1 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

U NI T E D ST A T E S OF A M E R IC A DEP A R T ME NT OF T R A N S P ORT A T I ON F E DE R A L AV I A T I ON

A DM I N I S T R A T I ON W A S H I N G TON, DC

Regu l a t o r y D o c k et N o

.

______________________________

I N T H E M A T T E R OF T H E P E T I T I ON FOR E X EM P T I ON O F:

REEDER FLYING SERVICE INC.FOR A N E X EM P T I ON SE E K I NG R E LI E F FROM T H E R E Q U I R EME NTS OF

T I TLE 14 OF T H E C ODE OF F E DE RA L R E G U L A T I ONS SE C T I O NS

14 C F R Pa r t 2 1 s u b p a r t H

14 C F R 45

. 23 (b)

14 CFR 61.101 (e) (4) and (5)

14 C F R 61

. 113 (a) & ( b)

14 C F R 91

. 7 (a)

14 C F R 91

. 9 (b) ( 2)

14 C F R 91

. 103 (b)

14 C F R 91

. 109

14 C F R 91

. 119 ( b) & ( c)

14 C F R 91

. 121

14 C F R 91

. 151

14 C F R 91

. 203 (a) & ( b)

14 C F R 91

. 405 (a)

14 C F R 91

. 407 (a) ( 1)

14 C F R 91

. 409 (a) (1) & ( 2)

14 C F R 91

. 417 (a) & ( b)

CO N C E R N I NG C O M M ER C I A L OP E R A T I O N OF DJI INSPIRE 1 U N M A NNED A I R C RA F T SYS T E M S

P U R SU A N T T O SE C T ION 333 OF T H E F A A M ODE R N I ZA T I O N A ND RE F O R M A C T OF 2012 ( P U B L I C

L A W 11 2

- 95)2 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

UAS I n t egra t ion O f f i c e

– Spe c i a l R u l es C oo rdi nat o r

Federal Avi at ion A d m i n i s t ra t ion

U. S. D ep a rt m ent of T r a ns p o rt at ion

D o ck e t M an ag ement S y s t em

12 0 0 N e w J e r s e y Ave., SE Was h i ngt o n, D C 20 5 90

November 13 , 2015

R e: Pet it ion f o r E xe m p t ion f o r Use o f U AS f o r R eal E s t a t e, Pu b l i c I n t e r est, Sm a ll Bus i ness

Ap p l i c at ions under Sec t i o n 33 3

, Ti t le 14

Pu r s u a n t t o S e c ti o n 333 o f t h e FA A M o d e r n i z a t i o n a nd R e f o r m A ct o f 2012 ( t he “ R e f o r m A c t ” )

a nd 14 CFR Pa r t 11, Reeder Flying Service Inc

. , o p e r a t o r o f a n U n m a n n e d Ai r c r a f t S y s t e m

( U A S), h e r e b y a p p li e s fo r an e x e m p t i o n f r o m t h e l i s t ed F e d e r a l A v i a t i o n R e g u l a t i o ns

( “ F A R s ” ) t o a l l o w c o m m e r c i a l o p e r a ti o n o f i t s U A S, s o l o ng as s u ch o p e r a t io ns a r e c o n d u c t e d

w i t h i n an d u n d e r t he c o n d i t i o ns o u t l i n e d h e r e i n o r as m a y be e s t a b li s h e d b y t he FA A as

r e q u i r ed b y S e c t i o n 333.

Co m m e r c i a l o p e r a t i o n o f a n U A S, as d e s c ri b ed h e r e i n, w h i ch a r e e q u i p p ed w i t h c a m e r a(s) a n d

s e n s o r s

, w o u l d o p er a t e i n t h e fol l o w i ng m an n e r :

1. A e r i a l p h o t o g r a p h y a n d / o r vi d e o fo r p u b li c a n d /or p r i v a t e u s e i n c l u d i ng r e al e s t a t e,

a r c h i t e c t u r e

, l a n d s u r v e yi n g, e n g i n e e r i ng a n d o t h e r r e l a t ed p r of e ssi o n al ac t i v i t i e s

.

2. A e r i a l v i d e o a n d /or p h o t o g r a p h y fo r p u b l i c a n d / o r p r i v a t e u s e i n c l u d i ng t e l e vi s i o n

, p u b l i c

e v e n t s

, c i n e m a t o g r a p hy a n d n e w s g a t h e r i n g

.

3. A e r i a l i n s p e c ti o n / p ho t o g r a p hy o f r e s i d e n t i a l /c o m m e r c i a l st r uc t u r e s u n d er c o n t r act w it h

t h e o w n e r s o r l o c a l gov e r n m e n t a u t ho r i t y

.

4. A e r i a l i n s p e c ti o n / p ho t o g r a p hy /data collection o f r e s i d e n t i a l /c o m m e r c i a l u t i l i t y

i nf r a s tr u c t u r e i n c l u d i n g b u t not l i m i t ed t o e l e ct r i c al pow e r li n e s

, structures and related facilities, w i nd

t u r b i n e s a n d c e l l t o w e r s

, gas pipeline right of ways, installations and facilities

.

5. A e r i a l v i d e o / p h o t o g r a p hy o r p r ov i d i ng l iv e v i d eo fe e d t o a ss i s t w i t h s e a r c h a nd r e s cue

o p er a ti o n s i n ca s e s o f a n e m e r g e n c y o r n a t u r al d i s a st e r o n l y w h en t he lo cal a u t ho r i t i es o r

g o v e r n m e nt h as r e q u e s t e d i t by c o n t r act o r d o n ati o n.

6. T he a b i l i t y t o off er tr a i n i ng t o p e rs o ns i n d i v i d u a l l y o r b e l o n g i n g t o both p r i v a t e a n d /or

p u b l i c o r g a n i z a t i o ns t h at h a v e i n t e r e s t s i n t he u s e a n d a p p l i c a ti o n o f a U A S fo r t h e p u r pose o f

t he s afe o p er a ti o n o f a U A S t o e n h an ce t he s af e t y o f t h e N a t i o n a l A i rs p ace S y s t e m ( N A S) a s w e l l

a s fo r t he p r o t e c ti o n o f t h e p e r s o ns a n d p r o p e r t y

.

A s d e s c r i b ed f u l l y b el o w, t h e r e q u e s t e d e x e m p t i o n w o u l d p e r m i t t he o p e r a t i o n o f a U A S u n d e r

c o n tr ol l e d c o n d i ti o n s i n t he N A S t h a t w o u l d be a) li mi t ed b) c o n tr ol l e d c) p r e d e t e r m i n e d a nd d)

w i l l p r o v i de s a f e t y e n h a nc e m e n t s t o t h e a l r e a d y s afe o p e r a ti o ns i n t h e i n d u st r y p r e s e n t l y u s i ng

c o n v e n tio n a l a i r c r aft. A p p r o v a l o f t h i s e x e m p t i o n w o u l d t h er e b y e n h a n ce s af e t y a n d f u l f i l l

t he S e c r e t a r y o f T r a n s por t a t i o n’s ( t he F A A A d m i n i s t r a t o r ’ s ) r e s po n s i b i li t i es t o “

... . e s t a b l i s h

r e q u i r e m e n t s fo r t h e s afe o p e r a t i o n o f s uch a i r c r a f t sy s tems in the national airspace

system.”3 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

BACKGROUND

Located in Twin Falls Idaho Reeder Flying Service was founded in 1941 by Charles T.

