## lAW OFFICES OF WAYNE 

## A. JOHNSON WAYNEA. JOHNSON, ATTORNEY 2901 W. PARKER ROAD#864434 PLANO, TEXAS 75086 214.454.3292

October 14, 2015 Docket ManagementFacility U.S. Department ofTransportation 1200 NewJersey Ave. SE West Building Ground FloorRoom W12-140 Washington, DC 20590 Re: InTechSys, LLC Exemptionrequest under Section 333 ofthe FAAReform Act and Part 11 ofthe Federal Aviation Regulations Dear SirorMadam: Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 and 14 CFRPart 11, InTechSys, LLC hereby applies for an exemptionfrom the Federal Aviation Regulations (FARs) listed below and discussed inAppendix A. Exemption is being sought in orderto allow InTechSys to operate its small unmanned aircraft systems (sUAS) in commercial operations involving aerial applications such as photography, data gathering, inspections, surveying, sUAS flight training, and demonstrations. sUAS are ideally suited for the commercial operations such asthe above because the aircraft has the capabilityto deliverhigh quality datamore efficiently and cost-effectively thantraditional methods. Using sUAS can also be safer for workers because inmany cases it will avoid putting workers in situations withpotential hazards, eliminating the risk ofinjuries. They also allowthe safe inspection ofhard-to-access or**environmentally\~ensitive** areas withoutthe use oftrucks and otherutilityvehicles. Overall, sUAS canprovide significantbenefits to workers and customers overthese traditional methods. \\\ 

## \ InTechSys proposes to use sUAS that are rotorcraft and one\fixed wing aircraft, which crafts have a maximumtakeoffweight ofunder 55 pounds, will be'operated at a speed ofno more than 50 knots, and which crafts containbuilt-in safety features. Proposed operations will be conducted under controlled conditions in airspace that is (1) limited, (2) predetermined, and 

### (3) access controlled. Operationsunderthe exemption will be subjectto strict operatingparameters to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft.



### liP ageThe name and mailing address ofthe petitioner, InTechSys LLC, is: InTechSys, LLC Attn: EdTovar Ph.: 512.431.0545 Email: etovar@dronepilot.io Address: 6905 MesaDrive, Austin, Texas 78731 The regulations from which the exemptionis requested are listedbelow. These are more fully discussed inAppendix A. 14 CFR 

### § 61.113 (a) and (b) 14 CFR §61.133 (a) 14 CFR 

### § 91.7 (a) 14 CFR 

### § 91.119 (c) 14 CFR 

### § 91.121 14 CFR 

### § 91.151 (a) 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)

The Unmanned Aircraft Systems. InTechSys proposes to use sUAS that are rotorcraft and one fixed wing aircraft, which crafts have a maximumtakeoffweight ofless than 

### 55 pounds (including payload), will be operated at a speed ofno more than 50 knots, and which crafts contain built-in safety features. Proposed operations will be conductedunder controlled conditions inairspace that is (1) limited, (2) predetermined, and (3) access controlled. Operations underthe exemption will be subjectto strict operatingparametersto ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft. InTechSys will conduct operations with lightweight rotorcrafts producedbyindustry leaders DJI, 3D Robotics and Yuneec Electric Aviation, along with one small 3DRobotics fixed wing (Aero). These aircraft are identified below. 

### DJI 

### aircraft

• Phantom 2 • Phantom 2 Vision + • Phantom 3 Standard • Phantom 3 Professional • Phantom 3 Advanced • Inspire 1 • S 800 EVO • S900 

