# Petition for Exemption / Rulemaking to the FAA

Commercial visual line

- of

- sight s UAS Operations

Prepared by Robert R. Murrell

CIO Aerialspecs, Inc.
48675 Jefferson Drive Macomb, MI 48044

+1 (248) 845

- 8365 info@aerialspecs.comPetition for Exemption/Rulemaking to the FAA

Commercial visual line

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- sight s UAS operations



# T ABLE OF 

# C ONTENTS

Summary

................................ ................................ ................................ ................................ .............................. 1

Exemption

................................ ................................ ................................ ................................ ............................. 1

Scope

................................ ................................ ................................ ................................ ............................... 1
Specific Exemptions

................................ ................................ ................................ ................................ ......... 1
14 CFR Part 61: Certification: Pilots, Flight Instructors, and Ground Instructors

................................ .......... 1

14 CFR §61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

................................ ... 1
14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

................................ ............. 2
14 CFR §45.23 (b): Marking of the Aircraft

................................ ................................ ................................ .. 2
14 CFR §91.7(a): Civil aircraft airworthiness

................................ ................................ ................................ 2

14 C FR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

................................ ................................ ... 2
14 CFR §91.103(b)(2): Preflight action

................................ ................................ ................................ ........ 3
14 CFR §91.105: Flight C rewmembers at Stations

................................ ................................ ....................... 3
14 CFR §91.109: Flight instruction

................................ ................................ ................................ .............. 3

14 CFR §91.119: Minimum safe altitudes

................................ ................................ ................................ .... 4
14 CFR §91.121: Altimeter Settings

................................ ................................ ................................ ............. 4
14 CFR §91.151: Fuel requirements for flight in VFR conditions

................................ ................................ .. 4
14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

................................ ............ 5
14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

................................ .... 5
Public Safety

................................ ................................ ................................ ................................ ......................... 6
Safety of our Employees

................................ ................................ ................................ ................................ .. 7
Safety of our Customers

................................ ................................ ................................ ................................ ... 7
Operational Roles

................................ ................................ ................................ ................................ ................. 7
Chief Equipment Operator

................................ ................................ ................................ ............................... 7
Equipment Operator

................................ ................................ ................................ ................................ ........ 8

Spotter

................................ ................................ ................................ ................................ ............................. 8
Flight Operations Certification

................................ ................................ ................................ .............................. 8
Flight Certification

................................ ................................ ................................ ................................ ........... 8
Equipment Operator and Spotter Flight Time Requirements

................................ ................................ ...... 9
Chief Equipment Operator Flight Time Requirements

................................ ................................ ............... 10
TSA Equivalent Background Check

................................ ................................ ................................ ............ 10

Medical Examination

................................ ................................ ................................ ................................ 10

Basic First Aid Certification

................................ ................................ ................................ ....................... 10Petition for Exemption/Rulemaking to the FAA

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Operating Standards

................................ ................................ ................................ ................................ ........... 10
Fly

- off Procedures

................................ ................................ ................................ ................................ .......... 12
Flight Standards District Offic es Notification

................................ ................................ ................................ .. 13
Equipment Specification

................................ ................................ ................................ ................................ 13
Maintenance and Repair

................................ ................................ ................................ ................................ 14
Specific Use Cases

................................ ................................ ................................ ................................ ............... 15
Wind Turbine Construction and Inspection

................................ ................................ ................................ .... 15
Operational Area

................................ ................................ ................................ ................................ ...... 15
Additional Safety Measures

................................ ................................ ................................ ...................... 17
Payload

................................ ................................ ................................ ................................ ..................... 17
Electric Generation, Transmission, Sub Transmission, and Distribu tion Facilities Inspection

.......................... 18
Operational Area

................................ ................................ ................................ ................................ ...... 18
Additional Safety Measures

................................ ................................ ................................ ...................... 19
Payload

................................ ................................ ................................ ................................ ..................... 20
Building, Bridge, Structure or Span Inspection

................................ ................................ ............................... 20
Operational Area

................................ ................................ ................................ ................................ ...... 20
Additional Safety Measures

................................ ................................ ................................ ...................... 22
Payload

................................ ................................ ................................ ................................ ..................... 22
Agriculture Inspection

................................ ................................ ................................ ................................ .... 22
Operational Area

................................ ................................ ................................ ................................ ...... 23
Additional Safety Measures

................................ ................................ ................................ ...................... 23
Payload

................................ ................................ ................................ ................................ ..................... 23
Industrial / Mining Environmental Inspection

................................ ................................ ................................ 23
Operational Area

................................ ................................ ................................ ................................ ...... 23
Additional Safety Measures

................................ ................................ ................................ ...................... 24
Payload

................................ ................................ ................................ ................................ ..................... 24
Municipal Police, Fire, and Search and Rescue

................................ ................................ ............................... 25
Operational Area

................................ ................................ ................................ ................................ ...... 25
Additional Safety Measures

................................ ................................ ................................ ...................... 26
Payload

................................ ................................ ................................ ................................ ..................... 27
Appendix

................................ ................................ ................................ ................................ ............................. 28
A. General Flight Process

................................ ................................ ................................ ............................... 28
B. Fly

- off Process

................................ ................................ ................................ ................................ ............ 29
Glossary of Terms

................................ ................................ ................................ ................................ ............... 30Petition for Exemption/Rulemaking to the FAA

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AGL

................................ ................................ ................................ ................................ ................................ 30

AIRMET

................................ ................................ ................................ ................................ .......................... 30

ATC

................................ ................................ ................................ ................................ ................................ 30

C2

................................ ................................ ................................ ................................ ................................ .. 30

EM

................................ ................................ ................................ ................................ ................................ . 30
Fly

- Off

................................ ................................ ................................ ................................ ............................ 30

FSDO

................................ ................................ ................................ ................................ .............................. 30

GPS

................................ ................................ ................................ ................................ ................................ 30

IMU

................................ ................................ ................................ ................................ ............................... 30

IR

................................ ................................ ................................ ................................ ................................ ... 31

NIR

................................ ................................ ................................ ................................ ................................ . 31

NTSB

................................ ................................ ................................ ................................ .............................. 31

SFC

................................ ................................ ................................ ................................ ................................ . 31

SIGMET

................................ ................................ ................................ ................................ .......................... 31

sUAS

................................ ................................ ................................ ................................ .............................. 31

TFR

................................ ................................ ................................ ................................ ................................ 31

UAV

................................ ................................ ................................ ................................ ............................... 31

UV

................................ ................................ ................................ ................................ ................................ .. 31

VFR

................................ ................................ ................................ ................................ ................................ 31

References

................................ ................................ ................................ ................................ .......................... 32Petition for Exemption/Rulemaking to the FAA

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P a g e | 1 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved 

# S UMMARY

Pursuant to 14 CFR Part 11, the following summary is provided by Aerialspecs, Inc. for public ation in the Federal Register : Aerialspecs, Inc. is seeking exemption from the following regulations to operate small Unmanned Aerial Systems for the purpose s of remote visual line

- of

- sight videography, data collection, sensing, and visual inspection :

 14 CFR PART 61: Certification: Pilots, Flight Instructors, and Ground Instructors

 14 CFR §61.113 (a) & (b): Private pilot privil eges and limitations: Pilot in C ommand

 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

 14 CFR §45.23 (b). Marking of the Aircraft

 14 CFR §91.7(a): Civil Aircraft Airworthiness

 14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

 14 CFR §91.103 (b)(2) : Preflight Action

 14 CFR §91.105 : Flight Crewmembers at Stations

 14 CFR §91. 109: Flight Instruction

 14 CFR §91.119: Minimum safe altitudes

 14 CFR §91.121: Altimeter Settings

 14 CFR §91.151: Fuel requirements for flight in VFR conditions

 14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

 14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections
It is the position of Aerialspecs, Inc. that a new license class be created for the commercial visual line

- of

- sight of sUAS. Many industries needlessly place the lives of employees in ha rm’s way every day to keep the general public safe and deliver products to their customers. Requiring reasonable everyday workers in hazardous jobs to obtain a Pilot’s license is too costly and time consuming. The rigor and cost associated to achieving a p rivate p ilots certificate is typically $10,000 USD and 50

- 60 hours of an individual’s time . This far exceeds the training necessary to achieve a CDL with a Hazmat endorsement required to transport dangerous cargo over land.
Aerialspecs, Inc. believes it has created training, certifications, operational standards, and equipment specifications that represent reasonable guidelines for operation of sUAS comparable to risk sUAS poses and similar to CDL, forklift, or other hazardous equipment employees are en tr usted to operate every day. Aerialspecs, Inc. is willing to partner with the FAA to create a new license class leveraging this exemption as its springboard. Until then we believe or training and certification standard s , the type of equipment

, operating standards
, fly

- off procedures , and clear are as of operation defined herein exceed the standard s set forth in FAA Advisory Circular AC 91

- 57 for hobby operations and provide an equivalent level of safety supporting the grant of the exceptions requested herein. This satisfies the criteria provided in Section 333 of the Reform Act of 2012 providing ad equate justification for these exceptions allowing for commercial operations of s UAS within visual line

- of

- sight by Aerialspecs, Inc.
Aerialspecs, Inc. is committed to the safety of the everyday worker and believes that through our services and this exempt ion we can provide safe, quality operations of sUAS to reduce the risk to employees, improve our customers OSHA ratings, and protect the public.