Reeder. His aviation innovations led the way in many areas and has left a lasting

impression on the aviatio n community

.

Over the past 75 years the company has evolve d from a family run agricultural support

operation to a full service FBO and helicopter charter company. Reeder Flying Service

has grown and changed with the times in aviation.

Since 1960, Reeder Flying Service ha s provided helicopter services. The Company

operates under FAA 135, 133, 137 ce rtificates.

In 2012 Reeder Flying Service was purchased by three local businessmen

, Jack M.

Hunsaker

, David R. Price and Alan Anderson

.

The integration of UASs into the National Airspace System (NAS) has the promise and

potential to be transformative in the ways in which the public, educational and research

institutions, businesses and non

- profits pursues their interests and goals. Reeder Flying

Service, Inc

. , as a long standing member of the commercial aviation community, feels it is

in an excellent position to parti cipate in this expanding market. U sing its understanding

and expertise in commercial aviation, Reeder feels it has an important role to play in

further ing the safe, lawful use and professional development of commercial unmanned

aerial systems.

Reeder Flying Service Inc. will conduct its business using the DJI Inspire 1 UAS. The

Inspire 1 is a vertical takeoff and landing UAS with a maximum gross weight of less than

55 pounds and a maximum speed of less than 50 mph. The Inspire 1 is driven by electric

motors and powered by lithium polymer batteries.

The aircraft registration application and all required supporting documentation for this UAS

has been forwarded to the FAA Aircraft Registration Branch, AFS

- 750, P.O. Box 25504,

Oklahoma City, OK 73125

- 0504. The registration has been returned with the UAS

registered as N644RD.

BASIS FOR PETITION

Petitioner, Reeder Flying Service Inc., pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the DJI Inspire 1 UAS in the National

Airspace System (NAS), and for an exemption from the requirements of 14 CFR 21

subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e) (4) & (5); 14 CFR 61.113(a) and (b); 14

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103 (b) ; 14 CFR 91.109; 14 CFR 91.119(c);

14 CFR 91.121; 1 4 CFR 91.151 ; 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR

91.407(a) (1) ; 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b).4 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Reeder Flying Service Inc.’s operation of DJI Inspire

1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Reeder Flying Service Inc. requests relief from Sections 91 .405(a),

91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b), as these sections set forth

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Reeder Flying Service Inc. submits that the requested relief is proper s ince an equivalent

level of safety will be ensured. Reeder Flying Service Inc. will use experienced personnel

or technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed i n the operating documents (i.e.,

the Reeder Flying Service Inc. UAS Flight Operations Manual , UAS Maintenance Lo g, and

DJI Inspire 1 User Manual. ) Furthermore, Reeder Flying Service Inc. will document

maintenance and maintain all maintenance records for the DJI Inspire 1 UAS.

Reeder Flying Service Inc. seeks relief from Section 91. 7(a)

- Civil aircraft airworthiness,

because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. As such, Reeder Flying Service Inc. submits that it will

ensure that the DJI Inspire 1 UAS s are in an airworthy condition, prior to every flight, by

determining that the UAS are in compliance with the operating documents (i.e., the R eeder

Flying Service Inc. UAS Flight Operations Manual , UAS Maintenance Lo g, and DJI Inspire

1 User Manual), and that the air craft is in a condition for safe flight.

In accordance with 14 C.F.R. § 11.81, Reeder Flying Service Inc. provides the following

information in support of its petition for exemption:

I. N a me A nd A d d r e ss O f T he P e ti t i o n e r.

The name and address of the Peti tioner and point of contact is:

Reeder Flying Service Inc.

644 Airport Loop

Twin Falls ID. 83301

Tel: (208) 733

- 5920

website: www.reederflying.com

II

. Th e Specific Sections Of 14 CFR From Which Reeder Flying Service Inc. Seeks

Exemptions

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.101(e)(4) and (5)

, 14 CFR 61.113(a)

and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR

91.119 (b) and (c); 14 CFR 91.121; 14 CFR 91.151 ; 14 CFR 91.203 (a) and (b); 14 CFR

91.405 (a); 14 CFR 91.407(a) (1) ; 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

.

III . The Extent Of Relief Reeder Flying Service Inc. Seeks And The Reason Reeder

Flying Service Inc. Seeks The Relief

.5 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 CFR Part 11, Reeder Flying Service Inc., operator of an Unmanned Aircraft

System (UAS), hereby applies for an exemption from the listed Federal A viation

Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations

are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by Section 333.

Commercial operation of an UAS , as described herein, which are equipped with camera(s)

and sensors, would operate in the following manner:

1. A e r i a l p h o t o g r a p h y a n d / o r vi d e o fo r p u b li c a n d /or p r i v a t e u s e i n c l u d i ng r e al e s t a t e,

a r c h i t e c t u r e

, l a n d s u r v e yi n g, e n g i n e e r i ng a n d o t h e r r e l a t ed p r of e ssi o n al ac t i v i t i e s

.

2. A e r i a l v i d e o a n d /or p h o t o g r a p h y fo r p u b l i c a n d / o r p r i v a t e u s e i n c l u d i ng t e l e vi s i o n

, p u b l i c

e v e n t s

, c i n e m a t o g r a p hy a n d n e w s g a t h e r i n g

.

3. A e r i a l i n s p e c ti o n / p ho t o g r a p hy o f r e s i d e n t i a l /c o m m e r c i a l st r uc t u r e s u n d er c o n t r act w it h

t h e o w n e r s o r l o c a l gov e r n m e n t a u t ho r i t y

.

4. A e r i a l i n s p e c ti o n / p ho t o g r a p hy /data collection o f r e s i d e n t i a l /c o m m e r c i a l u t i l i t y

i nf r a s tr u c t u r e i n c l u d i n g b u t not l i m i t ed t o e l e ct r i c al pow e r li n e s

, structures and related facilities, w i nd

t u r b i n e s a n d c e l l t o w e r s

, gas pipeline right of ways, installations and facilities

.

5. A e r i a l v i d e o / p h o t o g r a p hy o r p r ov i d i ng l iv e v i d eo fe e d t o a ss i s t w i t h s e a r c h a nd r e s cue

o p er a ti o n s i n ca s e s o f a n e m e r g e n c y o r n a t u r al d i s a st e r o n l y w h en t he lo cal a u t ho r i t i es o r

g o v e r n m e nt h as r e q u e s t e d i t by c o n t r act o r d o n ati o n.

