Request for Exemption: Global Positions, LLC Page 1

Global Positions, LLC
, Montana

– Petition for Section 333 Exemption

July 4
, 2015

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

Re ference : Request for Exemption under Section 333 of the FAA Modernization and
Reform Act of 2012 from 14 CFR . Part 21; 14 CFR . 43.7; 14 CFR . 43.11; 14 CFR

. 45.11; 14 CFR . 45.27; 14 CFR . 45.29; 14 CFR . 61.113; 14 CFR . 91.7(a); 14 CFR

. 91.9(b)(2); 14 CFR . 91.9(c); 1 4 CFR . 91.103(b)(2); 14 CFR . 91.105; 14 CFR . 91.109; 14 CFR . 91.119; 14 CFR . 91.121; 14 CFR . 91.151; 14 CFR . 91.203(a) & (b); 14 CFR

. 91.215; 14 CFR . 91.403; 14 CFR . 91.405; 14 CFR . 91.407; 14 CFR . 91.409; 14 CFR. 91.417 and 14 CFR 61.195.

Dear Sir or Madam,

Global Positions , a Montana Limited Liability Company (LLC) , seeks an exemption to certain Federal Aviation Regulations (FARs) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and Part 11 of Title 14 of the CFR

. The requested exemption woul d support a claim for a C ommercial Certificate of Authorization to use the system to perform aerial photography
, spatial data collection for mapping and GIS, academic research
, and video capture ( aerial data collection)

. Approval of exemptions for Global Positions, LLC will permit commercial unmanned aircraft system (UAS) operations

. By approving these exemptions, the FAA will createRequest for Exemption: Global Positions, LLC Page 2

benefits through safer survey methods by UAS, resulting in decreased potential for loss of life and enhanced efficiency and productivity for the affected activities, which are all ultimately in the public interest.

Global Positions, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, pursuing reprieve from any currently applicable FARs operating to
inhibit Global Positions, LLC proposed aerial data collection within the national airspace system.

This exemption request should be granted because the use of the aircraft utilized by Global Positions, LLC under the limitations and conditions anticipated will meet or exceed an equivalent level of sa fety as Congress has intended

.

Sincerely,

Jere Folgert

Principal, Global Positions, LLCRequest for Exemption: Global Positions, LLC Page 3

Overview : Pursuant to 14 CFR . Part 11, the following overview is provided for publication in the Federal Register, should it be determ ined that publication is needed.
Petitioner seeks an exemption from the following rules:

14 CFR . Part 21; 14 CFR . 43.7; 14 CFR . 43.11; 14 CFR . 45.11; 14 CFR . 45.27; 14 CFR . 45.29; 14 CFR . 61.113; 14 CFR . 91.7(a); 14 CFR . 91.9(b)(2); 14 CFR . 91.9(c); 14 CFR . 91.103(b)(2); 14 CFR . 91.105; 14 CFR . 91.109; 14 CFR . 91.119; 14 CFR . 91.121;
14 CFR . 91.151; 14 CFR . 91.203(a) & (b); 14 CFR . 91.215; 14 CFR . 91.403; 14 CFR

. 91.405; 14 CFR . 91.407; 1 4 CFR . 91.409; and 14 CFR . 91.417.

Approval of these exemptions for Global Positions, LLC will permit commercial operations of UAS for the purpose of obtaining vertical and oblique aerial images and
video. Images will be post

- processed ( orthorectification will be performed to create planimetrically

- correct image ) and used predominantly in geographic information system (GIS) for mapping and analysis. G lobal Positions, LLC does not intend to operate sUAS for the purpose of closed

- set motion picture filming.

This petition for exemption is submitted to fulfill the objective of congress in
p assing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerat e the incorporation of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to contemplate whether certain unmanned aircraft systems may maneuver safely in the National Air space ("NAS") before completion of the formal UAS rulemaking, based on If the Secretary supports that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System".