Douglas Sigler CE O and Owner

- Aerialspecs, Inc.

+1 (586) 745

- 4503 info @aerialspecs.com Robert R

. Murrell C IO and Owner

- Aerialspecs, Inc.

+1 (248) 845

- 8365
info @aerialspecs.comPetition for Exemption/Rulemaking to the FAA

Commercial visual line

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- sight s UAS op erations

P a g e | 1 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved 

# E XEMPTION



## S COPE The scope of this exemption includes Aerialspecs, Inc. employees, affiliates, partners, vendors, or any other person or entity operating in a flight capacity on behalf of Aerialspecs, Inc. for the purpose of
commercial visual line

- of

- si ght sUAS operations leveraging both manual command and control, and auto piloted flight.



## S PECIFIC 

## E XEMPTIONS



### 14 CFR P ART 

### 61 : C ERTIFICATIO N 

### : P ILOTS 

### , F LIGHT 

### I NSTRUCTORS 

### , A ND 

### G ROUND 

### I NSTRUCT ORS The regulations set forth in 14 CFR Part 61 require a pilot certificate and medical certificate for anyone operating as a required pilot of a civil aircraft.

Aerialspecs, Inc. is seeking exemption from 14 CFR Part 61 on the grounds that the FAA does no t require a pilot certificate for recreational use of aerial vehicles with the same configurations hereunder today as defined by FAA Advisory Circular AC 91

- 57, Model Aircraft Operating Standards 1

. Also, the operation of sUAS is far simpler than large scal e aircraft, especially with modern flight control and stabilization systems, requiring less training and experience to be safe and effective. Finally, there is no evidence to support the rigor of a pilot certificate, or lack thereof, makes the operations o f sUAS more or less safe.

Aerialspecs, Inc. exceeds the voluntary standards defined in FAA Advisory Circular AC 91

- 57 as well as
maintain s the equivalent level of safety intended by 14 CFR Part 61 by strictly following the Flight Operations Certification a nd General Operational Guidelines herein. Equipment Operators will have a minimum number of total flight hours overall, minimum number of total flight hours per s UAS type, minimum number of flight hours per year, knowledge of airspace and restrictions, av iation background checks, medical certification, and basic first aid training.



### 14 CFR § 61.113 ( A 

### ) & ( B 

### ) : P RIVATE PILOT PRIVILE GES AND LIMITATIONS 

### : P ILOT IN COMMAND These regulations limit private pilots to non

- commercial operations only. Although Aerialspe cs, Inc. is seeking exemption from certificates, ratings, and authorizations, it may still leverage licensed pilots to
operate a s UAS . To not violate the regulations set forth in 14 CFR §61.113 (a) & (b), an exemption is required.

Aerialspecs, Inc. is seek ing exemption from 14 CFR §61.113 (a) & (b) on the grounds that the level of risk associated with the operation of a sUAS compared to commercial operations of a piloted aircraft when Part 61 was conceived is so negligible that having a private pilot as the Pilot In Command exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

Aerialspecs, Inc. will maintain an equivalent level of safety by operating a sUAS hereunder in specific operational areas away from the general public that will not carry passengers or crew, not exceed an operational weight of 24.9476 kg (55 lbs.) including payload , and not exceed ground speeds of 25 m/s (56 mph).Petition for Exem ption/Rulemaking to the FAA

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P a g e | 2 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved 

### 14 CFR P ART 

### 21, S UBPART 

### H: A IRWORTHINESS 

### C ERTIFICATES 

### 14 CFR §91.203 ( A 

### ) (1) This regulation requires that aircraft have a current certificate of airworthiness . It also requires that the airworthiness certificate be displayed in the cabin or cockpit entrance so that it is legible to passengers and crew

. Aerialspecs, Inc. is seeking exemption from 14 CFR Pa rt 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) on the grounds that a sUAS operated hereunder does not carry passengers or crew, will not weigh more than 24.9476 kg (55 lbs.) including payload , and will not exceed ground speeds of speed s of 25 m/s (56 mph). A sUAS hereunder will fly under strict guidelines in narrow operational areas. This combined with the safety measures herein provide a greater degree of safety to the public than conventional operations conducted with airworthiness ce rtificates issued under 14 CFR Part 21, Subpart
H. See Public Safety and General Operational Guidelines for more information

. The Federal Aviation Act (49 USC §44701 (f)) and Sec tion 333 of the Reform Act both authorize the FAA 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 particul ar sUAS

.


### 14 CFR § 45.23 ( B 

### ): M ARKING OF THE 

### A IRCRAFT This 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 provisi onally certificated aircraft, the Equipment Operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words ‘limited,’ ‘restricted,’’ ’ light

- sp ort,’ ‘experimental,’ or ‘provisional,’ as applicable.”
Aerialspecs, Inc. is seeking exemption from 14 CFR § 45.23 (b) on the grounds that sUAS operated hereunder do not have a cabin, cockpit or pilot station. Their size makes it impossible to fit the word “Experimental” in letting no smaller than 2 inches high. To maintain compliance with §45.29 (f), Aerialspecs, Inc. will require the word “Experimental” on sUAS fuselages so that the operator, spotter, or supporting personnel working with the vehicle will see the identification.

Precedence has been set by the following exemptions issued by the FAA 2 : Exemptions Nos . 10700 , 10167
, and 10167A.



### 14 CFR §91.7( A 

### ): C IVIL AIRCRAFT AIRWOR THINESS This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

Aerialspecs, Inc. is seeking exemption from 14 CF R § 91.7(a ) on the grounds that there will be no
airworthiness certif icate issued for the aircraft. S hould this exemption be granted, no FAA regu latory standard will exist for determining airworthiness for such vehicles

. Given the size of the aircraft, the requirements contained in the equipment maintenance manuals
, and use of safety ch eck lists prior to each flight

, an equivalent level of safety will be provided.



### 14 CFR § 91.9 ( B 

### ) (2): C IVIL 

### A IRCRAFT 

### F LIGHT 

### M ANUAL IN THE 

### A IRCRAFT This regulation requires that an approved Flight Manual, manual materials, markings, and place cards, or any combination thereof be placed in the aircraft and available to the pilot.Petition for Exem ption/Rulemaking to the FAA

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P a g e | 3 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved Aerialspecs, Inc. is seeking exemption from 14 CFR §91.9 (b) (2) on the grounds that the s UAS operated hereunder have no cockpit and are not large enough to carry a Pilot or the Flight Manual.

The equivalent level of safety will be maintained b y keeping the flight manual at the ground control point where the Equipment Operator controlling the sUAS or the Observer will have immediate access to it.

Precedence has been set by the following exemptions issued by the FAA 3 : E xemption Nos. 8607, 8737, 8738, 9299, 9299A, 956 5, 9565B, 10167, 10167A, 10602 , and 10700.



### 14 CFR § 91.103 ( B 

### )(2) : P REFLIGHT ACTION This regulation requires the pilot in command to take certain action before a flight, specifically:

“ (b) For any flight, runw ay lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport e levation and runway slope, aircraft gross weight, and wind and temperature. ”
Aerialspecs, Inc. is seeking exemption from 14 CFR § 91.103 on the grounds that there is no FAA approved
Roto r craft Flight Manual for the UAV. The Equipment Operator will follow a preflight check list provided by
the UAV manufacturer as well as validating UAV performance, battery requirement for the specific flight, landing and takeoff distances, area of operations, and weather conditions appropriate for VFR. See
General Operati onal Guidelines for more information.



### 14 CFR §91.105 : F LIGHT 

### C REWMEMBERS AT 

### S TATIONS This regulation requires that crewmember be at flight stations, presumably in the aircraft, wearing safety belts or harnesses during takeoff, landing, and while en route.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.105 on the grounds that sUAS operated hereunder have no cockpit and are not large enough to carry a Pilot

. Aerialspecs, Inc. will provide the equivalent level
of s afety by requiring an Equipment Operator and Spotter for each sUAS in operation and require a securing strap between the C2 remote and the Equipment Operator.



