Applicant’s Petition for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

Applicant: Airspace Consultant of Applicant:
RETTEW Attn: Brian Freed 5031 Richard Lane, Suite 111 Mechanicsburg, PA 17055 Phone: (717) 697-3551 Email: brian.freed@rettew.com Clyde J. Pittman Director of Engineering Federal Airways & Airspace 1423 S. Patrick Dr. Satellite Beach, FL 32937 Phone: (321) 777-12661 

### I. SUMMARY OF PETITION Pursuant to Section 333 of the FAA Modernizatio n and Reform Act of 2012 (“Section 333”), RETTEW (“Applicant”) hereby respectfully requests expedited approval to use Small Unmanned Aircraft System (“sUAS”) under the terms and conditions described in th is Petition for Exemption (“Petition”) to conduct surveys throughout the United States. RETTEW also re quests the exemptions that are necessary to such approval pursuant to 49 U.S.C. § 44701(f), and 14 C.F.R. § 11.81. 1 Applicant seeks to use sUAS to perform visual inspec tions of project sites and surveying purposes. Small UAS are ideally suited for the inspection of project si tes and surveying—they can safely, inexpensively, and quickly deliver high-quality photo and video, which eliminates the need for physical inspection with traditional methods. Not only do sUAS have potential be nefits to the environment, they also can facilitate the safe surveying and inspection of hard-to-access or en vironmentally sensitive areas without the use of ATVs, light-duty trucks and associated equipment that may have more impact than sUAS. sUAS can also allow greater access to densely vegetated or impassable areas. The use of sUAS would allow for greater precision in imagery that would require a MSL height too low for co nventional aircraft. In addition, RETTEW frequently surveys slope failures in mountainous terrain. When a road collapses or repairs are needed, often times workers do not have the luxury to wait on weather. Ri sky methods, such as the use of belay lines by workers to navigate down a mountain side, woul d become obsolete or a last resort if the use of sUASs is introduced. Sites that are vacant or under development would also benefit from the use of UAS. They will allow for the reduction of the risk of injury by eliminating of th e need for large amounts of workers in a potentially

1 As described in Appendix A to this Petiti on, Applicant requests an exemption from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. Part 27; 14 C.F.R. §§ 45.23(b); 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(b); 91.9(b)(2); 91.103; 91.109; 9 1.119; 91.121; 91.151(a); 91.203(a) and (b); 91.319(a)(1); 91.405(a); 91.407(a)(1); 91.409 (a)(2); 91.417 (a) and (b); 91.1501.2 hazardous environment. There are many risks in every type of work place but especially in the surveying and construction fields. In many cases sUAS can be more efficient and cost effective than traditional methods, which can help to reduce operations and overall project costs and perhaps most importantly, provide a means for quicker resolution of any problems encountered during projects. A reduction of overall costs would be of benefit to the public by being able to pass any reduction of costs directly to the client and in turn to the public that would be utilizing their services. The public interest is critical to our success and the approval of this request and the provision of the necessary exemptions will enhance employee and public safety, increase productivity, and decrease client and consumer costs. In addition, larger more conventional aircraft are potentially hazardous due to size, emission of hazardous pollutants, and combustible fuel. Moreover, approving the requested use would represent a significant step forward in the Federal Aviation Administration’s (“Administration”) efforts to integrate sUAS into the national airspace system. RETTEW provides a wide range of engineering, enviro nmental, surveying, planning, safety, and related consulting services. The use of sUAS in surveying and inspection can significantly increase the quality and accuracy of site evaluation and investigation. RETTEW currently has a network of 10 successful, well s upported offices in five states. RETTEW’s request provides the Administration with an opportunity to pa rtner with an engineering firm ranked by Engineering News-Record as one of the top design firms in the Un ited States as it works to develop its rulemaking pursuant to the FAA Reauthorization Act of 2012 —while doing so for a compelling public purpose and under strict operational and safety guidelines. Given the uni queness of Applicant—the company offers its services over a diverse geographical, environmental, and a distin ctive resource mix—it is ideally suited to help the Administration understand the potential survey applications for sUAS.3 RETTEW proposes to use sUAS that are rotorcraft, we igh 15 or fewer pounds, operate at a speed of no more than 87 knots (100 mph) or the maximum UAS operating speed as indicated by the manufacturer (whichever is lower), and contain built-in safety features . In addition, RETTEW proposes to use the aircraft at low altitudes for a majority of operations, not in pr oximity to airports or densely populated areas, on property that is owned or controlled by RETTEW or is owned or controlled by clients utilizing RETTEW's services, within the visual line of sight of the op erator, and under controlled conditions. Accordingly, the requested exemptions satisfy the applicable statutory cr iteria and policies, will serve the public interest, will not adversely affect safety, and will provide a level of sa fety at least equal to the existing airworthiness and related regulations. Approval of this Petition is theref ore consistent with Section 333’s directive to “establish requirements for the safe operation of [unmanned aircraft systems] in the national airspace system” if the Secretary of Transportation determines that certain unmanned aircraft systems may operate safely in the national airspace system. 2