The exemption should be granted because the operations proposed by Global Positions, LLC, using unmanned UAS weighing less than 10 pounds , conducted according to the
conditions and limitations deliberated in this document w ill deliver a level of safety exceeding that of traditional aerial operations

- operating as manned aircraft. No flights will be conducted without the acquisition of adequate GPS signals to enable GPS

- aided flight. F light s will be constrained to class G airspace at altitudes less than 400 feet Above Ground Level ( AGL ) and at controlled speeds. Each of the factors identified by the Congress in approving this exemption process under Section 333 including weight,Request for Exemption: Global Positions, LLC Page 4

speed, size, operational capability, proxim ity to airports, operation within visual line of light and proxim ity to densely populated areas, supports confirmation of the exemptions
desired by Global Positions, LLC.

Description of the Petitioner: Global Positions, LLC is a Montana Limited Liability Company established in 1997 and specializes in geographic information systems
, professional mapping, cartography, data collection, education and outreach. Global Positions, LLC has completed numerous GIS projects around the globe and has
received the Smal l Business Innovation Research (SBIR) Award from the National
Science Foundation. Global Positions, LLC has performed numerous sUAS flights in
remote areas under different weather conditions.

Contact Information:
Mr. Jere Folgert, Principal

Global Positions, LLC
3215 Warbler Way #5
Bozeman, MT 59718 (406) 580 1314 Jfolgert@GlobalPositions.com

www.GlobalPositions.comRequest for Exemption: Global Positions, LLC Page 5

Qualifications for Exemption Und er Section 333 of FMRA : The proposed operations would permit the use of a small UAS (sUAS) under controlle d conditions in airspace where : (1) flights are limited in vertical elevation and
horizontal distance travelled ; (2) flights are prearranged and prep lanned; (3) sUAS are operate d in line of sight and will only operate within those areas designated in the enc losed Flight Operations Manual; (4) Controller conduct its own operations in compliance with the protocols described herein or as otherwise
establ ished by the FAA

.
Global Positions, LLC currently operates the DJI Inspire 1. Due to the rapid advancements in technology and improvements in aircraft safety, Global Positions, LLC requests that any exemption granted extend not only to the DJI Inspire 1 currently owned by Global Positions, LLC, but also to any future sUASs owned by Global Positions, LLC th at are manufactured by DJI ; ( 2 ) . Have a flight
wei gh t less than 10 pounds at takeoff; ( 3 )

. Have built

- in global positioning system (GPS) receiver that aids in its flight, position, and elevation. (4). Have improved safety features as compared to the DJI Inspire 1

.
If the request for exemption cannot be fulfilled for future sUASs owned by Global Positions, LLC

- Global Positions, LLC explicitly requests the exem ption allow ing the operation of the DJI Inspire 1.

Characteristics of the Aircraft: The DJI Inspire 1 is a battery

- powered UAV utilizing electric motors and blade rotors. It has a maximum gross weight of approximately six and one half (6.5) pounds. The DJI Inspire 1
, m odel number
T600 has a weight (battery included) of 2935 grams. It has a hovering accuracy (GPS mode) v ertical of 0.5 meters and Horizontal accuracy of 2.5 meters. Its maximum angular velocity pitch is 300 degrees per second and its maximum ascent speeds is 5 meters per second. The maximum flight time is approximately 18 minutes. Its operating temperature range is between

- 10° C to 40° C. It hasRequest for Exemption: Global Positions, LLC Page 6

a n overall dimensions of 438 m x 451 mm x 301 mm.

Image of the DJI Inspire 1.

The DJI Inspire 1 has a built

- in f light control system that utilizes GPS, an inertial
measurement unit
, and electronic compass. This unit has a maximum flight speed of approximately 40 knots and uses a 22.2 volt, 4500 milliampere

- h our b attery , which provides an energy source to power the craft’s motors and
electronics for approximately 15 minutes of flight

. This aircraft has distinctive failsafe capabilities including a n ability to determine the amount of battery power required to fly the aircraft back to a pre
- designated ho me point

. The DJI Inspire
1 has limited range due to the physical limitations of the Light B ridge transmission system from the remote controller. In addition, this aircraft has the capability for a maximum altitude to be set prior to each flight. DJI I nspire 1 has programmed into the firmware “no

- fly zones” which will prevent flights in restricted airspace.
Please refe r to the respective user manual for the DJI Inspire 1 aircraft for
additional information.