### 14 CFR §91.109: F LIGHT INSTRUCTION This regulation requires any civil aircraft (except a manned f ree balloon) to have dual flight controls when used for flight instruction.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.109 on the grounds that sUAS are remotely
controlled within line

- of

- sight and by design do not have dual controls. Flight con trol is accomplished through a m icrocontroller accepting human and/or software input that communicates flight commands
via radio to the UAV. Aerialspecs, Inc. will provide the equivalent level of safety by the fact that neither Equipment Operator nor instr uctor will be onboard the UAV. It will also follow the General Operational
Guidelines defined herein where the sUAS will be operated is specific, predefined areas, and the flight instruction behaving in the role of Chief Equipment Operator, will be present during instruction and have
access to the controller.Petition for Exem ption/Rulemaking to the FAA

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P a g e | 4 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved Precedence has been set by the following exemptions issued by the FAA 4 : Exemption Nos. 5778K &
9862A

.


### 14 CFR §91.119: M INIMUM SAFE ALTITUDES This regulation specifies the minimum altitudes of operation under various conditions including restricting operations below 152.4 m (500 Ft. AGL) over non

- congested areas.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.119 under special circumstances on the grounds
that many of the specific use cases defined herein have structures below 152.095 m (499 ft.) AGL and to gather relevan t information on said structure the UAV must operate well below specified minimums.

Aerialspecs, Inc. will p rovide the equivalent level of safety by flying in specific areas of operation away from the general public . The equipment will not carry any hazardous or explosive cargo, travel no more
than 25 m/s (56 mph) , and not exceed 24.9476 kg (55 lbs.) in operatio nal weight including payload

. The Equipment Operator and Spotter will also be equipped with aviation radios to communicate with nearby traffic. The details of the flight will be publicly publish on the Aerialspecs, Inc. corporate web site indicating the lo cation, two dimensional operational area, maximum altitude, start time, and expected
duration.



### 14 CFR § 91.121 : A LTIMETER 

### S ETTINGS This regulation requires each person operating an aircraft to maintain cruising altitude by refere nce to an altimeter that is set:

“ (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; “

Aerialspecs, Inc. is seeking exemption from 14 CFR § 91.121 on the grounds that s ome o f the aircraft used

re ly strictly on GPS for altitude and those aircraft that have an altimeter will auto calibrate ground level to the atmospheric pressure at time of startup.

Aerialspecs, Inc. will provide an equivalent level of safety by including in th e preflight checklist verification that GPS fix is sufficient to maintain altitude within a reasonable margin of error, that the GPS altitude is correct before flight, or in case of barometric altimeter based aircraft, that the altimeter reads 0 m (0 ft. ) AGL before flight.



### 14 CFR § 91.151 : F UEL REQUIREMENTS FOR FLIGHT IN 

### VFR CONDITIONS
This regulation require s :

“ (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraf t 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, to fly after that for at least 20
minutes. ”
Aerialspecs, Inc. is seekin g exemption from 14 CFR §91.151 on the grounds that sUAS operated hereunder generally have battery limits of approximately 20

- 60 minutes depending on atmospheric conditions,Petition for Exem ption/Rulemaking to the FAA

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P a g e | 5 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved make, model, and age of the battery. In some cases this would provide no reserve c apability, in others, leaving not enough flight time to gather the information required for the visual inspection of the wind
turbine.

Aerialspecs, Inc. will maintain an equivalent level of safety by flying in specific areas of operation away from the gene ral public. The equipment will not carry any hazardous or explosive cargo, travel no more
than 25 m/s (56 mph) , a nd not exceed 24.9476 kg (55 lbs.) in operational weight including payload . Flight operations will c ease when battery levels reach 1 5% of their startup capacity. This restriction will provide ample battery life for the UAV to return to its designated landing area.

Precedence has been set by the following exemptions issued by the FAA 5 : Exemptions Nos. 10673
, 2689F,
5745 , 10673, and 10808

.


### 14 CFR § 91.203 ( A 

### ) & ( B 

### ) : C ARRYING 

### C IVIL 

### A IRCRAFT 

### C ERTIFICATION AND 

### R EGISTRATION This regulation requires in 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 certificate 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.”
Aerialspecs, Inc. is seeking exemption from 14 CFR §91.203 (a) & (b) on the grounds that the s UAS at full operations weight will be less than 24.9476 kg (55 lbs.) including payload , has no c ockpit, and has no room to carry a pilot onboard.

Aerialspecs, Inc. will maintain an equivalent level of safety by keeping these documents at the ground control point where the pilot flying the s UAS will have immediate access to them; to the extent they ar e applicable to the s UAS.

Precedence has been set by the following exemptions issued by the FAA 6 : Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.



### 1 4 CFR §91.405 ( A 

### ); 407 ( A 

### ) (1); 409 ( A 

### ) (2); 417( A 

### ) & ( B 

### ): M AINTENANCE 

### I NSPECTIONS These regulations require that each owner or operator:

“Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;”
Aerialspecs, Inc. is seeking exemption from 14 CFR §91.405 (a), 407 (a) (1), 409 (a) (2), and 417(a) and (b) on the grounds that these regulations and the regulations set forth in Part 43 ar e intended for aircraft
with airworthiness certificates and a s UAS hereunder will not be issued an airworthiness certificate.

Aerialspecs, Inc. will maintain an equivalent level of safety by operating a s UAS hereunder in specific operational areas away fro m the general public that will not carry passengers or crew, not exceed an operational weight of 24.9476 kg (55 lbs.) including payload , and not exceed ground speeds of 25 m/s (56 mph)

. Should a mechanical issue arise the s UAS can immediately land within t he operational area.Petition for Exem ption/Rulemaking to the FAA

Commercial visual line

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- sight s UAS operations

P a g e | 6 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved Aerialspecs, Inc. will also perform routine and scheduled inspection s of all s UAS and follow the maintenance recommendations of the equipment manufacturer. A log of all maintenance and repair will be kept for each s UAS to ensure the hi ghest operational performance.

Per the Operational Procedures herein, all flights will perform a pre

- flight and post

- flight checklists which will include visual inspection of the equipment to identify anomalies bef ore they become an issue. See Maintenance and Repair for more information on the maintenance and repair of sUAS by Aerialspecs, Inc.



# P UBLIC 

# S AFETY

Aerialspecs, Inc. will follow these specific safety measures t o en sure the safety of our employees and the general public:

 A sUAS operated hereunder will remain confined to an operational area.

 No flight operations will occur inside restricted or special use, airspace.

 No flight operations will occur inside Class B, C, o r D airspace with the following conditions:

o No flight operations will occur within a 5 nm ( 9260 m) radius of a Class A airport in Class B, C, or D airspace with a floor of SFC.

o Flight operations will be restricted to a maximum altitude of 400 ft. (121.92 m ) AGL
outside the 5 nm ( 9260 m) radius of a Class A airport in Class B, C, or D airspace with a
floor of SFC

. Figure 1.1 depicts the area of operations in Class B, C, or D airspace with floor of SFC new a Class A airport.

 No UAV will operate or cross over a roadway designated as a h ighway by the Federal or State government the roadway is in with the exception of the specific use case of Municipal Police, Fire, and Search and Rescue or specific situations during Bridge Inspection. See Municipal Police, Fire, and Search and Rescue and Building, Bridge, Structure, or Span Inspection below for more
information.

 All operations will be performed by a trained two

- man crew: Equipment Operator and Spotter. The Equipment Operator will be responsible for piloting the UAV while the Spotter will focus on ground and air hazard identification.

 No UAV operate d hereunder will exceed an operational Weight 24.9476 kg (55 lbs.) including payload

.

 No UAV operated hereunder will exceed a ground speed of 25 m/s (56 mph).

 All UAV operated hereunder will be battery operated with no more than 60 minutes of minutes
of fl ight time on a single charge.

 All UAV operated hereunder will have “Return to Home” capability to return to a predetermined point should the sUAS Equipment Operator lose C2 communications

.

 No UAV operated hereunder will carry flammable, explosive or otherw ise hazardous material.

For more information on Equipment Operator and Spotter see the Operational Roles below, for more information on equipment, see Equipment Specificatio n below. Additional information on Aerialspecs, Inc. operatin g standards is available in Operating Standards and Appendix A. General Flight Process below.Petition for Exem ption/Rulemaking to the FAA

Commercial visual line

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- sight s UAS operations

P a g e | 7 Copyright © Aerialspecs, Inc, 2015. All Rights Reserved 

## S AFETY OF OUR 

## E MPL OYEES Employees with operational roles will be issued and minimally required to wear during operations the following personal protection equipment:

 ANSI Z89.1

- 2009 Type I Class C Helmet with chin strap.

 Safety Glasses.