6. T he a b i l i t y t o off er tr a i n i ng t o p e rs o ns i n d i v i d u a l l y o r b e l o n g i n g t o both p r i v a t e a n d /or

p u b l i c o r g a n i z a t i o ns t h at h a v e i n t e r e s t s i n t he u s e a n d a p p l i c a ti o n o f a U A S fo r t h e p u r pose o f

t he s afe o p er a ti o n o f a U A S t o e n h an ce t he s af e t y o f t h e N a t i o n a l A i rs p ace S y s t e m ( N A S) a s w e l l

a s fo r t he pr o t e c ti o n o f t h e p e r s o ns a n d p r o p e r t y

.

As described fully below, the requested exemption would permit the operation of a UAS

unde r controlled conditions in the NAS that would be a) limited b) controlled c)

predetermined and d) will provide safety enhancements to the already safe operations in

the industry presently using conventional aircraft. Approval of this exemption would

thereby enhance safety and fulfill the Secreta ry of Transportation’s (the FAA

Administrator’s) responsibilities to “....establish requirements for the safe operation of such

aircraft systems in the national airspace system.”

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates Subpart H

- Airworthiness

Certificates6 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

The regulation establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be utilized by th e Applicant, an exemption from Part 21

Subpart H meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FA A to exempt aircraft from the

requirement for an airworthiness certificate, upon consideration of the size, weight, speed,

operational capability, and proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these crite ria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft)

operating with an airwo rthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot

nor passenger, carries no explosive materials or flammable liquid fuels, and operates

exclus ively within a secured and designated area. Unlike other civil aircraft, operations

under this exemption will be tightly controlled and monitored by both the operator and

under the requirements and in compliance with local public safety requirements. These

safety enhancements provide a greater degree of safety to the public and property owners

than conventional operations conducted with airworthiness certificates issued under 14

C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstr ates that there is no credible threat to

national security posed by the UAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a

substantial external load.

14 C.F.R. § 45.23 (b)

- Marking of the Aircraft

The regulation requires when marks include only the Roman capital 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, cockpit, or pilot sta tion, in letters not less than 2

inches nor more than 6 inches high, the words “ limited, ” “ restricted, ” “ light

- sport, ”

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

Even though the UAS will have no airworthiness certificate, an exemption may be needed

as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word

“Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be

impossible. The word “Experimental” will be placed on the fuselage in compliance w ith

§45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the

UAS will see the identification of the UAS as “Experimental.”

1 4 CFR § 61.101 (e) (4) and (5) : Recreational Pilot Privile ges and Limitations: Pilot in

Command.7 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

Relief is requested to the extent necessary to allow a PIC holding a recrea tional pilot level

certificate and who has met certain flight

- hour and currency requirements, to conduct the

proposed UAS flight oper ations for compensation or hire and in furtherance of a business.

The issuance of a Recreational Pilot Certificate requires the applicant to be trained in and

pass a knowledge test on the aeronautical knowledge areas listed in 14 CFR § 61.97 (b),

and demonstrate to an examiner flight proficiency as outlined in 14 CFR § 61.98.

Reeder Flying Service, Inc. submits that to the extent that a commercial UAS, operating

under the grant of exemption, will i mpact the airspace system, a recreational pilot

certificate will provide an adequate and equivalent level of expertise to ensure safety to the

public.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Relief is requested to the extent necessary to allow a PIC holding a priva te pilot and who

has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that

a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with

any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for compensation

or hire

.

The issuance of a Private Pilot Certificate requires the applicant to be trained in and pass

a knowledge test on the aeronautical knowledge areas listed in 14 CFR § 61.105 (b), and

demonstrate to an examiner flight proficiency as outlined in 14 CFR § 61.106.

Reeder Flying Service, Inc. submits that to the extent that a commercial UAS, operating

under the grant of exemption, will impact the a irspace system, a private pilot certificate will

provide an adequate and equivalent level of expertise to ensure safety to the public.

As set forth more fully below, Reeder Flying Service Inc. submits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1

UAS unless that PIC has met certain flight

- hour and currency requirements,

demonstrating that the PIC is able to safely operate eith er the DJI Inspire 1 UAS in a

manner consistent with the operations specifications as described in this exemption,

including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures

.

1 4 C.F.R. §91.7(a ): Civil Aircraft Airworthiness

Relief f rom Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness,

is requested to the extent required to allow Reeder Flying Service Inc. to determine that

the DJI Inspire 1 UAS ar e in airworthy condition prior to every flight by ensuring that the

UAS is in compliance with the operating documents (i.e., the Reeder Flying Service Inc.

UAS General Operations Manual, UAS Daily Flight Log preflight airworthiness sign off,

UAS 50 hour/ 2 00 flight Inspection and DJI Inspire 1 Instruction Manual).

Reeder Flying Service Inc. seeks the requested relief because the DJI Inspire 1 UAS does

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, Reede r Flying Service Inc. will ensure that the DJI Inspire 1 UAS are in8 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

airworthy condition based upon its compliance with the op erating documents noted above

prior to every flight, and further, determine that the aircraft is in condition for safe flight, as

s tated in the conditions and limitations below.

14 C.F.R. § 91.9 (b) (2): Civil Aircraf t Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2)

For which an Airplane or Rotorcraft Flight Manual is not required by §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 thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the aircraft. The equivalent level of safety will be

maintained by keeping the manufacturer provided user manual at the ground control point

where the pilot flying the UAS will ha ve immediate access to it

.

14 C. F.R. § 91.103 (b) : Preflight Action

This regulation requires each pilot in command to take certain actions before flight to

insure the safety of flight , regarding runway lengths and use of approved flight manuals

. As FAA app roved rotorcraft flight manuals will not be provided for the aircraft an exemption

will be needed.

The PIC will take all actions as stated in the manufacturer’s user m anual and the Reeder

Flying Service, Inc. UAS General Operations Manual, including but not limited to reviewing

weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

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

Section 91.103 provides that no person may operate a civil aircra ft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls.

Flight control is accompl ished through the use of a ground control station that

communicates with the aircraft via radio communications. The FAA has approved

exemptions for flight training without fully functional dual controls for a number of aircraft

and for flight instruction i n experimental aircraft. The equivalent level of safety is provided

by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size

and speed of the aircraft

.

14 C.F.R. §91.119 (b) and (c) : Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescribed for

h elicopters by the FAA.