## • s 1000 

### 2\Page

# • s 1000+ 30 Robotics aircraft 

### • XB+ • 3DR Aero fixed wing • Solo Yuneec Electric Aviation aircraft

• Typhoon QSOO • Typhoon QSOO + • Typhoon QSOO 4K

These sUAS have commoncharacteristics. Each canbe operated by toggle or entirely by a touch-screen, map-based interface. This means the operator only needs to commandthe system where to go, andthe system does all the flying for the operator. They canbe operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones ormaximum flight ranges and altitudes so the system cannot enter areas deemed unsafe orunnecessary to fly over. In addition, the sUAS have built-in intelligent fault handling capabilities which allowthem to detect a system fault while inthe air and automatically fly backto its take-offlocation and land. Faultsthat canbe detected include: loss ofcommunication; exceedingpre-set wind thresholds; and lowbattery levels. All flight operations are global positioning system (GPS) controlled, making the systems easyto navigate. At anypointifthe operatoris not explicitly commandingthe rotorcraft system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometricpressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. DJI, 3DRand Yuneec all maintain online product information portals with comprehensive downloadable operating and maintenance manuals, user guides, flight checklists, safety information and missionplanning instructions. Available also are instructional product and training videos along withrobust online blogs and product forums. 

### OperatingDocuments. The web addresses for the comprehensive operation manuals/user guides for each aircraft are listed onAppendix "B". They are available openly onthe internet at the manufacturers' website. Standard Operating Procedures, Pre-flight checklist and Post-flight checklist are attached as Appendices "C", "D" and "E". 

### ThePIC (pilot in command).

31Page• A PIC musthold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government.

• In the case ofrotorcraft, the PIC will have accumulated and logged, ina manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotal time as a sUAS rotorcraftpilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• Inthe case offixed wing aircraft, the PIC will have accumulated and logged, ina manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotal time as a sUAS fixed wing pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• The PIC will have accumulated and logged a minimum offive hours as a sUAS pilot with the make and model ofsUAS to be utilized for operations underthe exemption and three take-offs and landings in the preceding 90 days priorto an operation

• As noted belowin "Operating Parameters; Conditions andLimitations", the operator will not allow a PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the sUAS in a manner consistent with howthe sUAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Visual observers musthave demonstrated that they understand the conditions and limitations of flight noted belowin "Operating Parameters; Conditions and Limitations". OperatingParameters; Conditions and Limitations. Grant ofthe exemptions will be subject to the following conditions, whichprovide at least an equivalent orhigher level ofsafety than under the current conditions. These conditions are drawn from Exemptions 11062 through 11067, 11080, 11109 and 11110. Forpurposes ofthis listing, InTechSys is referred to as the operator. 1. Operations will be limited to the aircraft described above. 2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted. 

### 3. The UA may notbe operated at a speed exceeding 87 knots (100 miles per hour). The operator mayuse either groundspeed or calibrated airspeed to determine compliance withthe 87 knot speed restriction. In no case will the UAbe operated at airspeeds greaterthan the maximum UA operating airspeed recommended bythe aircraft manufacturer. 4. The UAmustbe operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude mustbe reported infeet AGL. 5. The UA mustbe operatedwithinvisual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use humanvisionunaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate or U.S. driver's license. 41Page6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line ofsight (VLOS) ofthe PIC and VO at all times. The VO may be used to satisfytheVLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mustbe able to communicate verbally at all times; electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transferhis orher designation for the duration ofthe flight. The PIC must ensure that the VO can performthe duties required ofthe VO. 7. Upon grant, the exemption and all documents needed to operatethe UAS and conduct its operations in accordance withthe conditions and limitations stated inthe grant of exemption, will be, and are hereinafterreferred to as the operating documents. The operating documents mustbe accessible during UAS operations andmade available to the Administrator uponrequest. Ifa discrepancy exists betweenthe conditions and limitations ina grant of exemption and the procedures outlined inthe operating documents, the conditions and limitations inthe granttake precedence and mustbe followed. Otherwise, the operatormust follow the procedures as outlined inits operating documents. The operator mayupdate orrevise its operating documents. Itis the operator'sresponsibilityto track suchrevisions andpresent updated andrevised documents to the Administrator oranylawenforcement official upon request. The operator must also presentupdated and revised documents if

### itpetitions for extension or amendmentto this grant ofexemption. Ifthe operator determines that anyupdate orrevision would affect the basis upon which the FAA granted this exemption, then the operator mustpetition for an amendmentto its grant ofexemption. 8. AnyUAS thathas undergone maintenance oralterations that affect the UAS operation orflight characteristics, e.g., replacement ofa flight critical component, must undergo a functional test flight priorto conducting further operations underthis exemption. Functional test flights may onlybe conducted by a PIC with aVO and mustremain at least 500 feet from other people. The functional test flight mustbe conducted in such a manner so as to notpose anundue hazard to persons and property. 