2 Section 333(c) of the FAA Moderniz ation and Reform Act of 2012, Pub. L. No. 112-95, 126 Stat 11.4 

### II. APPLICANT BACKGROUND RETTEW is a Pennsylvania based engineering firm that has been recognized by Engineering New-Record as one of the top design firms in the United States. RETTEW has been providing a wide range of engineering, environmental, surveying, planning, safety, and related consulting services since 1969. Growing from a single location to more than ten successful, well-supported offices in five states. We are committed, first and foremost to safety. Our employees and the health and well-being of the public are of paramount importance. We strive to provide an inherently safe work environmen t, be it on a job site or in an office. All safety measures taken are required to perform the work reques ted by our clients and are critical to maintaining everyone's well-being. We believe that completing a job safely is just as imperative as completing a quality project on time. Safety is a core value at RETTEW and it is a corporate goal to have zero work-related incidents. In addition to work place safety, RETTEW is committe d to minimizing environmental impacts. Focusing on resource conservation and sustainable design projects, RETTEW is committed to everyday business practices being as environmentally responsible as possi ble. In this way, RETTEW' s policy contributes to improving the quality of life for the communities, clients, and employees that are served. The use of sUAS by RETTEW correlates to both the environmentally friendly ideals that RETTEW practices, especially the conservation and reduction of fuel consumption as well as the principles of work place, employee, and public safety. Utilization of sUAS has the potential to further reduce carbon emissions. Consistent with RETTEW's efforts for providing safe and reliable service to our clients, RETTEW seeks to use sUAS to more safely and effectively perform insp ections and surveys during various stages of projects. This includes but is not limited to:

 Monitor pipeline construction. Assistance in e nhanced documentation of trench installation.

 Survey of hazardous areas including:5 o Industrial facilities,

o Gas well pads, and

o Active gas compressor stations.

 Inspection and documentation of bridges, especially for structural deficiencies and deterioration.

 Rapid documentation of accident scenes (via safe ty group). Allow post-cleanup scene reconstruction for further analysis.



### III. RELEVANT STATUTORY AUTHORITY
A. SECTION 333 Section 333(a) states that the Administration “sha ll determine if certain unmanned aircraft system before completion of the plan and rulemaking [to broa dly integrate UAS into the national airspace] required by Section 332 of this Act.” Section 333 is also described as a pathway for “expedited operational authorization.” 3 Section 333(b)(1) outlines the factors that the Admi nistration shall use to determine whether UAS may be operated safely in the national airspace system: size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight. In addition, and importantly for this Petition, Section 333(b)(2) provides the Administration wi th the discretion to determine that a certificate of waiver, certificate of authorization, or airworthiness certification is not required to operate UAS that are found to be appropriate under Section 333(b)(1). Fina lly, Section 333(c) allows the Administration to establish requirements for safe operation of the UAS dete rmined to be able to be operated safely in the national airspace system.