 Safety Gloves.

 Hard sole steel toe sa fety boots that cover the ankle.

 ANSI Class 2 Safety Vest.

Addition safety equipment may be required depending on the specific use case or environment. The Equipment Operator is accountable for safety equipment beyond the minimum specified above.

During op erations the Equipment Operator or Spotter will have immediately available the following safety equipment:

 ABC fire extinguisher.

 5 person first aid kit.



## S AFETY OF OUR 

## C USTOMERS

 All nonessential customer personnel we be prohibited from entering the defined operational

a rea.

 All essential customer personnel we be required to use the same safety equipment as the Equipment Operator and Spotter while inside the operational area.

 All essential customer personnel we be briefed by Aerialspecs, Inc. on the associat ed health and safety hazards of being in close proximity of a sUAS

.



# O PERATIONAL 

# R OLES

Aerialspecs, Inc. will utilize the following ope rational roles to provide safe operations of sUAS . All operational roles will be required to maintain Flight Operations Certification s tatus as defined below. Employees in Equipment Operator or Spotter roles will be used interchangeably.



## C HIEF 

## E QUIPMENT 

## O PERATOR

The Chief Equipment Operator is in charge of and accountable for all flight operations hereunder and is
accountable for the Equipment Operators and Spotters.

The Chief Equipment Operator will have knowledge of and authorize all sUAS flight operations hereunder and will monitor weather, VFR conditions, Restricted, TFR, or SUA air space , and AIRMET/SIGMET zones. The Chief Equipment Operator will manage the operational relationship between Aerialspecs, Inc. and the FAA, FDSO, NTSB, State of Michigan, and local municipalities , obtaining permits and permission for operations where requ ired

. The Chief Equipment Operator will have full authority to cancel or abort any flight, any time, for any

reason. The Chief Equipment Operator will also conduct the daily Mission Briefing for all employees with operational roles.Petition for Exem ption/Rulemaking to the FAA

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## E QUIPMENT 

## O PERATOR

The Equipment Operator is accountable for the safe operation of the sUAS and is effectively the Pilot

- In

Command. The Equipment Operator will have full authority to cancel or abort any flight, any time, for any

reason.



## S POTTER The Spotter is responsible for t he safe operation of the sUAS . The job of the Spotter is to assist the Equipm ent Operator in “see and avoid,” monitoring the operational area for hazards, and/or incursions by unauthorized personnel or the general public on land, sea, or in the air. The Sp otter will have full authority to cancel or abort any flight, any time, for any reason. A Spotter will maintain the same level of proficiency as an Equipment Operator.



# F LIGHT 

# O PERATIONS 

# C ERTIFICATION

Failure to comply with the terms of this Petition for Ex emption, the process and procedures established by Aerialspecs, Inc.
, as well as local, State, and Federal laws may result in the revocation of certification for flight and termination from Aerialspecs, Inc.



## F LIGHT 

## C ERTIFICATION To be eligible for an opera tional role an employee must be 21 years of age or older, pass a TSA equivalent background check , pass a Third Class medical examination , maintain basic first aid certifications , have a valid driver’s license in the State of Michigan, and have not been convicted of a DUI or DWI or have refused an alcohol or drug test in the 60 working days prior to flight operations certification trainin g.

All operational roles will receive an 8 hour training course one t he basics of safe operations of sUAS used by Aerialspecs, Inc. This course will include the following:

 Health and safety hazards to employees and the general public.

o Required Personal Pro tection Equipment.

o Cutting hazards.

o Fall hazards.

o High speed collision hazards.

o Electric shock hazards.

o Fire hazards.

o Safe handling and disposal of batteries.

 Additional hazards to other land, sea, and air traffic.

o Potential issues encountering traffic.

o “S ee and avoid” tactics.

 Identifying hazards on the job site.

o Obstacle Identification.

o Overhead utility lines.

o Ropes, cables, and guy wires.

o Areas designated for the public.

o Avian hazards.

 Potential issues during operations, including:Petition for Exem ption/Rulemaking to the FAA

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o Equipment Failure.

o Op erational Area incursion.

o RF Interference.

o Fly

- offs or un

- commanded flight.

o Unexpected changes in weather.

o Fires.

 Aerialspecs, Inc. operating standards.

 General flight procedures

.

o Roles and responsibilities.

o SUA checks.

o TFR checks.

o Airspace checks.

o Weather verification.

o Effective pre and post

- mission briefings

.

o Pre and post

- flight checklists

.

 Emergency flight procedures

.

o Fly

- off or un

- commanded flight

.

o Operational Area incursion s.

o Crash es.

o Abort ing a flight.

o Communicating with pilots over Aviation Radio

.

 Re porting incidents to the FAA

. Upon completion of the training all operational roles will be given a test on the materials. Failure to pass the test with an 80% score or better will require the employee to retake the course. All operational roles
will be re quired to take this course annually or sooner should major operational changes be required. Should major operations changes be required inside the annual period , operational roles may only be required to take a bridge course with appropriate testing design ed around the changes

. Each operational role must obtain 8 hours of combined flight and equipment training for each type of equipment before being certified to operate the equipment.

Aerialspecs, Inc. will keep a record of training, certification, logged o perational hours, and equipment certified, for each person in an operational role.



### E QUIPMENT 

### O PERATOR AND 

### S POTTER 

### F LIGHT 

### T IME 

### R EQUIREMENTS The equipment operator and spotter must 8 hours of flight time logged checked off by a Chief Equipment Operator to ob tain a Flight Operation Certification. Once certified an Equipment Operator or Spotter will have an 8 hour flight time probation where they cannot be partnered with another Equipment Operator or Spotter who is on probation. Those 8 hours of flight will be logged and checked off by the experienced Equipment Operator or Spotter not on probation.

To maintain Flight Operations Certification an Equipment Operator or Spotter must log at least 10 hours
of operational time , either on

- the

- job or practice
, annually, excluding the flight time logged during the initial Flight Operations Certification checks.Petition for Exem ption/Rulemaking to the FAA

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### C HIEF 

### E QUIPMENT 

### O PERATOR 

### F LIGHT 

### T IME 

### R EQUIREMENTS
In addition to the Equipment Operator and Spotter Flight Time Requirem ents above , A Chief Equipment Operator must have at least 20 hours of operational time in the field and no incidents where he or she
was deem “at fault” in the last 12 calendar months.



### TSA E QUIVALENT 

### B ACKGROUND 

### C HECK Aerialspecs, Inc. employees, affiliate s, partners, vendors, or any other person or entity operating in a flight capacity on behalf of Aerialspecs, Inc. must pass an annual Aviation Background Check pursuant to FAA Regulations 14 CFR Parts 121, 125 and 135

. Aerialspecs, Inc. will contract Unive rsalTM 13 , to provide Aviation Background Checks.



### M EDICAL 

### E XAMINATION All roles will be required to maintain annually a Third Class Medical ce rtification from a local Aviation
Medical Examiner.



### B ASIC 

### F IRST 

### A ID 

### C ERTIFICA TION All roles will be required to maintain annual Basic CPR, Basic First Aid, and Basic AED certifications from
the American Red Cross.



# O PERATING 

# S TANDARDS

The following are a set of operational standards Aerialspecs, Inc. will use upon approval of the ex emption. These standards are intended to replicate the level of safety intended during the drafting of many of the regulations Aerialspecs, Inc. is seeking exemption for. These standards are not all inclusive and will likely change as Aerialspecs, Inc. mat ures this capability.

 No flight operations will occur inside restricted or special use, airspace.

 No flight operations will occur inside Class B, C, or D airspace with the following conditions:

o No flight operations will occur within a 5 nm ( 9260 m) radius of a Class A airport in Class B, C, or D airspace with a floor of SFC.

o Flight operations will be restricted to a maximum altitude of 400 ft. (121.92 m) AGL
outside the 5 nm ( 9260 m) radius of a Class A airport in Class B, C, or D airspace with a
floor of SFC

. Figure 1.1 depicts the area of operations in Class B, C, or D airspace with floor of SFC new a Class A airport.

 No UAV will operate outside visual line

- of

- sight of the Equipment Operator or Spotter

.

 No UAV will operate outsi de the range of the C2 transceiver of the Equipment Operator.

 No UAV will operate or cross over a roadway designated as a Highway by the Federal or State
government t he roadway is in with the exception of the specific use case of Municipal Police, Fire, an d Search and Rescue or specific situations during Bridge Inspection . See Municipal Police, Fire, and Search and Rescue and Building, Bridge, Structure, or Span Inspe ction below for more
information.

 All planned operations will have an on

- site survey done by an Equipment Operator or Spotter prior to operations.