### 9. The operator is responsible for maintaining and inspecting the UAS to ensure that itis in a condition for safe operation. 10. Priorto each flight, the PIC must conduct apre-flight inspection and determine the UAS is in a conditionfor safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, orequipment. Ifthe inspectionreveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. 11. The operatormust follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirements for the aircraft and aircraft components. 

### 12. EachUAS operatedunderthis exemptionmust complywith all manufacturer safetybulletins. 

### 13. A PIC musthold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. 

## 51 Page

### driver's license issued by a state, the District ofColumbia, Puerto Rico, aterritory, apossession, orthe Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 

### 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. 14. The operatormay not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in amanner consistent with how the UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 

### 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's ability to safely operate the UAS in amanner consistentwith how the UAS will be operated underthis exemption are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 

### 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. 

### All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 

### statute miles from the PIC. 18. If

### the UAS 

### loses communications or loses its GPS 

### signal, the UA

### must return to apredetermined location within the private or controlled-access property. 19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer ifgreater. 21. All operations shall be conducted in accordance with an Air Traffic Organization Certificate ofWaiver or Authorization. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings must be as large as practicable. 61Page23. Documents used bythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 

### §§ 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents mustbe made available to the Administrator or any lawenforcement official uponrequest. 24. The UA mustremain clear and give wayto all manned aviation operations and activities at all times. 25. The UAS may notbe operated bythe PIC from any moving device orvehicle. 26. All Flight operations mustbe conducted atleast 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientlyprotect nonparticipating persons from the UA and/or debris in the event ofan accident. The operatormust ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety ofnonparticipating persons; and b. The owner/controller ofany vessels, vehicles or structures has grantedpermissionfor operating closerto those objects and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that itdoes not present an undue hazard. The PIC, VO, operatortrainees oressential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted overprivate or controlled-access property with permission from the property owner/controller orauthorized representative. Permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COAmustbe reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. 

### The Public Interest. The public interest in granting this exemptionrequest is served by, among others, the following:

• Congress has established a national policythat favors early integration ofsUAS into the NAS -pending completion ofthe statutorily required rulemaking for such integration, exemptionrequests such as this oneby InTechSys (and many others) are integral in developing and in movingthis policy along

• The use ofsUAS improves public safety and reduces riskbyalleviating the public's exposure to danger and emissions associated withtraditional aerial methods (full size aircraft) that carry passengers and flammable fuel 

### 71Page• Allowing the commercialization oftheNASby sUAS will provide additionaljob and career opportunities for ournation'spopulation

• Resulting ecological and environmental benefits such as precision inspections and assessments offuel-laden pipelines, rights-of-way, energyproductionplatforms, along with coastal marine environment observations for conservationpurposes

• Harnessing the power ofnewtechnologies and providing challenges to ournation's entrepreneurs and developers

• InTechSys' pilot and visual observertraining (as noted in operatingparameter#15 above) will enhancethe safety ofsUAS flight and will serve to minimize the riskto the NAS and to persons andproperty onthe ground Summary for publication. Forpublicationinthe FederalRegister InTechSys provides the following summary. An exemption is requested from the following regulations in orderto allow commercial operations ofits unmanned aircraft systems involving aerial applications such as photography, inspections, surveying, and demonstrations.

14 CFR §61.113 (a) and (b) 14 CFR §61.133 (a) 14 CFR §91.7 (a) 14 CFR 

### § 91.119 (c) 14 CFR 

### § 91.121 14 CFR §91.151 (a) 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)

Conclusion. Giventhe small size ofthe sUASs involved and the restricted environment within which they will operate, this petition falls squarely within that equivalent level ofsafetyinwhich Congress envisioned thatthe FAAmust, by exemption, allow commercial operations ofsUASs to commence immediately. Too, given the clear direction in Section 333 oftheReform Act, the authority contained inthe Federal Aviation Act, the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit ofthe various applications, including enhanced safety, reduction in environmental impacts by fuel laden vehicles, including reduced emissions, the public value ofthe unmanned aerial vehicle industry, the grant oftherequested exemption is in the public interest. InTechSys seeks anexemption from the listed and discussed FARsto operate commerciallythe small unmanned aircraft systems inthe aerial operations setforth herein.