3 Section 332(b)(1).6 

### B. SECTION 44701(F) In addition to its specific authority related to authorizing UAS operation under Section 333, the Administration has general authority to grant exemptions from its safety requirements and minimum standards if the Administration finds that the exemption is in the public interest. 4 Administration regulations set forth the information that must be included in the petition for exemption: (1) the applicant’s name and mailing address; (2) the regulations from which the applic ant seeks exemption; (3) the extent of relief sought and why; (4) the reasons why granting the request would be in the public interest and how it would benefit the public as a whole; and (5) the reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at le ast equal to the rule from which the applicant seeks exemption. 5



### IV. DISCUSSION
A. APPLICANT’S PROPOSAL SATISFIES TH E SECTION 333 CRITERIA FOR APPROVAL. As described above, Section 333(b)(1) outlines the factors that the Administration shall use to determine whether UAS may be operated safely in the national airspace system: size, weight, speed, operational capability, proximity to airports and populated areas, a nd operation within visual line of sight. Applying the criteria outlined in Section 333(b)(1) and other relevant criteria to this case demonstrates that Applicant’s proposed terms and conditions of operation will result in the sUAS being operated safely in the national airspace system, consistent with Sect ion 333. Based on the small size of the sUASs involved, the low altitude and restricted environment in which they will operate, and the fact that they will be operated within the

4 49 U.S.C. § 44701(f).

5 14 C.F.R. § 11.81.7 visual line of sight of the operator, there is more than sufficient basis to find that the sUAS can be operated safely under Applicant’s proposal.



### 1. SIZE, WEIGHT, SPEED, AND OPERATIONAL CAPABILITY Applicant proposes to use small, multi-rotor craft with a maximum take-off weight of 15 pounds or less, powered by electric batteries, and carry no flammabl e fuel or cargo. RETTEW anticipates the majority of flights will use much smaller craft—quadcopters with a maximum takeoff weight of less than five pounds. Heavier craft (up to 15 pounds) will only be used in situations requiring specialized equipment. The sUAS used by RETTEW will have an integrated GPS autopilot system. The integrated GPS autopilot provide stable, precise flight, and stable hovering—ena bling field workers to focus on situational awareness and the safety of themselves and the public. In addition, the GPS autopilot system provides an automatic return to home capability in the unlikely case of signal loss with the operator. These small, multi-rotor craft are ideally suited for surveying and aerial imaging of project sites because they often deliver high-quality photo and video more efficiently and cost effectively than traditional methods. Using sUAS can also be safer for employees because it will avoid putting workers in a potentially dangerous setting as with vacant sites and under-develo pment sites. The use of sUAS would allow access and safe inspection or survey of densely vegetated, envi ronmentally sensitive, or impassable areas that would otherwise be difficult for workers to perform their required tasks without the use of heavy machinery or other utility vehicles. Overall, sUAS can provide significan t benefits over traditional survey and site inspection methods to employees and clients.


### 2. PROXIMITY TO AIRPORTS/POPULATED AREAS Applicant will avoid operating the sUAS over densely populated areas. Operations shall be a minimum of the following distances from the airport reference poin t of any public use airport, heliport, gliderport, or seaport listed in the Airport/Facility Directory, Alaska Supplement, or Pacific Chart Supplement of the U.S.8 Government Flight Information Publications: five nautic al miles away from any airport with a control tower, three nautical miles away from any airport with publis hed instrument procedures but no control tower, two nautical miles away from any airport with no publishe d instrument procedures and no control tower, and two nautical miles from any heliport. These guidelines shall be followed unless a letter of agreement with that airport's management is obtained. Any letter of agreement with airport management shall be made available upon request. The sUAS will be operated a majority of the time at low altitudes of 250 feet Above Ground Level (AGL) or less—much lower than the airspace in which manne d vehicles operate and lower than the altitude at which hobby aircraft fly. Altitudes above this value ( 250 feet AGL) up to 400 feet AGL, shall be requested during the NOTAM process, by obtaining a letter of agre ement with the closest airport's management or by acquiring a COA to operate above 250 feet AGL. Finally, all operations will occur over areas that are owned or controlled by RETTEW, has obtained written or verbal permission from the property owner(s), or within public right-of-way of roads or bridges. All operations shall adhere to the standards set forth in section IV (1)(B): Mandatory Operating Conditions, (C): Operator Tr aining and Certificate, (D) Privacy Considerations of this document.