As this exemption i s for a UAS that is a rotorcraft and the exemption requests authority to

operate at altitudes up to 400 AGL, or not more than 200 above an elev ated platform from

which aerial data collection is planned, an exem ption may be needed to allow such

operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the9 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

exception that in circumstances where the UAS is used to survey or photograph a

structure whose height exceeds 400 feet AGL, the U AS will not be operated more than

200 feet above the highest point on the structure. It will however be ope rated in a defined

area with security perimeter, where buildings and people will not be exposed to operations

without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as

well as the location where it is operated. No flight will be taken without the permission of

the property owner or local officials. Because of the advance notice to the property owner

and participants in the filming activity, all affected individuals will be aware of the planned

flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more

than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk

associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude

operations of the UAS will ensure separation between t hese UAS operations and the

operations of conventional aircraft that must comply with Section 91.119

.

14 C. F.R. §91.121 Altimeter Settings

Relief from Section 91.121, entitled Altimeter settings, is required to allow flight operations

of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and

a radio communications telemetry data link to downlink altitude information from the UAS

to the PIC at the ground control Station (GCS). Since the FAA requires that any altitude

informati on concerning UAS operations be reported to air traffic control (ATC) in feet

above ground level (AGL), Reeder Flying Service Inc. seeks the requested relief because

the DJI Inspire 1 UAS’s altimeter may be set on the ground to zero feet AGL, rather than

t he local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent necessary to comply with the applicable conditions and limitations

stated b elow. As more fully set forth herein, an equivalent level of safety will be maintained

since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS

equipment, which automatically ensures that a ground level pressure setting will be

es tablished prior to each flight, and provides the PIC with altitude information of the UA on

the heads

- up display of the GCS

.

14 C.F.R. § 91.151 : Fuel Requirements for Flight in VFR Conditions

Relief from Section 91.151 entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS

during daylight hours in visual meteorological conditions (VMC), under visual flight rules

(VFR), for a total duration of 20 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 5 minutes.

Reeder Flying Service Inc. seeks the requested relief because without an exemption from

Section 91.151 , the flight time duration of the battery powered DJI inspire 1 UAS will

severely constrain the practicality of any aerial video or still photo flight operations that

Reeder Flying Service Inc. proposes to conduct pursuant to this Petition.10 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the

DJI Inspire 1 operating documents, and Reeder Flying Service Inc. proposed operating

limitations, ensure that Reeder Flying Service Inc. will safely operate the battery powered

DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), with enough battery power to fly for a total duration of 20 minutes

to the first point of intended landing and, assuming normal cruising sp eed, to fly after that

for at least 5 minutes. Applicant believes that an equivalent level of safety can be achieved

by limiting flights to 25 minutes or 25% of battery power

— whichever happens first. This

restriction would be more than adequate to return the UAS to its planned landing zone

from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulatio n provides in pertinent part:

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

within it the following: (1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificat e 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.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard

pilot. As such, there is no ability or place to carry certification and registration documents

or to display them on the UAS. An equivalent level of safety will be achieved by keeping

these documents at the ground control point where the pilot flying the UAS will have

immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “s hall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections,

except as provided in paragraph I of this section, have discrepancies repaired as

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in

compliance with Part 43.

Given that these section s and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. Maintenance will be accomplished

by the operator pursuant t o the manufacturer’s User manual and Company Operations

Manual. An equivalent level of safety will be achieved because the UAS is very limited in

size and will carry a small payload and operate only in restricted areas for a limited period

of tim e. If mechanical issues arise the UAS can land immediately and will be operating

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working

order prior to initiating flight, perform required maintenance, and keep a log of any

mai ntenance performed. Moreover, the operator is the person most familiar with the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalent level of safety. An equivalent level of safety will be achieved because

ma intenance and inspections will be performed in accordance with the UAS

Manufacturer ’ s User Manu al. As provided in the Operations Manual, the operator will

ensure that the UAS is in working order prior to initiating flight and perform required

maintenance n eeded.11 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

IV. The Reasons Why Granting Reeder Flying Service Inc.’s Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT

This exemption request will permit Reeder Flying Service Inc. to operate its UAS

commercially for t he purpose of aerial filming, photography and data collection to include:

commercial and residential real estate, infrastructure inspections, construction,

architecture, scientific research, environm ental assessment, land surveying and mapping

and other applicable areas. Reeder Flying Service Inc. will provide a service that is

beneficial to industries and organizations that are already using, and seeking to use, UASs

for these purposes with a legal a nd safe option. This will benefit the public with the

controlled operation of UASs and increase integration into the NAS.

Granting the present petition will further the public interest by allowing Reeder Flying

Service Inc. to perform safely, efficiently, and economically, aerial video and photography

of construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce,

and provide significant bene fits to the economy.

The integration of UASs into the NAS will not only replace traditionally more expensive

options or approaches, it will enable work to be done and decisions to be made in ways

that were simply impossible to do previously. The commercial deployment of small

unmanned aircraft systems offers the public a new, highly efficient and relatively

inexpensive platform for collecting, analyzing and utilizing data and photographic/video

imagery.

In deploying its UAS, Reeder Flying Service Inc. has developed specific performance

standards, operating requirements, protocols and work processes that are aligned with the

FAA’s continuing mission, and will result in safe operating practices that are consistently

applied and continuously improved. For its part, Reeder Flying Service Inc. recognizes the

important role it plays in educating the public and building awareness of both the promise

and precautions that accompany the commercial deployment of this new and exciting

platform.

The UAS utilized by Reeder Flying Service Inc. is battery

- powered and serves as a safe,

efficient and economical alternative to the manned aircraft traditionally utilized to obtain

aerial imagery. A grant of exemption would allow Reeder Flying Service, Inc. to contribute

to the reduction of manned aircraft needed to perform the aerial acquisition of data, video

and photographic content and subsequently reduce the volume of manned aircraft in the

NAS.

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will

greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using

battery power and electric motors, the DJI Inspire 1 UAS produces no air pollution, and is

the most viable environmentally conscious alternative to the internal combustion engine

aircraft that are typically utilized for aerial video and photography. The DJI Inspire 1 UAS,

while reducing the carbon footprint of aerial acquisitions, also sharply reduces noise

pollution, as the UAS is propelled by battery powered electric motors, rather than an

internal combustion engine.12 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. The DJI

Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross weight

with a length of 17.3 inches and width of 17.7 inches, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air,

compared to the manned aircraft that typically conduct similar operations

.

Previously, such services as high

- resolution digital aerial real estate photography,

surveying and inspections were limited and affordable to a relatively small group of

agencies, companies and organizations with significant operating capital. The granting of

this exemption will enable Reeder Flying Service Inc. to change this by deploying its UAS

in ways that make aerial photography and other UAS services accessible and affordable to

a significantly larger portion of individuals, organizations and businesses. The many new

forms of aerial content would have immediate and direct benefits to service providers,

business owners and consumers alike.

PUBLIC SAFETY

With safety as its primary operational requirement, Reeder Flying Service Inc. will plan,

conduct and manage its flight operations within very specific and well

- defined operating

limitations and standards detailed in its flight operations protocols (see Attachment G).