### SIP 

### age

### Thankyou. 

### C::

....

# ~· ely,

-- 

## (

# ~---**~** _,--' Wayne A. Johnson, Attorney 

### Counsel for InTechSys, LLC

91Page

## APPENDIX A 14 CFR §61.113(a) and (b); 61.133(a): Private Pilot Privileges and Limitations: Pilotin Command; Commercial PilotPrivileges and Limitations Sections 61.113(a) and (b) limitprivatepilots to non-commercial operations. Section 61.133(a) requires an individual with a commercial pilot's license to be pilotin command ofan aircraft for compensation orhire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the sUAS proposed for use by lnTechSys are remotely controlled with no passengers orcargo on board. InTechSys respectfully requests exemptions from these requirements based onthe particular characteristics ofthe sUAS that will be used. The risks associated with the operation ofthe sUAS described above (giventhe size, speed, operational capabilities and lack ofcombustible fuel) are much lowerthan the risks associated with commercial operations contemplated byPart 61 with conventional aircraft. Accordingly, a recreational or sportpilot, adequately trained inthe properuse ofsUAS, possesses the requisite skills and knowledge oftheNAS and FAA regulations to assure the safe operation ofthe sUAS. In addition, InTechSys will use the identified sUAS with a high degree ofcontrol and various built-intechnical capabilities that strictly limitthe potential for operation outside ofthe operating conditions set forth inthis Petition. InTechSys emphasizes sUAS training and flight experience for those PICs who will operate these aircraft inthe proposed commercial applications. Byrequiring extensive flight experience withthese aircraft priorto conducting commercial operations, these PICs will have a better grasp ofthe handling ofthe aircraft than they would byholding a commercial pilotlicense for an entirely differenttype ofairborne system. Giventhe inherently lower-risk nature ofthe sUAS and these training, experience and safety features, InTechSys proposes that operators should notbe required to hold a commercial pilot certification. Instead operators should berequired to hold only a recreational or sportpilot certification and have the experience with the sUASs as indicated inthis Petition. The risks associated withthe operation ofthe sUAS identified herein (given their size, weight, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level of risk associated with commercial operations contemplatedbyPart 61 with conventional aircraft (rotorcraft or fixed wing) that allowing operations ofthe sUAS as set forth above meets or exceeds the present level ofsafety providedunder 14 CFR 

### § 61.113(a) and (b) and does notrise to the level ofrequiring a commercial pilotto operate under§ 61.133(a). Giventhese conditions and restrictions, an equivalent level ofsafety will beprovidedby allowing operation ofthe sUAS identified herein with a private pilot's certificate, underthe conditions set forth inthis Petition. The FAA has granted exemptionto conduct similar operations in Exemptions 11062 through 11067, 11080, 11109 and 11110.

