11 th St Tillamook, OR 97141 (308) 520

- 3532 ian.broad@outlook.comAugust 26, 2015

Petition Summary:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Section 333”) an d the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), Ian Broad of Oregon Coast Drones (“Petitioner”) hereby petitions
for e xemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Air worthiness Standards: Normal Category Rotorcraft), 14 C.F.R §§ 61.113(a) , 91.7(a) , 91.119(c),
91.121, 91.151 (a)(1)

, 91.405(a), 91.407(a)(1), 91.409(a)( 1 )

- ( 2), and 91.417(a)

- (b).

The proposed exemption, if granted, would allow Petitioner to conduct commerci al operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.

Petitioner is an aerial service and technology business that plans to utilize the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Precision a griculture

- Mining

- Telecommunications

- Infrastructure and industrial inspections

- Search and rescue operations

- Aerial filmmaking and photography

- Energy systems inspections and asset management

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

- Pipeline inspection and patrolling

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Sy stems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operati on authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The Petitioner r equests relief f rom the f ollowing: Section 61.113(a) prescribes that

— (a) no person who holds a pr ivate pilot certificate may act as a 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.

Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthy condition.August 26, 2015

Section 91.119 ( c) prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes

, ( 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 fe et to any person, vessel, vehicle, or structure.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.”

Section 91.151(a) (1) prescribes , in pertinent part, that

— (a) N o 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,

assum ing normal cruising speed, (1) D uring the day, to fly after that for at least 30 minutes

.

Section 91.405(a) requires, in perti nent part, that

— (a) an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as pr escribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, (a) any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless , (1) it has been approved for return to servic e by a person authorized under § 43.7 of this c hapter.

Section 91.409(a)( 1)

- ( 2) prescribes, in pertinent part, that (a) no person may operate an aircraft unless, within the preceding 12 calendar months, it has had , (1) a n annual inspection in accordance with part 43 of this chapter and 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 airworthi ness certificate in accordance with part 21 of this chapter.

Section 91.417(a)

- (b) prescribes, in pertinent part, that

— (a) Each registered 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 required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, roto r, 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 numb er 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 which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including t he time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.August 26, 2015

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of com pliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alter ation to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retai ned until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified 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.

The Petitioner has supplied the following a dditional i nformation :
DJI Phantom 3 Operation Manual and Flight Checklist

Iris + Operation Manual and Flight Checklist
3D Robotics X8

- M Operation Manual and Flight Checklist

Unmanned Aircraft Systems requested to operate under this request:

DJI Phantom 3
3D Robotics Iris + 3D Robotics X8

- M

The petitioner states that the unmanned aircraft (UA) to be operated under this request are less than 55 lbs. fully loaded, fly at a speed of no more than 50 knots, carry neither a pilot nor passen ger, carry no explosive materials or flammable liquid fuels, and operate exclusively within a secured area as set out in
the POHs.

The Phantom 3 is a four

- rotor manufactured by DJI. The VTOL quadrotor

- type design has four motors, GPS, full autonomous autopilot c apabilities, telemetry and manual ground control. In addition, the craft has integrated safety features built into the design of the UAS, as described in the POH, to ensure the safety of persons and property within and surrounding the limited operating are a. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability to return to a pre

- determined location within the Security Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted obstacles or emergencies.

The Iris + is a four

- rotor manufactured by 3D Robotics. The VTOL quadrotor

- type design has four motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, the craft has integrated safety features built into the design of the UAS, as described in the POH, to ensure the safety of persons and property within and surrounding the limited operating area. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will hav e the capability to return to a pre

- determined location within the Security Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted obstacles or emergencies.

The X8

- M is a four

- rotor manufactured by 3D Robotics. The VTOL quadrotor

- type design has eight motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, the craft has integrated safety features built into the design of the UAS, as described in the POH, to
ensure th e safety of persons and property within and surrounding the limited operating area. TheAugust 26, 2015

petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability to return to a pre

- determined location w ithin the Security Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted obstacles or emergencies.

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. Part 45, Subpart C. Markings will be as large as practicable.

Pre

- flight Inspection, Maintenance Before each flight the PIC will perform a series of pre

- flight and takeoff checks as defined by the POH supplied. After each 60 minutes of airtime, the cr aft will undergo a thorough inspection of all aircraft components, including, but not limited to: a. Actuators / Servos b. Motors, wiring and connectors c. Propellers, smooth, no chips d. Electronic speed controller, wiring and connectors e. Batteries, wir ing and connectors
f. Remote command and control g. Ground control station

UAS Operating Parameters The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in daytime VFR flight conditions and all operations wi ll be conducted with the assistance of a second spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet AGL. Altitude is accurately measured by GPS. The petitioner further states that an operator will ensure that only consenting production personnel will be allowed within 100 feet of the UA operation, and UAS will be kept at least 100’ from any inhabited structure. Generally the petitioner’s UAS will be operated in rural or suburban areas that will permit significantly larger saf ety zones.

Flight Standards District Offices (FSDOs) will be notified as required prior to operations to describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations under this grant of exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation.

Petitioner’s UAS will remain clear and yield the right of way to all manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and hangliders). Petitioner wi ll not conduct UAS operations within 5 nautical miles of the geographic center
of a non

- towered airport unless a letter of agreement with that airport’s management is obtained and the operation is conducted in accordance with a Notice to Airmen (“NOTAM”).

Pilot in Command (PIC) The pilot in command will be

, Ian Broad of Oregon Coast Drones . Mr. Broad has logged over 50 hours of UAV flight time. H e is a holder of a valid driver’s license, OR License number A164643 , Expiring

06 / 23 / 2023

. Mr. Broad has approximately 4 years of experience with rotor wing aircraft.August 26, 2015

Radio Frequencies Radio frequencies used will be those allotted by the FCC for data transmission and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage a nd emissions regulations.

Safety and Benefits of the UAS The petitioner will be using the UAS in a variety of applications that generally require expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad of ben efits over the
use of full

- sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few. Replacing significantly larger manned aircraft carrying crew and flammab le fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. By granting Petitioner’s requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and w ill advance the public knowledge base for such operations. Petitioner is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion For the foregoing reasons, the exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA.

Thank you for your consideration.

Sincerely,

Ian Broad Oregon Coast Drones