These protocols also clearly define the roles and responsibilities of the UAS Pilot in

Command (UAS

- PIC)

, the UAS V isual O bserver (VO), and the client representative

working with the Reeder Flying Service, Inc. team.

In seeking this exemption, Reeder Flying Service Inc. submits that the DJI Inspire 1 UAS

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the

characteristics of the DJI Inspire 1 UAS, the pilot certification requirements, and the

specific operating limitations. The specifications of the DJI Inspire 1 UAS (see

Attachments A and B) demonstrate its safe characteristics. The DJI Inspire 1 UAS does

not create a hazard to us e rs of the NAS or the public, or otherwise pose a threat to national

security considering its size, weight, speed, and operational capability. Many of the

functional capabilities and features of the DJI Inspire 1 UAS enable it to be operated in a

highly controlled, precise and safe manner.

The DJI Inspire 1 UAS autonomous flight and navigation modes enable it to remain within a

defined operational area. Also, the DJI Inspire 1 UAS may be operated in both manual and

fully autonomous flight modes. A complete description of the flight and navigational modes

of the DJI Inspire 1 UAS is provided on pages 12

- 17 and 45

- 50 of the DJI Inspire 1 User

Manual v1.4 (see Attachment B).

The DJI Inspire 1 UAS includes automatic return

- to

- home

- point or hover functionality in the

event of loss of the control link or navigation. When the control ink is lost, the DJI Inspire 1

UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI

Inspire 1 UAS does not reacquire control link data from the ground control station/remote

controller, the UAS will assume that the control link is lost and will return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown.

A complete description of the failsafe functions of the DJI Inspire 1 is provided on pages

13

- 15 of the DJI Inspire 1 User Manual (see Attachment B).13 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

Whether conducting site and land surveys

, inspecting infrastructure, helping to protect the

public or acquiring aerial imagery and video, Reeder Flying Service Inc. UAS s will be

providing its customers with more accurate and timely information. The real

- time

situational awareness and improved decision

- making this achieves will enable Reeder

Flying services’ customers and clients to communicate with and more safely serve and

support their respective constituents.

Strict adherence to specific flight operations protocols (see Attachment G ), the use of the

DJI Inspire 1 UAS configured with significant safety functionality, the acquisition of an

accurate understanding of both the flight operations area and its adjacencies using Reeder

Flying Service Inc.’s Site Safety and Planning Template (see Attachment L), and the use of

Reeder Flying Services’ On

- Site Client Safety Briefing (see Attachment N ) will provide a

level of safety and oversight that is in complete alignment with the FAA’s mission to

“provide the safest, most efficient aerospace system in the world.” [FAA online document,

Public Guidance for Petitions for Exemption Filed under Section 333. Rev. 9/25/2014]

PRIVACY

All flights will occur over private or controlled

- access property with the property owner’s or

controlling authority’s prior consent and knowledge. Aerial photography and video capture

w ill be of people who have provided their written consent to being photographed or have

been authorized to be in the area where flight operations are taki ng place

. (see

A ttachments O and P) Establishing and maintaining tight controls over access to the flight

operations area will minimize privacy issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decade s, Reeder Flying Service Inc.’s proposed operation of the DJI Inspire 1 UAS will not

implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated under

detailed operational protocols designed to ensure client or property owner involvement as

well as local law enforcement notification. Flight operations will be conducted in

accordance with Federal Aviation Regulations, including the altitude restrictions as defined

in this Grant of Exemption

.

Reeder Flying Service Inc. has developed a proprietary work

- site planning template and

site briefing plan (see Attachment s L and M ) that will be completed and reviewed with the

client’s onsite representative prior to the commencement of any operation or project. This

detailed diagram of the operational environment will provide the PIC , VO(s), Safety Officer

, and any other designated support and security personnel with a full understanding of the

site or subject’s structural characteristics, layout, topography, adjacencies, and all

significant and relevant natural and man m ade features within the operational area. The

template will also be used by Reeder Flying Service Inc. personnel t o gai n a clear picture

of any area or condition immediately adjacent to or near the operational area. This will

enable Reeder Flying Service Inc. to acquire a detailed understanding of the larger

geographical context surrounding the flight operations area and review relevant factors with

the client before the commencement of any work or service.14 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

CONDITIONS AND LIMITATIONS

As set forth in Reeder Flying Service Inc. UAS General Operations Manual , which

includes: All manufacturer documentation for the Inspire 1 UAS and Reeder Flying

Service, Inc. proprietary operations documentation for all UAS operations (e.g., Flight

Operations Protocols, Flight Checklists and Operating Procedures, Pilot Flight Log, UAS

Flight Log, Client Site Safety and Planning Template, Pre

- Flight Operations On

- Site Client

Safety Briefing, and Permission to Conduct Onsite Flight Operations Consent Form), the

applicant proposes the following limitations and conditions:

1. Op e r a t i ons a uthori z e d b y th i s g r a nt of e x e mp t ion a re l i m i ted to the DJI Inspire 1 w h e n

w e i g hi n g less than 55 pounds in c lud i ng p a y load. P ropo s e d op e r a t i ons of a n y other a ir c r a ft

will re quire a n e w p e t i t i on or a p e t i t i on to am e nd th i s e x e mp t io n

.

2. Op e r a t i ons for t h e pur p o se of c lose d

- s e t m ot i on pictu r e a nd tel e vis i on fil m ing a r e not

p e rmit t e d.

3. The UA m a y not be o p e r a ted a t a sp e e d e x cee di n g 87 knots ( 100 m i les p e r ho u r ) . The

e x e mp t ion ho l d e r m a y u s e e i t h e r g roun d s p ee d or c a l i b ra ted a irs p ee d to det e rmine

c omp l ian c e with t he 87 k not sp ee d r e striction. I n no ca se will the U A b e o p e r a ted a t

a irsp ee ds g r ea t e r th a n the ma x i m um UA op e r a t i ng a irsp ee d r ec om m e n d e d b y the a ir c r a ft

m a nu f ac tur e r.

4. The UA must be op e r a t e d a t an a l t i t ude of no mo r e than 400 fe e t above g r o und lev e l

( A G L ). Alt i tude must be re port e d in f ee t A G L

.

5. The UA must be op e r a t e d with i n visu a l l ine of si g ht ( V L OS) of the UAS

- P I C a t a ll

t i mes. This r e quir e s the P I C to be a ble to use human vis i on un a ided b y a n y d e v i c e other

than c o r re c t i ve lens e s, a s spe c ified on the P I C’s F A A

- is s u e d a irman medi c a l c er t i fi ca te or

U.S. driv e r ’ s l i ce n s e

.