10 

## IPage14 CFR § 91.7(a): Civil Aircraft Airworthiness This regulation requires thatno person may operate a civil aircraft unless it is inairworthy condition. Should the exemptionbe granted allowing commercial operation ofthe named aircraft without an airworthiness certificate, no standard will exist for airworthiness ofthe aircraft. Giventhe size ofthe aircraft and the requirements that the operatorhas agreedto as relates to airworthiness, as setforth herein and inthe various operating documents, an equivalent level ofsafety will be achieved byensuring compliance withthe aircraft manuals and operating documents for each flight. The FAAhas granted exemptions to conduct similaroperations in Exemptions 11062 through 11067, 11080, 11109 and 11110. 14 CFR §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (c) prohibits operations below 500 feet above the surface, orcloserthan 500 feet to any person, vessel, vehicle or structure. As this exemptionrequests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. The equivalent level ofsafety will be achieved giventhe size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will betaken withoutthe permission ofthe property owner or local officials, where required. Because ofthe advance notice to the property owner andparticipants, all affected individuals will be aware ofthe planned flight operations as set forth inthe planof operations. lnTechSys LLC therefore requests a waiver from Section 91.119(c) for all participatingpersons, i.e., persons associated withthe operations. InTechSys LLC will also ensure that non-participating persons are kept at least 500 feet from the operating area, or seek approval from the Administrator for less separation ifan equivalent level ofsafety canbe achieved. Compared to flight operations with aircraft orrotorcraft weighting far more than the maximum ofunder 55 pounds proposedherein and the lack offlammable fuel, any risk associated with these operations is far less thanthose risks associated withthe conventional methods. In addition, the low-altitude operations ofthe sUAS will ensure separation between these sUAS operations andthe operations ofany conventional aircraftthat mustcomplywith Section 91.119. 14 CFR §91.121: Altimeter Settings This regulation requires eachperson operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

... to the elevation ofthe departure airport oran appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemptionmaybe needed. Anequivalent level ofsafety will be achieved bythe operator confirming the acquisition ofGPS signals and an initial ground level altitude ofzero priorto take-off. The FAA has granted exemptions to conduct similar operations inExemptions 11062 through 11067 and 11080. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight inan airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enoughfuel to fly to the first point ofintended landing, and, assumingnormal cruising speed

- (1) Duringthe day, to fly afterthat for at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes." lljPageThe battery powering the named sUAS rotorcrafts provides approximately 25 minutes or less of powered flight inthe case ofthe rotorcrafts and 40minutes inthe case ofthe 3DRfixed wing craft. To meetthe 30minute reserve requirement in 14 CFR §91.151, sUAS flights would not be able to effectively fly. InTechSys LLC believes that an exemption from 14 CFR §91.151(a) is safe and falls withinthe scope ofprior exemptions. Operating the sUAS in a controlled area with a limitation onthe flight uponreaching 20% of batterypowerdoes notengenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe sUAS. InTechSys LLC believes that an equivalent level ofsafety can be achieved inthis manner. This restrictionwould be more than adequate to returnthe sUAS to its planned landingzone from anywhere inits limited operating area. Similarexemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR §91.405 (a); 407 (a) (1); 409 (a) (1) and (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter

...,"andothers shall inspect ormaintain the aircraft in compliance with Part43. Given that these sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to InTechSys LLC. Maintenance will be accomplished byInTechSys LLC pursuantto InTechSys LLC' operations manuals andpractices along withmanufacturer specifications. An equivalent level ofsafety will be achieved because these small UASs are very limited in size (less than 55 pounds), will carry a small payload and operate onlyinrestricted areas for limited periods oftime with no flammable fuel. Ifmechanical issues arise the sUAS can land immediately and will be operating from no higher than400 feet AGL. Asprovidedherein InTechSys will ensure that the sUAS is in working orderpriorto initiating flight, perform a preflight safety checklist, performrequired maintenance, andkeep a log ofany maintenance performed. Moreover, InTechSys is most familiar with the aircraft and best suited to maintainthe aircraft inan airworthy condition to provide the equivalent level ofsafety.



### 121 Page

## APPENDIX 8 Operating Documents

DJI aircraft

• Phantom 2 www.dji.com/product/phantom-2/download • Phantom 2 Vision+ www.dji.com/product/phantom-2-vision-plus/download • Phantom 3 Standard www.dji.com/product/phantom-3-standard/download • Phantom 3 Professional www.dji.com/product/phantom-3/download • Phantom 3 Advanced www.dji.com/product/phantom-3/download • Inspire 1 www.dji.com/product/inspire-1/download • S800 EVO www.dji.com/product/spreading-wings-5800-evo/download • S900 www.dji.com/product/spreading-wings-5900/download • S 1000 www.dji.com/product/spreading-wings-SlOOO/download • S 1000+ www.dji.com/product/spreading-wings-1000+/download 30 Robotics aircraft