 No flight operations will occur without the knowledge and permission of a Chief Equipment Operator.Petition for Exem ption/Rulemaking to the FAA

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 There wi ll be a daily Mission Briefing conducted by a Chief Equipment Officer evaluating weather

, AIRMET/SIGMET, SUA, TFR, and other factors to determine flights and flight windows for the day.

 A Chief Equipment Operator will monitor all restricted or Special Use Airspace, TFR, and AIRMET/SIGMET restrictions taking the appropriate actions with the Equipment Operator.

 All planned flight operations will be made publically available on the Aerialspecs, Inc. corporate web site with the exception of Municipal Police op erations of extreme circumstance. The information published will include:

o The date, time, and duration of the operations.

o The geograp hical position of the operational area

.

o The type of equipment being used.

 There will be an Equipment Operator and Spotter f or each UAV during flight operations.

 A Chief Equipment Operator

, Equipment Operator, or Spotter may cancel or abort a flight at any time for any reason. The Equipment Operator and Spotter have the responsibility to abort the flight should the situation ar ise.

 All flight operations require a Chief Equipment Operator or Equipment Operator
, and Spotter
present per sUAS in operation

.

 The Equipment Operator and Spotter will have in their possession the ability to communicate
with aircraft in the area via Aviati on Radio.

 A Mission briefing will be conducted to identify local hazards and plan of action to meet the objectives of the flight.

 A designated takeoff and landing point will be identified and clearly marked as a hazard with cones, flags, or some other obvi ous means. This point will also be set as the “return to home” point of the UAV.

 A pre

- flight check will be conducted per the equipment manufacturer and any standards set forth by Aerialspecs, Inc.

 The Equipment Operator and Spotter will remain in constant communication during operations
via voice or radio. In the event that communications between the Equipment Operator and Spotter are lost, flight operations shall cease with a controlled landin g of the UAV until
communications can be established.

 Should un authorized personnel or a member of the general public enter the operational area, either on land, sea, or in the air during sUAS operations, flight operations shall cease with a safe, controlled landing of the UAV until the hazard has cleared.

o All other a ir traffic in or near the operational area will have the right of way and appropriate action will be taken by the Equipment Operator to avoid the traffic.

 sUAS operations hereunder will comply with FAA §91.155 Basic VFR weather minimums 7 for daytime operat ions for Class G airspace and follow typical “see and avoid” standards during operations.

 No sUAS will be flown in weather conditions that exceed FAA §91.155 Basic VFR weather
minimums 7 for daytime operations for C lass G airspace or the operational envelope set forth by the equipment manufacture.

 Flight operations will cease with a safe, controlled landing of the UAV at the designated landing point when batt ery onboard the U AV reaches 1 5% of its capacity.

 The Equipment Operator and Spotter will conduct a Mission Debriefing when flight operations have been completed to document and share any learnings during the flight

.Petition for Exem ption/Rulemaking to the FAA

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 The Equipment Operator will log the flight when operation s have been completed.

For detailed information on the process see Appendix A. General Flight Process below. Figure 1.1 depicts the area of operations in Class B, C, or D airspace with floor of SFC neear a Class A airport.

Fig

. 1.1 Example area of operations inside Class B, C, or D airspace with a Class A airport. No flight operations are permitted within 5 nautical miles. Flight operations within the 12 nautical mile Class B airspace SFC to 10,000 ft. (3048 m) AGL will be restricted to maximum altitude of 400 ft. (121.92 m) AGL.



## F LY



## - OFF 

## P ROCEDURES

In the unlikely event of loss of control or communications with a UAV resulting in un

- commanded flight outside the operational area where all othe r attempts to abort the flight have failed

, the following procedures will be followed:

 The Equipment Operator will immediately contact the ATC responsible for the airspace the operations are in to notify them of the hazard. The Equipment Operator will prov ide ATC with the following information:

o Last known position of the UAV.

o The last known situation: altitude AGL, ground speed, and heading.

o The operational weight of the UAV.

o The estimated flight time remaining.

o Any defining characteristics of the UAV to he lp in locating and identifying the vehicle in flight.

 The Equipment Operator will contact the Chief Equipment Operator to log the incident.

 The Equipment Operator will provide periodic updates the ATC responsible for the airspace providing information

, if telemetry is available, until UAV is recovered or the estimated flight time remaining has expired.

 The Equipment Operator will contact the ATC responsible for the airspace once the UAV is recovered or the estimated flight time remaining has expired to info rm them the hazard no longer exists

.

 The Equipment Operator will contact the Chief Equipment Operator once the UAV is recovered
, or the estimated flight time remaining has expired

, to close the incident.Petition for Exem ption/Rulemaking to the FAA

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 The FSDO will be notified of the incident.

 A safety incident will be logged with Aerialspecs, Inc. with a follow

- up investigation in an attempt
to learn from the incident.

For detailed information on the process see Appendix B , Fly

- Off Process below

. Similar to the General Operating Standards above, these procedures are not all inclusive and will likely change as Aerialspecs,
Inc. matures this capability

.



## F LIGHT 

## S TANDARDS 

## D ISTRICT 

## O FFICES 

## N OTIFICATION Aerialspecs, Inc. will rep ort weekly to the FSDO the planned flights for the coming business week in electronic document format. This document will include the following information:

 Date, time, and duration of the mission.

 Location of the operations.

 Operational area.

 Nature or ob jective of the mission.

 Planned equipment to be used.

 How to contact the Equipment Operator and Spotter for the mission.

Aerialspecs, Inc. will also create a special webpage on its corporate website specifically for the FSDO containing the information abov e and allowing for additional comments or request. Ad

- hoc or emergency services will be reported to the FSDO within one business week. Any fly

- off, aerial operational area incursion, or crash will be reported to the FSDO in accordance to current guidelines

. The company is currently focusing on business operations in the State of Michigan

. The Michigan FSDO
locations are:

East Michigan
8800 Beck Road

- Eastside
, Belleville, Mi chigan, 48111 Phone: (734) 487

- 7222 Fax: (734) 487

- 7221
Grand Rapids
3196 Kraft Avenue Southeast

, Grand Rapids, Mi chigan, 49512 Phone: (616) 954

- 6657 Fax: (616) 940

- 3140
Aerialspecs, Inc. will establish a relatio nship with the FSDO East Michigan and Grand Rapids offices following the approval of this Petition for Exemption.



## E QUIPMENT 

## S PECIFICATION Aerialspecs, Inc. will limit operations of a UAV hereunder to light weight, battery operated configuration
with follow ing minimum specifications:

 Fixed wing or multi

- rotor craft

 Maximum operational Weight 24.9476 kg (55 lbs. ) including payload

.

 Maximum ground speeds of 2 5 m/s ( 56 mph).

 Battery operated with no more than 60 minutes of minutes of flight time on a single ch arge

.

 “Return to Home” capability.Petition for Exem ption/Rulemaking to the FAA

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 A flight controller leveraging any combination of the following: GPS, IM U, altimeter, computer vision, magnetic compass, or ultrasonic ranging and stabilization

.

 R emotely operated in the public 2.4 GHz, 5.8 GHz, or 900 MH z FCC Part 15 bands as well as non

C 2 information from the cellular bands in the GSM, CDMA, and LTE spectrums depending on carrier or service availability

.

 External GPS tracker with cellular transmitter in the GSM, CDMA, and LTE spectrums, depending

on car rier or service availability, to send periodic location updates.



## M AINTENANCE AND 

## R EPAIR Aerialspecs, Inc. will keep a maintenance log of all s UAS operated hereunder and make available this log to the FAA or NTSB upon written request. This log will include:

 The uniquely identifiable sUAS requiring maintenance or repair.

 The date and time of the maintenance or repair.

 The nature of the maintenance or repair.

 The motivation for the maintenance or repair.

o Equipment Failure.

o Crash.

o Manufacturer recall or request

.

o Chief Equipment Operator, Equipment Operator, or Spotter service request

.

o Mandate by a regulating body at the Federal, state, or local level.

 The company, organization, and/ or individual who performed the maintenance or repair.

 The actions taken to valid ate the maintenance or repair was complete and successful and the equipment is in operational order as defined by the equipment manufacturer.

Aerialspecs, Inc. will minimally follow the maintenance and repair recommendations set forth by the s UAS equipment manufacturer.Petition for Exem ption/Rulemaking to the FAA

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# S PECIFIC 

# U SE 

# C ASES

Below are the specific use cases Aerialspecs, Inc. is intending to operate under. Each use case describes how the sUAS will be used as well as the operational area, and any additional safety measures unique to
the use c ase. In the event that a specific use cases operational area conflicts with the constraints defined
in the Operating Standards herein, those constraints defined in the Opera ting Standards will take precedence.