6. All ope ra t i ons must u t i l i z e a visual obse r v e r ( V O ). The UA must be op e r a t e d with i n the

visu a l l ine of si g ht ( V L OS) o f the P I C a nd VO a t all t i m e s. The VO m a y be u s e d to satis f y

the V L OS r e q u ir e ment a s lo n g a s the P IC a lw a y s m a in t a ins V L O S ca p a bi l i t y . T h e VO a nd

P I C must be a ble to c o m mun i ca te v e r b a l l y a t all t i m e s ; e le c tronic mes s a g ing o r t e x t i ng is

not p e rmit t e d du r ing f l i g ht ope r a t i ons. The P I C must be d e si g n a t e d b e f or e the f l i g ht a nd

ca nnot tr a nsf e r his or h e r d e s i g n a t i on f o r the dur a t i on of the f l i g ht. T h e P I C must e nsu r e

that the V O c a n p e r fo r m t he d u t i e s r e quir e d of t h e V O

.

7. This e x e mp t ion and a ll d o c uments n ee d e d to o p e r a te the U A S a nd c ondu c t i t s

op e r a t i ons in a c c o r d a n c e with t he c ondi t ions and lim i tations stat e d in t his g r a nt of

e x e mp t ion, a r e h e r e in a ft e r re f e r r e d to as the op e r a t ing do c uments. T h e op e r a t i ng

do c uments must be ac c e s sib l e during UAS op e r a t i ons a nd made a v a i l a ble t o the

Admin i str a tor upon re q u e st. I f a disc r e p a n c y e x is t s bet wee n the c ondi t ions a nd l i m i tations

in th i s e x e mp t ion and the pro c e d u r e s o ut l ined in the op e r a t i ng d o c uments, the c ondi t ions

and lim i ta t ions h e r e in t a ke p r e c e d e n c e a nd must be f ol l o w e d. Oth e r w ise, the o p e r a tor

must f ol l ow the pro c e du r e s as outl i n e d in i ts ope r a t i ng do c uments. The op e r a tor m a y

up d a te or r e vise its op e r a t i n g do c uments. I t is t he op e r a tor ’ s r e spons i bi l i t y to t r a c k su c h

r e vis i ons a nd p re s e nt updat e d a nd revised do c uments to the A dm i nis t r a tor or a n y l a w

e n f o rc e ment o f fi c ial upon r e q u e st. The op e r a tor must a lso pr e s e nt updat e d a nd r e vi s e d

d o c uments if it p e t i t i ons for e x tension or a mendm e nt t o th i s g ra nt of e x e mp t ion. I f the

o p e r a tor d e te r m i n e s that a n y upd a t e or re vis i on would a f f e c t t he b a sis upon whi c h the F AA15 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

g r a nted this e x e mp t ion, t h e n the op e r a tor must p e t i t i on f o r a n a m e ndment to i ts g r a nt of

e x e mp t ion. The F A A ’s U A S I n t e g r a t i on O f fi c e ( A F S

− 80) m a y b e c ont a c ted if qu e st i ons

a rise re g a rding upd a tes or re vis i ons to the op e r a t i n g do c u m e nts.

8. A n y U AS t h a t has und e r g one m a in t e n a n c e or a l te r a t i ons th a t a f f ec t t he U A S op e r a t i on

or f l i g ht c h a ra c te r is t ics, e

. g

. , r e pla c e ment of a flight c ritic a l compon e nt, m ust und e r g o a

f un c t i on a l t e st fl i g ht prior to c ondu c t i ng fu r th e r op e r a t i ons und e r this e x e mp t ion. F un c t i on a l

t e st fl i g hts m a y on l y be c ondu c ted b y a P I C with a V O a nd must r e main a t le a st 500 f e e t

f rom other p e ople. T he f u n c t i on a l t e st fl i g ht m ust be c ondu c ted in su c h a mann e r so a s to

not pose a n undue h a z a rd to p e r s ons a nd p r op e r t y

.

9. The op e r a tor is r e spons i b le f or maintaini n g a nd i n spe c t i ng the U A S to ens u re that it is

in a c ondi t ion for sa f e o p e r a t i on.

10. P rior to e ac h fl i g ht, t he P I C must c ondu c t a p r e

- fli g ht i nspe c t i on a nd d e te r m i ne the

U A S is i n a c ondi t ion for sa f e f l i g ht. The p re

- fl i ght i nspe c t i on must a cc o u nt for a ll potential

dis c r e p a n c ies, e

. g

. , inop e r a ble c ompo n e n ts, i tems, or e quip m e nt. I f the inspe c t i on r e v e a ls

a c on d i t ion t h a t a f f e c ts t he s a fe op e r a t i on of the U AS, t he a ir c r a ft is p r ohib i ted f rom

op e r a t i ng unt i l t he n e c e ssa r y ma i nten a n c e h a s be e n p e r f o r med a nd the U A S is found to

be in a c ondi t ion for sa f e f l i g ht.

11. The op e r a tor must f ol l ow the U A S manu f a c tur e r ’s mainten a n ce , o v e rh a ul,

r e pla c e ment, insp ec t i on, a nd l i fe l i m i t r e quir e me n t s for the a ir c r a ft a nd a ir c r a ft

c omponents.

12. E ac h U A S op e r a ted un d e r this e x e mp t ion m u s t comp l y with all m a nufa c tu r e r s a f e t y

bul l e t i ns.

13. Und e r this gr a nt of e x e mp t ion, a P I C must hold either a n a irline t r a nsport, c om m e r c ial,

p r iva t e , or r e c r ea t i on a l pilot certificate. T he P I C must a lso hold a c u r r e nt F AA a irman

me d ic a l c e rtifi c a te or a v a l i d U.S. driv e r ’ s l i ce n s e is s u e d b y a stat e , the D is t ri c t of

Co l umb i a

, P u e rto R i c o, a te r r i to r y , a pos s e ss i on, or the Fe d e r a l g ov e rnm e nt. The P I C

m ust also m ee t t h e f l i g ht r e v i e w re qui r e ments spe c i f ied in 14 C F R § 61.56 in an a i r c r a ft in

which t h e P I C is r a ted on his or h e r pilot ce rtifi ca te.

14. The op e r a tor m a y not pe r m i t a n y P I C to o p e r a te u nless the P I C d e monstr a t e s the

a bi l i t y to sa fe l y o p e r a te t he U A S in a m a nn e r c o n si s tent with how the U AS wi l l be op e r a ted

un d e r this e x e mp t ion, i n c lud i ng e v a sive a nd e me r g e n c y ma n e uv e rs a nd maintaining

a ppro p ri a te dis t a n ce s f r om p e rsons, v e ssels, v e hicl e s and str u c tur e s. P I C qu a l i fi ca t i on

fli g ht hours a nd c u r r e n c y must be l o g g e d in a mann e r c onsist e nt wi t h 14 C F R § 61.51 ( b )

. F l i ghts for the pu r poses of t r a in i ng the o p e r a to r ’s P I C s and V O s (t ra in i n g

, p ro f ici e n c y

, a n d

e x p e ri e n c e

- bui l di n g ) and d e te r m i ning the P I C’s a bi l i t y to s a f e l y op e r a te the U AS i n a

mann e r c onsistent with how the U AS wi l l be op e r a ted und e r this e x e mp t ion a r e p e rmit t e d

und e r the t e rms of th i s e x e mp t ion. H o w e v e r, tr a in i ng op e r a t i ons m a y on l y be c ondu c ted

du r i n g d e dic a ted t r a in i ng s e ss i ons. Du r ing tr a in i n g , pr o fi c ien c y

, a nd e x p e ri e n c e

- bui l di n g

f l i ghts, a ll p e rs o ns not e ssential f or fli g ht ope r a t i ons a re c on s ide re d nonp a rticip a nts, a nd

the P I C must op e r a t e the U A with app r opri a te dist a n c e f rom nonp a rticip a nts i n acc o r d a n c e

with 14 C F R § 91.119.