• X8+ www.3drobotics.com/kb/X8+/ • 3DR Aero fixed wing www.3drobotics.com/kb/aero/ • Solo www.3drobotics.com/kb/solo/ Yuneec Electric Aviation

• Typhoon QSOO www.yuneec.com/support/ • Typhoon QSOO + www.yuneec.com/support/ • Typhoon QSOO 4K www.yuneec.com/support/



### 131 Page

## APPENDIXC 

## lnTechSys LLC Standard Operating Procedures For Small Unmanned Aircraft Systems (sUAS) The flight team. The flight team will consists of a pilot in command (PIC), a visual observer (VO), and such other members as may be designated for any particular mission. The PICwill:

• hold either a current FAA recreational or sport pilot certification or higher FAA pilot certification

• hold a valid driver's license

• ,in the case of rotorcraft, have accumulated and logged a minimum of25 hours oftotal time as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• ,in the case offixed wing aircraft, have accumulated and logged a minimum of25 hours oftotal time as a sUAS fixed wing aircraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• have accumulated and logged a minimum offive hours as a sUAS pilot with the make and model of UAS to be utilized for operations underthe exemption and three take-offs and landings in the preceding 90 days priorto an operation

• the operator will not allow a PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the sUAS in a manner consistent with howthe sUAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures The PIC and the VO must have demonstrated that they understand the conditions and limitations offlight noted below in I(Operating Parameters; Conditions and Limitations". Operating Parameters; Conditions and Limitations. The following matters apply to all sUAS being operated by Gulfof Mexico Foundation (referred to below as the operator): 1. The sUAS must weigh less than 55 pounds, including energy source(s) and equipment.

sUAS Standard Operating Procedures, page 1 of 52. The sUAS may not be flown at an indicated ground speed exceeding 50 knots. 3. Flights must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitudes reported to AirTraffic Control must be in feet AGL. 4. The sUAS must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the VO and PIC always maintain VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or her designation during the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 6. The operating documents and any grant ofexemption must be made available to the Administrator upon request. The operator may update or revise its operations manual. It is the operator's responsibility to track such revisions and present updated and revised documents tothe Administrator upon request. Ifthere is a discrepancy between the exemption conditions and limitations and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted an exemption the operator must petition the FAA for amendment to the exemption. 7. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe sUAS, the aircraft will be prohibited from operating until the necessary r,naintenance has been performed and the sUAS is found to be in a condition for safe flight. The ground control station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation orflight characteristics, e.g. replacement of aflight critical component, must undergo afunctional test flight. The PIC who conducts the functional test flight must make an entry in the sUAS aircraft records ofthe flight. 9. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items or equipment not already covered in the relevant sections ofthe operating documents.

sUAS Standard Operating Procedures, page 2 of 510. The operator must follow the sUAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 11. The operator must carry out its maintenance, inspections, and record keeping requirements in accordance with the operating documents. Maintenance, inspection, alterations and status of replacement/overhaul component parts must be noted in the aircraft records, includingtotal time in service, description ofwork done, discrepancies between inspections, and the identification ofthe authorized person returning the sUAS to service. 12. Each sUAS operated under this exemption must comply with all manufacturer safety bulletins. 13. The PIC must hold either a current FAA recreational or sport pilot certification or higher FAA pilot certification and hold avalid driver's license. 14. The PIC must also meetthe flight review requirements specified in 14 CFR 61.56 as the sUAS. 15. The operator may not permit any PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the sUAS in a manner consistent with howthe sUAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 16. Maximum flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 20%. 17. The operator will file a request for a Notice to Airmen (NOT AM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. 18. The radio frequency spectrum used for operation ofthe sUAS must comply with the FCC or other appropriate governmental oversight agency requirements. 19. All flights must be conducted over property that is private or controlled access property with permission from the land owner/controller or authorized representative. Permission will be obtained for each flight. 20. Ifthe sUAS loses communications or loses the GPS signal, the sUAS must return to a pre-determined location ortake-off point or be recovered in accordance with the operator's manual.