### 3. VISUAL LINE OF SIGHT A FAA licensed pilot will operate the sUAS during day light hours, in good weather, and within the operator's or visual observer's line of sight. The operat or will be accompanied by at least one trained spotter, who will be positioned in line of sight of the aircraft and will be in constant comm unication with the operator to identify and alert the operator to any potential obst acles. This eliminates the need for other “sense and9 avoid” capabilities during operation, as well as the need for any method of air traffic control communications. 6



### B. APPLICANT’S PROPOSAL ALSO SATISFI ES THE STANDARD FOR EXEMPTION UNDER SECTION 44701 AND 14 C.F.R. § 11.81.
1. GRANTING APPLICANT’S REQUEST WOULD NOT ADVERSELY AFFECT SAFETY AND WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO EXISTING RULES. Granting RETTEW’s Petition will not adversely affect safety. Applicant’s proposed terms and conditions of operation would provide a level of safety at least equal to existing rules. As discussed above with respect to Section 333(b)(1) criteria, the size, weight, speed, and operational capability of the sUAS that will be used in the proposed operations indicate that the aircraft can be operated safely in the national airspace system. Moreover, the aircraft will be operated at low altitude s, not in proximity to airp orts or densely populated areas, and within the visual line of sight of the op erator and spotter. In addition, RETTEW proposes the following conditions to ensure that the requested exemptio n would result in a level of safety at least equal to the rules from which RETTEW is seeking an exemption.



### A. SAFETY SYSTEMS Applicant will use sUAS that have a semi-autonomou s navigation and control system comprised of a Remote Control and “auto-pilot” system. Automated safe ty functions and safety enhancing features of the sUAS that RETTEW will use include the following:



###  Precision Flight and Stable Hovering : Integrated Flight Mode that allows the aircraft to hover accurately in position indoors and outdoors. GPS auto pilot system provides position holding, altitude

6 See Interim Operational Approval Guidance 08-01, Unmanned Aircraft Systems Operations in the U.S. National Airspace System at 4 (Mar. 13, 2008).10 lock, and stable hovering to all field personnel to focus on situational awareness and safely getting the job done.



###  Auto Return-To-Home : Fail-safe feature automatically activates in the event of signal loss with the remote controller. The aircraft is able to record a "Home Point" when the GPS signal is strong. This is the point the aircraft shall return to when this function is activated.



###  Intelligent Orientation Control (IOC): Allows the operator to lock the orientation of the aircraft. There are three types of locks in this feature: Co urse Lock, Home Lock, and Point of Interest. For additional information regarding the IOC, please see the accompanying operations manual.



###  Clearly Visible Battery and GPS Status : Battery and GPS Status will be available through airframe status lights clearly visible to the operator a nd available through the ground station display.



###  No Fly Zones :
o Airport: Comprised of takeoff restricted zones and restricted altitude zones. Takeoff restricted areas allow for no takeoff by the UAS, flight is prevented. Restricted altitude areas, flight is limited on a 15° incline for the radius of the restricted area plus 1 mile. 320 feet away from a no fly zone, the operator will receive a warning message.
o Restricted : Consists only of a takeoff restricted ar ea. These areas allow for no takeoff by the UAS, flight is prevented. There is a warning zone that is set around each restricted area. When the UAS is within 1 km of the restricted zone, a warning message will appear to the operator.


### B. MANDATORY OPERATING CONDITIONS In addition to the safety features described above, RETTEW proposes that its exemption be subject to the following mandatory conditions to ensure safe operation:

 Operations will avoid densely populated areas.

 Operations will be conducted over property that is owned or controlled by RETTEW, where the owner has given written or verbal permission to RETTEW for the use of UASs, or in utility or public right-of-way.

 Maximum total operation time for each flight w ill be 60 minutes. Flights will be terminated at 25% battery power reserve, should that occur before this time limit.

 Operations will occur during Visual Flight Rules Meteorological Conditions.

 Aircraft to remain within Visual Line of Sight (VLOS). VLOS will be guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles.