In the event the size of an operational area exceeds the range constraints defined in the Operational
Standards herein the mission will be broken up into multiple sorties.



## W IND 

## T URBINE 

## C ONSTRUCTION AND 

## I NSPECTION
Using sensors, video and still image surveillance, a sUAS will be used to visually inspect the easements, tower, nacelle, blades, and hub in multiple EM spectrums for the purposes of routine inspection, damage
verificat ion, restoration planning, 3D site ma pping , and flood and drainage monitoring of ea sements on privately owned farms

. Aerialspecs, Inc. will also experiment with probes that can take measurements on engineering points on
wind turbine blades. These measureme nts will typically be impedance measurement to validate that blade lightning arrester systems are in good operating condition

. Prior to turbine construction a sUAS will be used to fly the complete blade sweeping area of a planned turbine. Leveraging an att ached strobe light, aerial and ground video, point clouds, and computer simulation, Aerialspecs, Inc. can ensure the visibility of a wind turbine to the property owners before committing to an agreement with the operator.



### O PERATIONAL 

### A REA For inspection of an existing turbine t he UAV will operate within a 600 ft. ( 182.88 m) horizontal radius of
the wind turbine center with a maximum altitude of 400 ft. (1221.92 m) AGL. If the wind turbine is over 400 ft. (121.92 m) AGL, then the maximum altitude will be no more than 50 ft. ( 15.24 m) above the tip of the airfoil fully extended above the nacelle. In the State of Michigan, that is typically no more than 550 ft. ( 167.64 m) AGL as the majority of wind turbines are no more than 499 ft. (152.1 m) AGL. The UAV will also operate over the easements designated as access to the wind turbine. In such a case the UAV will not fly more 50 ft. ( 15.24 m) on either side from the center line of the easement and no more than 100 ft. ( 30.48 m) AGL in height

. Figure 2.1 depicts the operational area for a wind turbine inspection.Petition for Exem ption/Rulemaking to the FAA

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Fig

. 2.1 Operational area for wind turbine inspection.
During turbine construction planning, the operational area will be limited to the property it is planned to
reside on and n o more than 400 ft. ( 121.92 m) AGL. Figure 2.2 depicts the operational area for a proposed
wind turbine.

Fig

. 2.2 Operational area for wind turbine construction planning.

In the case of validatin g the visibility of turbine prio r to construction the UAV will operate within a 600 ft. ( 182.88 m) horizontal radius of the wind turbine center with a maximum altitude of 400 ft. (1221.92 m)
AGL. If the wind turbine is over 400 ft. (121.92 m) AGL, then the maximum altitude will be no mor e than 50 ft. ( 15.24 m) above the tip of the airfoil fully extended above the nacelle. In the State of Michigan, that is typically no more than 550 ft. ( 167.64 m) AGL as the majority of wind turbines are no more than 499 ft. (152.1 m) AGL in height. Figure 2.3 depicts the operational area for validating the visibility of a wind
turbine.Petition for Exem ption/Rulemaking to the FAA

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Fig

. 2.3 Operational area for wind turbine visibility validation.



### A DDITIONAL 

### S AFETY 

### M EASURES

 The wind turbine must be shut down, in a locked con figuration to prevent wing feathering, nacelle, or blade rotation , and tagged as “personnel on site” or other relevant protective tagging that would prevent the turbine or its operators from starting it up during sUAS operations

.

 Under certain circumstance s the nature of the fault may prevent the turbine from being completely passivated. In those situations operations may commence provided that:

o The hub, blades, or nacelle are damaged in a manner that would likely prevent the
blades rotation.

o The tower has collapsed.

o The nacelle is directed into the wind and the wings are feathered to minimize rotation.

o The operator has physically secured the turbine on sight.

 No members of the general public will be permitted in the operational area during operations
with a ppropriate signage on display.



### P AYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biolo gical, chemical, gas, noise, light, vibration, and range sensors.

 Impedance Measurement Probe

 Other sample probes requiring direct or indirect contact with structure or equipment.

 Strobe light.Petition for Exem ption/Rulemaking to the FAA

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## E LECTRIC 

## G ENERATION 

## , T RANSMISSION 

## , S UB 

## T RANSMISSION 

## , AND 

## D IS TRIBUTION 

## F ACILITIES 

## I NSPECTION Using sensors, video and still image surveillance a sUAS will be used to inspect transformers, insulators, switches, breakers, fuses, lines, enclosures, towers, poles and any other supporting equipment at substations and gen erating facilities.

In addition, sUAS will be used to inspect high voltage transformers, insulators, switches, breakers, fuses, lines, enclosures, towers, poles and any other supporting equipment . A sUAS will also be used to generate 3D maps and validate c onstruction of new equipment.

Using sensors, video and still image surveillance a sUAS will be used to document and provide live video
feeds to utilities to validate issues, assess damage to transformers, insulators, switches, breakers, fuses, lines, enclo sures, towers, poles and any other supporting equipment, and generate 3D maps to plan repairs after large storms or other incident severely impacting the distribution grid.



### O PERATIONAL 

### A REA The operational area for substations and generation facilities is no more than 100 ft. ( 30.48 m) horizontally from the building or structures property line and a maximum altitude of 400 ft. (121.92 m) AGL. If the substation or generating facility has equipment over 400 ft. (121.92 m) AGL then the operational area will be a maximum altitude of 50 ft. ( 15.24 m) above the tallest part of the substation or generation facility and 100 ft. ( 30.48 m) horizontally from the building or structure down to 400 ft. (121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the horizontal operation al area will then extend to 100 ft. ( 30.48 m) from the building or structures property line. Figure 3.1 depicts the operational area for a substation or generation facility.

Fig. 3.1 Operational area for transmissi on and sub tr ansmission Towers.
The operational area for transmission, sub transmission, and tie lines will be 100 ft. ( 30.48 m) from the utility easement and a maximum altitude of 400 ft. (1221.92 m) AGL.Petition for Exem ption/Rulemaking to the FAA

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Fig. 3.2 Operational area for transmission and sub transmiss ion Towers.
For distribution assets, the operational area will be localized to job sites or incident areas with due diligence of focusing on the utility easement defined with a maximum altitude of 400 ft. (121.92 m) AGL. Figure 3. 3 depicts the operational area of operations on the distribution grid.

Fig. 3.3 Operational area for the distribution grid. In most cases on residential property.



### A DDITIONAL 

### S AFETY 

### M EASURES

 sUAS will be tested at a utility training facilities to validat e safe operations near energized equipment.

 A representative will be present during any utility operations inside the property of a substation or generation facility.

 Employees will be trained in the health and safety hazards of electrical equipment and po wer lines.Petition for Exem ption/Rulemaking to the FAA

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### P AYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical,

ga s, noise, light, vibration, and range sensors.



## B UILDING 

## , B RIDGE 

## , S TRUCTURE OR 

## S PAN 

## I NSPECTION Using video and still image surveillance, a sUAS will be used to visually inspect commerci al, industrial, or
residential buildings, church spires, bridges, struct ures , or spans and their supporting equipment for routine inspection, damage assessment, 3D site mapping, or construction or repair verification. This inspection may include, but not limited to, p iping, ductwork, conduit
, cabling, expansion joints, smoke

s tacks or chimneys, storage containers, boilers, pressure vessels
, and other equipment for industrial purposes may be inspected as well. In the case of smoke stacks or chimneys, a UAV may be used to mount and retrieve inspection rigs for internal inspection

.

A UAV equipped with a rudimentary de

- nesting rod may be used on industrial equipment that requires the area to be free of debris such as pressure relief values, inspection ports, intake or exhaust ports, or transceiver equipment.



### O PERATIONAL 

### A REA
In the case of buildings or structure the operational area is no more than 100 ft. ( 30.48 m) horizontally
from the building or structures property line and a maximum altitude of 400 ft. (121.92 m) AGL

. If the building or structure is over 400 ft. (121.92 m) AGL t hen the operational area will be a maximum altitude of 50 ft. ( 15.24 m) above the tallest part of the building or structure and 100 ft. ( 30.48 m) horizontally from the building or structure down to 400 ft. (121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the horizontal operational area will then extend to 100 ft. ( 30.48 m) from the building or structures property
line. Figure 4.1 depicts the operational area around a large building above 400 ft. ( 121.92 m) AGL. Figure
4.2 depicts the operational area around a structure below 400 ft. ( 121.92 m) AGL.