sUAS Standard Operating Procedures, page 3 of 521. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 22. The operator must obtain an Air Traffic Organization {ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations under any grant of exemption. 23. All aircraft operated in accordance with an exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (Nnumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as possible. 24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the ground control station ofthe sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 25. The sUAS must remain clear and yield the right ofwayto manned aviation operations and activities at all times. 26. sUAS operations may not be conducted during night, as defined in 14 C.F.R § 1.1. All operations must be conducted undervisual meteorological conditions. Flights under special visual flight rules are not authorized. 27. The sUAS may not be operated by the PIC from any moving device orvehicle. 28. The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally.from a cloud orwhen visibility is less than 3 statute miles from the PIC. 29. The sUAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letterof agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required bythe operator's COA. The letterof agreement with the airport management must be made available tothe Administrator upon request. 30. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, VO, operator trainees or essential persons) vessels, vehicles and structures, unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event ofan accident. The operator must

sUAS Standard Operating Procedures, page 4 of 5ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe sUAS, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 31. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov.

sUAS Standard Operating Procedures, page 5 of 5

## APPENDIX 0 lnTechSys LLC Pre-flight Checklist For Small Unmanned Aerial Systems (sUAS)



# 0 FlightAuthority. Obtain proper authority to fly in the airspace ofthe intended flight. 

## 0 Documentation. Copies ofall required documentation are available. 

## 0 Eye Protection. Wear safety glasses or other suitable eye protection. 

## 0 Environment. Evaluate the current weather conditions (temperature, wind speed, humidity). Determine that they are within the capability ofthe sUAS and the flight team. 

## 0 Site Assessment. Perform a site assessment to identify any hazards like power lines, trees, cell towers, structures, and hills which could affect GPS reception. Ifequipped, check for Radio Frequency Interference (RFI). 

## 0 Calibration. If (i) your location has changed more than 200 miles since your last flight, (ii) you are using your sUAS forthe first time out ofthe box, (iii) you are using your sUAS for the first time since material maintenance has been performed on your sUAS, or (iv) you are using your sUAS for the first time following a hard landing or drop, calibrate the compass. Refer to manufacturers' instruction manual for details. Poweroff once calibration is completed. 

## 0 Inspection ofsUAS. Inspect the sUAS from top to bottom to make sure the frame/canopy is free of cracks or damage. Check that the payload (FPV gearNideo Downlink) is properly secured, all frame screws are present and secured and landing gear is not cracked or damaged. 

## 0 Motors. With the sUAS not powered rotate each propeller slowly by hand for at least one complete revolution. The feel should be slightly bumpy; although it is bumpy it should be consistently bumpy. If a magnet is missing or damaged it may feel resistive in that spot or move more freely. All motors should have the same feel of rotational resistance. Ifthere is an issue with a motor DO NOT FLY!

sUAS Pre-flight Checklist, page 1 of 2

## 0 Propellers. Inspect all propellers making sure they are installed correctly on the CW or CCW motors. See instruction manual for details. Check propellers for damage on each blade and atthe hub. Replace any that are cracked orworn. 

## 0 Battery. Ensure that the sUAS flight battery is fully charged and properly installed in the sUAS. 

## 0 Command and Control. Ensure that the transmitter is fully charged and powered on. If using ground station (GS) ensure that the system is fully charged and powered. Ensure thatthe flight programs are running and functioning correctly. Ifapplicable open preprogramed flight plan and ensure all waypoints are set to desired parameters. Disable screen savers. 

## 0 CameraNideo Recording System. Ensure video downlink monitoring system is fully charged and powered. Remove lens caps, power on sUAS on board camera, ensure video downlink is transmitting to GS monitor. Start recording sUAS camera for flight. LAST .........POWER ONsUAS andhave a safe flight. 

### In the event ofa hardlanding orcrash you shouldperform a preflightcalibration and inspection again.

sUAS Pre-flight Checklist, page 2 of 2

### APPENDIX E 

## lnTechSys LLC Post-flight Checklist For Small Unmanned Aircraft Systems (sUAS) 

## 0 Stop recording/power off camera 

## 0 Power OFF sUAS FIRST 

## 0 Power OFF transmitter SECOND 

# 0 Power OFF ground station 

# 0 Document flight in logbook