15. U A S op e r a t i ons m a y not be c ondu c ted d u ring n i g h t, as d e fin e d in 14 C F R § 1.1. All

op e r a t i ons must be c on d u c ted und e r visu a l m e t e o rolo g i c a l condit i ons ( V M C). F l i g hts

und e r sp ec i a l v i sual f l i g h t rul e s (SV F R) are not a u thori z e d.16 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

16. The UA m a y not op e r a te with i n 5 n a ut i ca l m i l e s of a n a irpo r t r e fer e n c e poi n t ( A R P ) a s

d e noted in the c u r r e nt F AA Air p o r t /F ac i l i t y Di re c to r y ( A F D) or for a i rpo r ts not d e noted w i t h

a n AR P , the ce nt e r of the a irpo r t s y mb o l as d e noted on the c u r r e nt F A A

- publ i shed

ae ro n a ut i ca l ch a rt, unless a letter o f a g re e ment with t h a t ai r port ’ s man a g e ment is obtain e d

or othe r wise p e rmit t e d by a C O A issued to the e x e mp t ion holde r . The letter o f a g re e ment

with t he a irpo r t m a n a g e ment must be m a d e a v a i l a ble to t he Admin i str a tor or a n y law

e n f o r ce ment o f fi c ial upon re qu e st.

17. The UA m a y not be o p e r a ted l e ss t h a n 500 fe e t b e l ow or less than 2,000 fe e t

hori z ontal l y f r om a c loud or w h e n vis i bi l i t y is l e ss t h a n 3 statute m i les f rom the P I C.

18. I f the U AS l oses c om m u nic a t i ons or los e s i t s GPS si g n a l, t he U A must re turn to a p re

d e t e rmin e d loc a t i on with i n the private or c on t roll e d

- a c ce ss pro p e r t y

.

19. The P I C must a bort the fli g ht i n the e v e nt of un p redict e d obst ac les or e me r g e n c ies.

20. The P I C is prohib i ted f r o m be g inn i n g a f l i g ht un le ss ( c onsid e ri n g wind a nd fo re c a st

w ea ther c ondi t ions) the r e is enou g h a v a i l a ble po w e r f or the UA to cond u c t t he in t e nd e d

op e r a t i on a nd to op e r a te a ft e r t h a t for a t l ea st five minu t e s or w i t h the re s e r v e pow e r

r ec om m e nd e d b y t he manu f a c tur e r i f g re a t e r.

21. Air T r a f fic O r g a ni z a t i on ( A TO) C e rtifi ca te of W a i v e r or Autho r i z a t i on (C O A ) . All

op e r a t i ons shall be c on d u c ted in a c c o r d a n c e with a n A T O

- is s u e d COA. T h e e x e mp t ion

ho l d e r m a y a p p l y f or a n e w o r a men d e d COA if it i ntends to c ondu c t op e r a t i ons th a t c a nnot

b e c ondu c ted und e r the te r ms of the a t t ac h e d COA.

22. All ai rc raft op e r a ted in a cc o r d a n c e with t his e x e mp t ion m ust be id e nt i fi e d b y s e ri a l

numbe r

, r e g is t e r e d in a cc o r d a n c e with 14 C F R p a r t 47, a nd h a ve identifi c a t i on

( N− Numb e r) ma r ki n g s in acc o r d a n c e with 14 C F R p a rt 45, S ubp a rt C. Ma r kin g s mu s t be

a s la r ge a s p r ac t i ca bl e

.

23. Do c uments used b y the o p e r a tor to e ns u re the s a fe op e r a t i on a nd fl i g ht of t he U A S

a nd a n y d o c uments r e qui r e d und e r 14 C F R §§ 91.9 a n d 91.203 must be a v a i l a b le to the

P I C a t t he G round Control S tation of the U A S a ny t i me the a i r c raft is ope r a t i n g

. Th e se

do c uments must b e made a v a i l a ble to the A d m i nis t r a tor or a n y law e n f o rce m e nt o f fi c ial

upon re q u e st.

24. The UA must re main c l e a r a nd g ive w a y to all ma nn e d a viation ope r a t i ons a nd

ac t i vi t ies a t all t i m e s.

25. The U A S m a y not be op e r a ted b y the P I C f rom a n y mov i n g d e vi c e or v e hi c le.

26. All F l i g ht op e r a t i ons must be c ondu c ted a t le a st 5 00 f e e t f r om a ll nonp a rti c ipating

p e rsons, v e ssels, v e hic l e s

, a nd stru c tur e s unl e ss:

a

. B a r ri e rs or str u c tur e s a re p re s e nt t h a t suf f ic i e nt l y p rot ec t nonpa r t i c i p a t i ng p e rsons f r om

t he UA a nd/ o r d e b r i s in t he e v e nt of a n a cc i d e nt. The op e r a tor must e nsure that

nonp a rticip a t i ng p e r s ons r e main und e r s u c h p r ote c t i on. I f a si t u a t i on a r ises wh e re

non p a rticip a t i n g p e rsons le a ve s u c h pr o t e c t i on a nd a re with i n 500 fe e t of the U A, f l i g ht

ope ra t i ons must cea se i m medi a te l y in a mann e r e ns u ring t h e s a f e t y of nonp a rticip a t i n g

p e rs o n s ; a nd17 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

b. The own e r

/ c ontroll e r of a n y v e ssels, v e hicl e s o r s tru c tur e s has g ra nted p er m i ss i on for

op e r a t i ng c loser to t h ose o bje c ts and the P I C h a s made a s a f e t y a s s e ss m e nt of the r isk of

op e r a t i ng c loser to those obj ec ts and d e te r m i n e d that it do e s not p re s e nt an und u e h a z a rd.

c. O p e r a t i o ns n e a r er t o t he PI C, VO

, o p e r a t o r t r a i n e es o r e s s e n ti a l p e rs o ns do not p r e s e nt a n

u n d u e h a z a r d t o t ho s e p e r s o ns p er § 91

. 1 19 ( a).