 Operations will occur during daylight hours.

 Most flights will be operated at an altitude of no more than 250 feet Above Ground Level (“AGL”). Altitudes above this value (250 feet AGL) up to 400 feet AGL, shall be requested during the NOTAM process, by obtaining a letter of ag reement with the closest airport's management, or by acquiring a COA to op erate above 250 feet AGL.11  All operations to remain more than the following distances of any public use airport, heliport, gliderport, or seaport listed in the Airport/Facilities Directory, Alaska Supplement, or Pacific Chart Supplement of the U.S. Governme nt Flight Information Publications:
o Five nautical miles from an airport with a control tower,

o Three nautical miles from an airport with no control tower but published instrument flight procedures,
o Two nautical miles from an airport with not control tower and no published instrument flight procedures, and
o Two nautical miles from a heliport Unless a letter of agreement with that airport's management is obtained. Any letter of agreement with airport management shall be made available upon request.

 Operators and spotters will meet the operator tr aining and certification requirements proposed below:
o Operators and spotters will be in communication at all times.
o Operator will perform required maintenance per the manufacturer’s recommendations and keep a log of any maintenance performed.
o Operator will perform any safety checks specified in the manufacturer’s user guide prior to each flight.


### C. OPERATOR TRAINING AND CERTIFICATION As discussed above, the sUAS RETTEW will use are ch aracterized by a high degree of control and built-in technical capabilities that limit the potential for operat ion outside the operating conditions set forth in this Petition. Moreover, the mandatory operating conditions (maximum altitude, proximity to airfields, visual line of sight) minimize any potential weather impact and interactions with other aircraft. Situational awareness around high-voltage and construction equipment, a thorough working knowledge of the sUAS, and strict adherence to corporate sUAS fl ight policy are key to safe sUAS operations. Given the significant differences between sUAS and piloted aircraft , the safety features inherent in the sUAS, and the strict operating conditions that will apply, RETEW propos es that, in addition to holding a sport level pilot license, operators of the sUAS shall also be required to have:

 Proven knowledge of RETTEW's UAS flight po licy (including Mandatory Operating Conditions specified in this Petition),12  Proven working knowledge of safe sUAS operatio ns, flight characteristics, safety features, GPS/Battery Status indicators, and emergency procedures,

 Knowledge regarding safe operations around high voltage power lines, substation equipment, and power plants,

 Knowledge regarding safe operations around construction equipment, and

 A valid driver’s license. Applicant is receptive to future regulations and industr y guidance on licensing sUAS pilots using training and testing that is relevant to oper ating sUAS in a limited flight area.



### D. PRIVACY CONSIDERATIONS Applicant will not operate sUAS in any way that may invade personal privacy and will comply with any federal, state, or local privacy laws that may apply in areas where RETTEW operates sUAS. In addition, as a practical matter, flights will occur over property/struc tures that is owned or controlled by RETTEW, where written or verbal permission from the owner(s) has been given, or in utility or public right-of-way. Privacy is unlikely to be a concern in relation to Applicant’s proposed use. All operations will be conducted at least 200 feet from all nonparticipat ing persons, vessels, vehicles, and structures unless a barrier or structure is present that will sufficiently protect any non participants from the UAS or any debris in the event of an accident, operatio ns may be conducted within the 200 foot limit. If any nonparticipants leave such protected areas and are located within the 200 foot buffer area, all UAS operations shall cease immediately in order to en sure the safety of the nonparticipating persons. In the event the UAS will need to be flown closer than 200 feet to any vessel, vehicle, or structure permission shall be obtained prior to the commencement of operations. Permission shall be obtained prior to any operations that will be conducted over property, structures, etc. that is not owned or controlled by RETTEW.13 