Fig

. 4 .1 Operational area around a building taller than 400 ft. ( 121.92 m ) AGL. Note the area around the perimeter of the property only extends to 400 ft. (121. 92 m) AGL. Also note the North side of the operational area does not extend over the highway.Petition for Exem ption/Rulemaking to the FAA

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Fig

. 4.2 Operational area around a structure below 400 ft. (121.92 m) AGL limit.
The operational area for bridges or spans is no more than 100 ft. ( 30.48 m) hor izontally from the span or bridges property or outer mos t structure, where appropriate and a maximum altitude of 400 ft. (121.92 m) AGL. If the bridge or span is above 400 ft. (121.92 m) AGL then t he maximum altitude is 50 ft. ( 15.24 m) above the tallest p art of the bridge or span

. The area underneath the bridge to the ground or water level will be considered the operational area as well. For bridges carrying vehicle traffic, no UAV will be flown over the roadway except around tower sections

. Figure 4.3 depicts the operational area around a bridge or span.

The operational area around the tower section of a bridge or span when over roadways is no more than 50 ft. ( 15.24 m) horizontally from the tower section, a minimum altitude of 50 ft. ( 15.24 m) above the roadway , and a maximum altitude of 400 ft. (121.92 m) AGL

. If the tower section of a bridge or span is above 400 ft. (121.92 m) AGL, including the 50 ft. ( 15.24 m) buffer, then the maximum altitude is 50 ft. ( 15.24 m) above the t allest part of the bridge or span.

Fig

. 4.3 Operational area around a bridge or span, minus the towers. Note no area over roadway.Petition for Exem ption/Rulemaking to the FAA

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### A DDITIONAL 

### S AFETY 

### M EASURES

 No sUAS will operate in an explosive atmosphere environment.

 No bridge, span, or structure that crosses over a roadway designated as a Highway by the Federal or State government the roadway is in will be inspected unl ess the highway has been closed in the operational area.

 The EM spectrum of antennas, buildings, bridges, structures, or spans contain ing transmitting equipment will be evaluated for interference of the C2 systems of the sUAS and vice versa.

 Equipment with intake or exhaust ports, or transmitters will be shut down before de

- nesting operations will occur.

 Equipment tied to smoke stacks or chimneys to be inspected will be shut down before internal inspections occur.

 Due to the nature of visibility in major metropolitan areas special handling of heliports will be taken. No sUAS operations in a major metropolitan area will occur within 1 stat ute mile ( 1.6 k m) of a heliport without informing the owner of the heliport s of the sUAS operations. This
communication will include:

o Date, time, and duration of the mission.

o Location of the operations.

o Operational area.

o Planned equipment to be used.

o How t o contact the Equipment Operator and Spotter for the mission.

 Sidewalks, bike paths, and any other pedestrian pathways inside the operational area will have appropriate warning signs, rope, tape, or other signaling methods to cordon off the area.

 If a brid ge or span can carry pedestrian traffic, the bridge or span must be closed to pedestrians.

 If a bridge or span is for vehicle traffic the UAV will not be flown over the roadway with the exception of the tower sections. It will be flown outside the guardrai l, main cables, hangers, or underneath the roadway.

 Operations over roadways around bridge or span tower sections will not be conducted if wind gusts exceed 20 MPH ( 8.94 m/s).



### P AYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, gas, noise, light, vibration, and range sensors.

 De

- Nesting or debris removal probes for removi ng animal nests or other debris.

 Other sample probes requiring direct or indirect contact with structure or equipment.



## A GRICULTURE 

## I NSPECTION Using video and still image surveillance, a sUAS will be used to gather visible, NIR, and IR photos of crops

to es tablish crop health for farmers. Aerialspecs, Inc. may also experiment with using other sensors to evaluate air, water, and soil conditions of crops.Petition for Exem ption/Rulemaking to the FAA

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### O PERATIONAL 

### A REA

UAV operations will be limited to a no more than 100 ft. ( 30.48 m) horizontally from th e property line
with a maximum altitude of 400 ft. ( 121.92 m) AGL. Figure 5.1 depicts the operational area for agriculture inspection.

Fig

. 5.1 Operational area for agriculture inspection.



### A DDITIONAL 

### S AFETY 

### M EASURES

 No fa rm equ ipment will be manned or operational in the operational area

.


### P AYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.



## I NDUSTRIAL 

## / M INING 

## E NVIRONMENTAL 

## I NSPECTION
Using video and still image surveillance, a sUAS will monitor stock piles, ash piles, run

- off, storage ponds,
erosion
, and document the environmental impact of those areas. 3D mapping will be leveraged to
measure volume and traversal of the environment over time. Aerialspecs, Inc. will experiment with other sensors including radiological, biological, and chemical as well.



### O PERATIONAL 

### A REA

UAV operations will be limited to a no more than 100 ft. ( 30.48 m) horizontally from the property line
with a maximum altitude of 400 ft. ( 121.92 m) AGL. Figure 6.1 and Figure 6.2 depict operational area s for environmental inspection. In the case of a quarry, pit, or hole, AGL will be measure from the base.Petition for Exem ption/Rulemaking to the FAA

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Fig

. 6.1 Operation al area for environmental monitoring , in this case a stockpile

.

Fig

. 6.2 Operational area for environmental monitoring , in this case a quarry.



### A DDITIONAL 

### S AFETY 

### M EASURES

 No sUAS will operate in an explosive atmosphere environment.



### P AYLOAD

 Passive video a nd/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, gas, noise, light, vibration, and rang e sensors.

 De

- Nesting or debris removal probes for removing animal nests or other debris.

 Other sample probes requiring direct or indirect contact with structure or equipment.Petition for Exem ption/Rulemaking to the FAA

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## M UNICIPAL 

## P OLICE 

## , F IRE 

## , AND 

## S EARCH AND 

## R ESCUE
Using audio, vid eo, and still im age surveillance a sUAS will be used to provide live visual , audio, telemetry
information to Police, Fire, Search and Rescue personnel during major incidents such as bomb threats, major vehicle accident involving hazardous materials, infrastructure or buil ding collapse, flooding, mudslide, landslide, hostage situation, or any other incident that poses an immediate threat to the health, lives, or safety of the general public or emergency response personnel. When equipped, the sUAS may also be used to provide live audio via directional microphone or active laser listening device where allowed by law. Aerialspecs, Inc. will experiment with other sensors including radiological, biological, and
chemical as well.

A sUAS will be used to generate point clouds for 3D mapping and monitoring of flood zones, rubble piles, or measuring spills.

Aerialspecs, Inc. will experiment with using a sUAS to tow a rescue rope or drop flotation devices to people during water or ice rescue.



### O PERATIONAL 

### A REA The operational area will b e defined by the Incident Commander handli ng the response. A typical operational area for a Police or Fire incident will be any suburban or metropolitan public, commercial, industrial, or residential property. In the case of buildings or structure the oper ational area is no more than 100 ft. ( 30.48 m) horizontally from the building or structures property line and a maximum altitude of 400 ft. (121.92 m) AGL. If the building or structure is over 400 ft. (121.92 m) AGL, including the 50 ft. ( 15.24 m) buffer, then the operational area will be a maximum altitude of 50 ft. ( 15.24 m) above the tallest part of the building or structure and 100 ft. ( 30.48 m) horizontally from the building or structure down to 400 ft. (121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the horizontal operational area will then extend to 100 ft. ( 30.48 m) from the building or structures property line. For the safety of the Equipment Operator and Spotter the horizontal area may be extended to 1000 ft. ( 304.8 m ) from the incident area. Figure 7.1 depicts the operational are for a Police or Fire incident. Figure 7.2 depicts the operational area
for search and rescue.

Fig

. 7.1 Operational area for Police and Fire.Petition for Exem ption/Rulemaking to the FAA

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Fig

. 7.2 Operational area for search and rescue.
For broader operations such as damage assessment, impact analysis, or search and rescue the operational area will be defined by the Incident Commander handling the response with a maximum altitude of 400 ft. ( 121.92 m) AGL.

Over a h ighway, the operational area will be 1000 ft. (304.8 m) radius around the approximate center of the Incident area with a maximum altitude of 400 ft. (121.92 m) AGL. Per the Additional Safety Measures
defined h ereunder, a 300 foot (91.44 m) barrier or buffer must be established and the highway must be
closed.

Fig

. 7.3 Operational area over highway. Due to the nature of hazardous or explosive cargo sometimes shipped over highways, an sUAS may have to enter anyw here from up to 1000 ft. (304.8 m) away for increased safety to the Equipment Operator and Spotter. Note the 300 ft. (91.44) barrier established in the Incident Area depicted in red.



### A DDITIONAL 

### S AFETY 

### M EASURES

 No sUAS will operate in an explosive atmospher e environment.