27. All ope ra t i ons shall be c o ndu c ted ov e r p riv a te or c ontro l led

- a c ce ss prop e r t y with

p e rmission f r om t he pro p e r t y o wn e r / c ontroll e r or a uthori z e d r e p re s e ntativ e

. P e rmission

f r om prop e r t y ow n e r/ c ontroll e r o r a u t hori z e d r e p re s e ntative w i ll be obtain e d for e ac h fl i g ht

t o be c ondu c ted.

28. A n y inci d e nt, a c c ident, o r f l i g ht op e rat i on that tr a ns g r e sses the l a t e r a l or v e rtic a l

bound a ri e s of the o p e r a t i on a l a r e a a s d e fin e d b y t he a ppl i ca ble COA must be re por t e d to

t he F A A ’ s U A S I n t e g r a t i on O f fi c e ( A F S

− 80) w i t hin 24 hours. A cc iden t s mu s t be r e port e d

to t he N a t i on a l T ra nsport a t i on S a f e t y B o a rd ( NT S B ) per instru c t i ons c ontain e d on the

N T S B W e b site: w w w.ntsb. g ov

.

5. LIST OF PROPRIETARY FLIGHT OPERATIONS, STANDARDS, PROTOCOLS AND

PROCEDURES DOCUMENTATION

As noted earlier, Reeder Flying Service, Inc .’ s UAS General Operations Manual (UAS

GOM) includes all manufacturer’s documentation for the DJI Inspire 1 UAS, as well as a

number of flight operations protocols, requirements and procedures Reeder Flying

Service, Inc. considers proprietary. Together, these documents governing the planning,

manag ement and execution of all Reeder Flying Service, Inc. flight operations. The UAS

GOM is reviewed and updated on a regular basis to ensure it is accurate, current and

reflects any new FAA requirement, change of standard and any improvement or addition to

i ts flight operations Reeder Flying Service, Inc. considers to be in its clients’ and the

public’s best interest.

Ten of the six teen attachments included (see Attachments G, H, I, J, K, L, M, N, O , P ) and

referenced in the request for exemption contain com mercial proprietary information that

Reeder Flying Service, Inc. has chosen not to share with others except under appropriate

confidentiality agreements at this time. These attachments contain operating conditions,

graphics and procedures that have been de veloped exclusively by Reeder Flying Service,

Inc., and that are not available to the public. Reeder Flying Service, Inc. is respectfully

requesting that these attachments be treated as proprietary information pursuant to 14

C.F.R. Section 11.35, and maint ains that they are protected from release under the

Freedom of Information Act. See 5 U.S.C. 552 et seq.

6 . THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Reeder Flying Service submits that grant of this exemption application advances the

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of

UASs into the NAS if it can be accomplished safely. This law directs the Secretary of

Transportation to consider whether certain UASs may operate safely in the NAS before

completion of the rulemaking required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UASs do not create a

hazard to users of the NAS, the public, or pose a threat to national security in light of the

following:18 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the PIC.

Reform Act § 333 (a) (1). If the Secretary determines that such vehicles “may operate

safely in the national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft in the national airspace system.” Id. § 333 (c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, from the requirement that all civil aircraft must have a current

airworthiness certificate and those regulations requiring commercial pilots to operate

aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the

Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction

in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as

amended; the strong equivalent level of safety surrounding the proposed operations; and

the significant public benefit, including enhanced safety and cost savings associated with

use of UASs for aerial videography/photography, the reduction or elimination of

unregulated operators, and the safe integration of UASs. Accordingly, the applicant

respectfully requests that the FAA grant the requested exemption without delay.

CONCLUSION

As set forth herein, Reeder Flying Service Inc. seeks an exemption pursuant to 14 C.F.R.

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the

requirements of 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.101 (e)(4) &

(5); 14 C.F.R. §§ 61.113 (a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R.

§ 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119 (b) and (c) ; 14 C.F.R. § 91.121; 14

C.F.R. § 91.151 ; 14 C.F.R. §§ 91.203 (a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. §

91 .407 (a) (1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 91.409 (a) (1) and (2); and, 14 C.F.R.

§§ 91.417 (a) and (b) to commercially operate an Unmanned Aircraft System (UAS) for the

purpose of conducting aerial video and photography over certain areas of the United

State s.

Approval of the exemption allowing commercial operations of Reeder Flying Service Inc.

UAS will increase safety by permitting an operator to conduct a service safely by adhering

to the prescribed guidelines. The exemption will also encourage the education of UAS

operators and the adoption of FAA guidelines and approval for commercial UAS operations

as pertains to Reeder Flying Service Inc. employees and contractors. It will allow Reeder

Flying Service Inc. to provide a service that benefits the public and local businesses. It

benefits the public through a higher level of safety of UAS operations and through a

smooth integration of UASs into the NAS. Having a pilot

- owned business bridges the gap

between the advancement of UAS technology and the current practices and operations in

the NAS and with the FAA. This assists the FAA with its mission of promoting aviation

while preserving safety of aviators, the public and property. The UAS operated by Reeder

Flying Service Inc. satisfies the criteria set forth in § 333 of the Reform Act

– size, weight,

speed, operating capabilities, operation within visual line of sight, and national security

–19 | Reeder Flying Serv i ce, Inc. Petition for Exemption under Section 333

and showing an equivalent level of safety to manned aircraft flights through appropriate

pilot certification and safety

- focused standards of operation. This provides more than

adequate justification for the grant of the requested exemptions allowing commercial

operations.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate

of the FAA Modernization and Reform Act of 2012, while also advancing the interests of

the public by allowing Reeder Flying Service Inc. to safely, efficiently and economically

operate the UAS commercially within the NAS.

Respectfully,

Stephen L. West

GM/Director of Operations

Reeder Flying Service Inc.

ATTACHMENTS

- All attachments presented in .pdf format

DJI Inspire 1 Manufacturer Documentation :

A. DJI Inspire 1 Overview a nd Specifications Data Sheet

B. DJI Inspire 1 User Manual_v1.4

C. DJI Inspire 1 Safety Guidelines

D. DJI Inspire 1 Quick Start Guide

E . DJI Inspi re 1 Maintenance Manual_v1.0

F. DJI Inspire 1 Intelligent Flig ht Battery Safety Guidelines

Reeder Flying Service, Inc. Proprietary Documentation :

G. Reeder Flying Service, Inc. UAS General Operations Manual, Ver1.0.pdf

H. Reeder Flying Service, Inc. UAS Daily Flight Log .pdf

I. Reeder Flying Service, I nc. UAS Inspection Status Form. pdf

J. Reeder Flying Service, Inc. UAS Pilot Duty and Flight Log .pdf

K. Reeder Flying Service, Inc. 50 hour/ 200 flight Inspection Form .pdf

L. Site Safety and Planning Template

M. Client Site and Operation Plan

N. Pre

- Flight Operations On

- Site Client Safety Briefing

O. Permission to Conduct Onsite Flight Operations Consent Form

P. Photo and Video Image Release Form