### 2. GRANTING APPLICANT’S REQUEST WOULD BE IN THE PUBLIC INTEREST AND WOULD BENEFIT THE PUBLIC AS A WHOLE. Allowing the requested use will provide significant benefits to the public, RETTEW clients, and RETTEW employees. Using sUAS for surveying and to inspect project sites can be safer and more efficient than traditional methods. The increased safety and efficiency of using sUAS to survey and inspect project sites is especially important to RETTEW, which not only serves clients in Pennsylvania but also throughout the U.S. where projects can range from closed construction sites to surveying bridges and roads. A survey and inspection process that is safer and more efficient can help to lower operation costs and more quickly resolve problems, both of which will benefit customers. Moreover, the requested use presents a compelling ca se for the Administration moving forward with efforts to integrate sUAS into the national airspace system as required by Section 333. RETTEW has proposed using sUAS to further this public interest in a way that is at least as safe as operatio n of aircraft under existing regulations. Applicant’s request, therefore, provides the Administration an appropriate vehicle to further Congress’ mandate to expedite integration of UAS. In addition, Applicant’s operational experience resulting from the use of sUAS in utility operations may be valuable to the Administration in developing comprehensive rules governing sUAS for others in the engineering industry.



### C. DESCRIPTION OF RELIEF SOUGHT AND REGULATIONS FROM WHICH EXEMPTION IS REQUESTED Based on the foregoing, Applicant’s proposal satisf ies the criteria for approval under Section 333. In addition, Applicant’s proposal meets the requirement s and policies for exemptions from Administration14 regulations. RETTEW therefore respectfully requests th at the Administration grant exemptions from the regulations set forth in Appendix A to this Petition. 7



### V. CONCLUSION For the reasons discussed above, RETTEW satisfies the relevant criteria for approval under Section 333 and exemptions from referenced regulations pursuant to Section 44701(f). Accordingly, RETTEW respectfully requests that the Administration grant the relief requested in this Petition to allow the use of sUAS for the purposes and under the conditions set forth herein. Gran ting this Petition will not only further Congress’ instruction to expedite the safe integration of UAS into the national airspace system, but will also further the significant public interest for safe and efficient survey of projects and site inspection.



### September 18, 2015 Respectfully submitted,

_____________________________ Clyde J. Pittman Director of Engineering Federal Airways & Airspace 1423 S. Patrick Dr. Satellite Beach, FL 32937 Phone: (321) 777-1266

7 Applicant has attempted to identify the app licable regulations for which an exemption is required for the proposed use. To the extent that the Administration determines that any othe r safety regulations might apply to Applic ant’s proposed use, Applicant further requ ests that this Petition be deemed to seek an exemption from those requirements.Appendix A to Applicant’s Petition for Exemption Page 1 

### APPENDIX A: REGULATIONS FROM WHICH EXEMPTION IS REQUESTED Applicant has attempted to identify the applicable re gulations for which an exemption is required for the proposed use. To the extent that the Administration determines that any other safety regulations might apply to Applicant’s proposed use, RETTEW further requ ests that this Petition be deemed to seek an exemption from those requirements.



### 1. 14 C.F.R. PART 21: AIRWORTHINESS CERTIFICATION Part 21 establishes procedural requirements fo r certifications under Section 44704, including airworthiness certificates. Both Sections 333 and 44701(b) authorize the Administration to exempt aircraft from airworthiness certification under this Part based upon consideration of its size, weight, speed, operational capability, an d proximity to airports and populated areas. S ee Section 333. An analysis of these criteria demons trates that the sUAS 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 operating with an airworthine ss certificate without the restrictions and conditions proposed. The sUAS(s) RETTEW will use are 15 pounds or less, ca rry no pilot or passengers, and carry no explosive materials or flammable liquid fuels. Operations under th is exemption will be tightly controlled and monitored by the operator and spotter. These safety enhancements provide at least the same degree of safety to the public and property owners than conventional oper ations conducted with airworthiness certificates.