 No operations will occur while any other police, fire, or search and rescue aerial vehicles are operating in response to the incident.Petition for Exem ption/Rulemaking to the FAA

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 The agency handling the response to the incident will designate the Incident Commander on

scene as the li aison between the agency and the Equipment Operator and Spotter.

o The Incident Commander will be responsible for obtaining the necessary warrants, permits, exemptions, authorizations, or licenses to operate sUAS for the situation.

o The Incident Commander wi ll have the same authority to abort or cancel a flight as the Equipment Operator and Spotter.

o The Incident Commander must be in constant communication with the Equipment Operator and Spotter via voice or radio during Operations. In the event that
communica tions between the Equipment Operator and Incident Commander are lost, flight operations shall cease with a controlled landin g of the UAV until communications
can be established.

 The Equipment Operator and Spotter will operate under the guidelines of the Na tional Incident Management System as governed by the United States Department of Homeland Security.

 Personal protection equipment appropriate for the situation will be specified by the liaison and used by employees at all times during operations. Examples include respirators, flame retardant clothing, or ballistics vests.

 Due to the nature of visibility in major metropolitan areas special handling of heliports will be taken. No sUAS operations in a major metropolitan area will occur within 1 statute mile ( 1 .6 km) of a heliport without informing the owner of the heliports of the sUAS operations. This
communication will include:

o Date, time, and duration of the mission.

o Location of the operations.

o Operational area.

o Planned equipment to be used.

o How to contact t he Equipment Operator and Spotter for the mission.

 A UAV will never be used to restrain, detain, subdue, or physically engage an individual. In the case of water or ice rescue, a UAV may be used to tow a lead line to, or drop a flotation device
near an ind ividual in a manner that minimizes the risk of contact with the individual.

 Every attempt will be made by the Equipment Operator to access the incident area with the UAV via easements or public property, avoiding flying over private property except in extr eme cases.

 No sUAS operations will occur over any roadway designated a Highway by Federal or State Government the roadway is in unless the Highway has been closed at the point of the incident and a minimum 300 ft. (91.44 m) safety zone has been established around the incident.



### P AYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, che mical, gas, noise, light, vibration, and range sensors.

 Active and/or passive listening devices (in accordance with local, State, and Federal laws).

 Rescue Lead lines or life preservers for search and rescue.

 Audio speaker, siren, or bull horn.Petition for Exem ption/Rulemaking to the FAA

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# A PPENDIX



## A

. G ENERAL 

## F LIGHT 

## P ROCESSPetition for Exem ption/Rulemaking to the FAA

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## B

. F LY



## - OFF 

## P ROCESSPetition for Exem ption/Rulemaking to the FAA

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# G LOSSARY OF 

# T ERMS



## AGL

Above Ground Level : The altitude above ground level for any given location.



## AIRMET
AIRman's METeorological Information : An AIRMET is a weather advisory issued by the NOAA that advises
of weather that maybe hazardous, other than convective activity, to single engine, other light aircraft, and Visual Flight Rule (VFR) pilots

.



## ATC

A service provided by ground

- based controllers who direct aircraft on the ground and through controlled airspace , and can provide advisory services to aircraft in non

- controlled airspace. 9



## C2

Command and Control : Telemetry used to control the vehicle including manual commands from the
controller.



## EM

Electrom agnetic Radiation : radiati on consisting of electromagnetic waves, including radio waves, infrared, visible light, ultraviolet, x

- rays, and gamma rays. 15



## F LY



## - O FF

The un

- commanded flight of an UAV due to interference or malfunction that typically resul ting in loss of
the vehicle.



## FSDO
Flight Standards District Office: pronounced FIZ

- doe, is a regional office of the United States Federal
Aviation Administration. 14



## GPS
Global Positioning System : A device used to determine geographic position I latitude, longitude and
altitude above sea level.



## IMU

Inertial Measurement Unit : Sometimes referred to as a solid state gyro, an IMU determines position and
orientation or an object through a technique known as dead reckoning by dete cting the gravitational force, or G, on a particular axis.Petition for Exem ption/Rulemaking to the FAA

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## IR

Infrared: is invisible radiant energy, electromagnetic radiation with longer wavelengths than those of visible light, extending from the nominal red edge of the visible spectrum at 700 nanomet ers (frequency 430 THz) to 1 mm (300 GHz). 10



## N IR

Near Infrared: I nfrared region of the electromagnetic spectrum (from about 800 nm to 2500 nm)

. 11



## NTSB
National Transportation and Safety Board : The independent Federal Agency Charged with determining the probable cause of transportation accidents and promoting transportation safety, and assisting victims of transportation accidents and their families.



## SFC

Surface or Ground Level.



## SIGMET

SIGnific ant METeorological Information : A SIGMET is a weather advisory issued by the NOAA that contains meteorological information concerning the safety of all aircraft.



### S 

## UAS
Small Unmanned Aircraft System : A UAV and all its supporting systems for operations. Usua lly includes the remote controller and ground stations used for communication, imagery, and telemetry.



## TFR
Temporary Flight Restriction: The pertinent sections of the FAR (14 CFR Sections 91.137, 91.138, 91.139,
91.1 41, 91.143, 91.145, 99.7) describe tem po rary flight restrictions . A TFR is a geographically

- limited,
short

- term, airspace restriction, typically in the United States. Temporary flight restrictions often encompass major sporting events, natural disaster areas, air shows, space launches, and Presi dential

movements. 8



## UAV

Unmanned Aerial Vehicle : An unmanned, remotely operated, aerial vehicle in a fixed wing or multiple

rotor copter configuration.



## UV

Ultraviolet: Ultraviolet (UV) light is electromagnetic radiation wit h a wavelength from 400 nm to 10 nm, shorter than that of visible light but longer than X

- rays. 12



## VFR
Visual Flight Rules : A set of regulations which allow a pilot to operate an aircraft in weather conditions

genera lly clear enough to allow the pilot to see where the aircraft is going.Petition for Exem ption/Rulemaking to the FAA

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# R EFERENCES

1. FAA Advisory Circular AC 91

- 57, Model Aircraft Operating Standards http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/1acfc3f689769a56862569e70077c9cc/$FIL E/ATTBJMAC/ac91

- 57.pdf 2. Exemptions relating to 14 CFR § 45.23 ( b ): M ark ing of the A ircraft http://aes.faa.gov/Form/Doc.asp?SelExemptID=15968&ExemptNo=10700 http://aes.faa.gov/Form/Doc.asp?SelEx emptID=15071&ExemptNo=10167 3. Exemptions relating to 14 CFR §91.9 (b) (2): http://aes.faa.gov/Form/Doc.asp?SelExemptID=12862&ExemptNo=8607 http://aes.faa.gov/Form/Doc.asp?SelExemptID=13111&ExemptNo=8737 http://aes.faa.gov/Form/Doc.asp?SelExemptID=13119&ExemptNo=8738 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9299 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx? ExemptNo=9565 http://aes.faa.gov/Form/Doc.asp?SelExemptID=15071&ExemptNo=10167 http://aes.faa.gov /AES.NET/GetPDFDocument.aspx?ExemptNo=10602 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10700
4. Exemptions relating to 14 CFR §91.109: Flight Instruction http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=5778K http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?Exemp tNo=9862A 5. Exemptions relating to 14 CFR § 91.151: F ue l requirements for flight in VFR conditions http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10673 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=2689F http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=574 5 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10673 http://aes.faa.gov/AES.NET/GetPDFDoc ument.aspx?ExemptNo=10808 6. Exemptions relating to 14 CFR § 91.203 (a) & (b ): Carryin g Civil Aircraft Certification a nd Registration http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?Ex emptNo=9565 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9665 http://aes.faa.gov/AES.NET/Ge tPDFDocument.aspx?ExemptNo=9789 http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9797 http://a es.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9816A http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10700
7. FAA Code of Federal Regulations

, Part 91 General Operatin g a n d Flight Rules , Subpart B

- Flight
Rules
, Sec. 91.155 Basic VFR weather minimums : http://rgl.faa.gov/Regulatory_and_Guidance_Library /rgFAR.nsf/0/074608a2fa18b48a86256eeb006704ef!OpenDocumen

t 8. TFR Definition http://en.wikipedia.org/wiki/Federal_Aviation_Regulations#Temporary_flight_r estrictions 9. ATC Definition http://en.wikipedia.org/wiki/Air_traffic_control 10. Infrared Definition http://en.wikipedia.org/wiki/Infrared
11. Ne ar Infrared Definition http://en.wikipedia.org/wiki/Near

- infrared_spectroscopy 12. Ultraviolet Definition http://en.wikipedia.org/wi ki/Ultraviolet 13. UniversalTM Aviation Background Check http://www.universalbackground.com/solutions/aviation.asp
14. FSDO Definition http://en.wikipedia.org/wiki/Flight_Standards_District_OfficePetition for Exem ption/Rulemaking to the FAA

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15. EM Definition http://dictionary.reference.com/browse/electromagnetic+radiation