### 2. 14 C.F.R. PART 27: AIRWORTHINESS STANDARDS FOR NORMAL CATEGORY ROTORCRAFT Part 27 sets forth the procedural requirements fo r airworthiness certification of normal category rotorcraft. To the extent the sUAS would otherwise re quire certification under Part 27, as a rotorcraft, RETTEW requests an exemption from Part 27’s airworthin ess standards for the same reasons identified above with respect to Part 21 requirements.Appendix A to Applicant’s Petition for Exemption Page 2 

### 3. 14 C.F.R. § 45.23(B): MARKING REQUIREMENTS Section 45.23(b) requires that on limited, restricted, or light-sport category aircraft, or experimental or provisionally certificated aircraft, markings indicating the aircraft category must be displayed in letters not less than two inches nor more than six inches high “near each entrance to the cabin, cockpit, or pilot station.” Exemption from 14 C.F.R. § 45.23(b) is warranted because the aircraft has no entrance to the cabin, cockpit, or pilot station on which the required marking can be displayed. RETTEW requests an exemption to 14 C.F.R. § 45.23(b)’s marking requirements and proposes instead to display markings to the fullest extent possible in compliance with the location requirements of 14 C.F.R. § 45.27(a) and the size requirements of 14 C.F.R. § 45.29(f).


### 4. 4 C.F.R. § 91.7(A): CIVIL AIRCRAFT WORTHINESS Section 91.7(a) requires that no person may operate a ci vil aircraft unless it is in airworthy condition. If the Administration grants Applicant’s request for exemption from the requirement to obtain an airworthiness certificate, no Administration regulatory standard will exist for determining airworthiness. RETTEW will, however, maintain the sUASs as directed by the ma nufacturers and conduct any recommended safety checks prior to each flight.


### 5. 14 C.F.R. § 91.9(B)(2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT Section 91.9(b)(2) prohibits a person from operating a ci vil aircraft “[f]or which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapte r, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, appr oved manual material, markings, and placards, or any combination thereof.” Given the size and configuration of the sUASs RETTEW will use, it is not possible to carry such a flight manual on the aircraft. The equivalent level of safe ty will be achieved by keeping the flight manual (specifically, the manufacturer’s user guide) at th e ground control point where the operator will have immediate access to it.Appendix A to Applicant’s Petition for Exemption Page 3 

### 6. 14 C.F.R. § 91.103: PREFLIGHT ACTION Section 91.103 requires a pilot in command to become familiar with specific information before each flight, including information contained in the Administra tion-approved Flight Manual on board the aircraft. As no Administration-approved Flight Manual will be provided, RETTEW requests an exemption from this requirement. The operator would, however, become familiar with the manufacturer’s user guide.


### 7. 14 C.F.R. §§ 91.109, 91.319(A)(1): FLIGHT INSTRUCTION These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircra ft has fully functioning dua l controls. The sUASs RETTEW will use are remotely-piloted aircraft and designed with out fully functioning dual controls. Flight control is accomplished through the use of a control box th at communicates with the aircraft via radio communications. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, by the size and speed of the ai rcraft, and the safety features of the aircraft that limit the potential for operation outside the operating conditions set forth in this Petition.



### 8. 14 C.F.R. § 91.119: MINIMUM SAFE ALTITUDES Section 91.119(c) prescribes the minimum safe altitu des under which aircraft may not operate, including 500 feet above the surface and away from any person, ve ssel, vehicle, or structure in non-congested areas. Section 91.119(d)(1) allows for a helicopter to operat e at less than those minimum altitudes under certain conditions. As described above, most operations RETTEW will co nduct with the sUAS shall be at altitudes up to 250 feet AGL, and therefore requests an exemption from the 500-foot minimum altitude. Given the size, weight, and speed of the sUAS and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircra ft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must generally operate above 500 feet.Appendix A to Applicant’s Petition for Exemption Page 4 

### 9. 14 C.F.R. § 91.121: ALTIMETER SETTINGS Section 121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “to the elevation of the departur e airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a ba rometric altimeter, but instead use GPS technology, RETTEW requests an exemption from this requirement to the extent it operates sUAS without a barometric altimeter. An equivalent level of safety will be achi eved by the operator confirming the acquisition of GPS signals and an initial ground level altitude of zero prior to take off.


### 10. 14 C.F.R. § 91.151(A): FUEL REQUIREM ENTS FOR FLIGHT IN VFR CONDITIONS Section 91.151(a) prohibits an individual from beginni ng “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly af ter that for at least 45 minutes.” Applicant requests an exemption fr om the 30 minutes of reserve fuel requirement. Given the limitations on flight locations and operations set forth in this Pe tition, a longer time frame for flight is reasonable. Operating the sUAS in a tightly controlled area with le ss than 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Applicant proposes that an equivalent level of safety can be achieved by limiting flights to 60 minutes or 25% of battery power, whichever happens first. This re striction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.


### 11. 14 C.F.R. § 91.203(A) AND (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION Section 91.203 requires a civil aircraft to have “within it . . . [a]n appropriate and current airworthiness certificate” that must be “displayed at the cabin or co ckpit entrance so that it is legible to passengers or crew.” As discussed above with respect to Section 91.9( b)(2) requiring the aircraft to carry a flight manual,Appendix A to Applicant’s Petition for Exemption Page 5 the physical characteristics of sUAS are such that there is no ability or place to carry registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping registration documents at the ground control point where the operator will have immediate access to them. Moreover, the requirement to carry airworthiness certificate w ill not apply to RETTEW if the Administration grants Applicant’s request for an exemption from this requirement, as requested above.


### 12. 14 C.F.R. §§ 91.405(A); 91.407(A)(1); 91.409(A)(2); 91.417(A) AND (B): MAINTENANCE INSPECTIONS These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. Specifically, 14 C.F.R. § 91.405(a) stat es that the owner or operator of an aircraft shall have the aircraft inspected as prescribed in the rules and have discrepanc ies repaired as prescribed in part 43; 14 C.F.R. §§ 407(a)(1) and 409(a)(2) requires that an aircraft be appr oved for return to service by a person authorized under 14 C.F.R. Section 43.7 after it has undergone ma intenance or receives an annual inspection; and 14 C.F.R. § 417 requires an owner or operator of an aircraft to maintain specific types of maintenance records, including signatures of the person authorized to approve the aircraft’s return to service. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Applicant’s operation of sU AS. Maintenance will be accomplished by the operator pursuant to the manufacturer specifications. An equivale nt level of safety to existing regulations will be achieved because these sUASs are very limited in size, op erate only in restricted areas for limited periods of time, and carry no flammable fuel. If mechanical issu es arise, the sUAS can land immediately and will be operating from no higher than 250 feet AGL. As describe d above, the operator will ensure that the sUAS is in working order prior to initiating flight, perform a pref light safety checklist, perform required maintenance, and keep a log of any maintenance 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.Appendix A to Applicant’s Petition for Exemption Page 6 

### 13. 14 C.F.R. § 91.1501: CONTINUED AIRWORTHINESS Section 91.1501(a) “requires operators to support the continued airworthiness of each airplane.” RETTEW requests an exemption from this regulation beca use the sUAS will not be subject to an airworthiness certificate



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14. ADDITIONAL EXEMPTION REQUESTS The FAA's current guidance on Section 333 Exemption requests requires the use of airline, transport, commercial, private, recreational, or sport pilot certif ication to be in command of the aircraft during UAS operations. RETTEW requests an exemption from rules/regu lations contained within 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), and 61.315(a) that specifica lly address limitations of private, recreation, and sport pilot certification that would not allow persons holdin g these certifications to commercially operate UAS's.Appendix B to Applicant’s Petition for Exemption Page 1 

### APPENDIX B: SUMMARY SUITABLE FOR PUBLICATION IN THE FEDERAL REGISTER Applicant petitions the Federal Aviation Administration for relief from compliance with 14 C.F.R. Part 21;14 C.F.R. Part 27; 14 C.F.R. §§ 45.23(b); 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91 .151(a); 91.203(a) and (b); 91.319(a)(1); 91.405(a); 91.407(a)(1); 91.409 (a)(2); 91.417 (a) and (b); 91.1501 for purposes of operating small unmanned aircraft 15 pounds or less on property that is owned or controlled by RETTEW, in utility or public right-of-way to inspect energy and civil infrastructure, or if written or verbal permission has been obtained from the owner(s). RETTEW proposes that its operation be subject to the operating conditions and safety standards set forth in the petition in lieu of the above-referenced regulations in order to provide a level of safety equivalent to those regulations.