Considering the authority contained in the Fe deral Aviation Act, as amended in Section 333 of the Reform Act , the equivalent level of safety surrounding theRequest for Exemption: Global Positions, LLC Page 7

proposed operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest.

Granting Global Positions, LLC request conforms with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of su ch aircraft systems [UAS's] in the national airspace system ” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes.

Global Positions, LLC Request Will Benefit the Public : Congress has declared
that it is in t he public’s interest to integrate commercially flown UAS's into the national airspace system, henceforth passing of the Reform Act. Granting Global Positions, LLC exemption request furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those proposed in this petition.

Aerial photography, remote sensing for geographical analysis and inventory, aerial videography and filmmaking, mapping, and ph otogrammetry ha ve been made possible through the use of manned fixed wing aircraft and helicopters. The public’s interest is advanced by diminishing potentially fatal crash es of manned aircraft and helicopters by permitting aerial video , and photo graphy ca pture through U AS's. Permitting Global Positions, LLC to fly within national air space furthers economic growth by offering cost

effective aerial photography, mapping products, and videography. Granting Global Positions, LLC exemption request furthers the public interest through awareness of the spatial connections of natural and human

- made features on the ground and geographical assessment and analysis of said features using GIS and mapping technologies.

Granting the exception will help federal agencies g ain a greater understanding and knowledge base for conduct ing commercial UAS operations . This valuable information has the potential to facilitate future rules and regulations, UAS flight operations, and operator qualifications. The UAS operated by the Pe titioner are light weight and do not carry any flammable fuel, further reducing the risk from any potential accident and harm to humans, animals, and property. Global Positions, LLC agrees to follow best safety practices when operating a battery

- powered s UAS.Request for Exemption: Global Positions, LLC Page 8

Proposed Flight Conditions and Operations : Global Positions, LLC would like to operate s UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act in Section 332 provides for incorporation of unmanned aircraft systems into our national airspace system as it is in the public’s i nterest to do so. Global Positions, LLC
, sUAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of Global Positions, LLC sUAS is expressly contemplated by the Reform Act.

Global Positions, LLC inte nds sUAS operation locations to be primarily in unpopulated areas in Montana, Wyoming and Idaho. Global Positions, LLC is requesting operat ions of sUAS in the United States and understands that this request may result in an increase
in the FAA ’s oversight tasks.

Global Positions, LLC has no intention in creating a hazard to humans, non
- human life
forms , private property or manned aircraft, and has no desire to risk the loss of the
Petitioner’s sUAS. Global Positions, LLC has performed numerous flights in remote

areas under different weather conditions. Global Positions, LLC also performs simulated flights in order to maintain suitable skills for the sake of safety. Global Positions, LLC is extremely cautious when operating any UAS an d will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of Global Positions, LLC s UAS, it falls well within Congress’s contemplated safety
zone when it promoted and publis hed the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. The sUAS used by Global Positions,
LLC has a many safety features and does not pose a threat to the general public or national security. The sUAS oper ated by Global Positions, LLC is equipped with a GPS receiver, electronic compass, auto return safety technology (if communication is lost between the UAS and the controller), and Real

- Time Fight Data Display.

Global Positions, LLC proposes that the exemption requested herein apply to all civil aircraft that have the characteristics and that operate with the limitations listed in this document. These limitations deliver an equivalent or higher level of safety to operations under the current regulatory structure. Global Positions, LLC agrees to be bound to
these limitations and conditions when piloting commercial operations under an FAARequest for Exemption: Global Positions, LLC Page 9

issued

- exemption. What follows are twenty ( 20 ) proposed operational limitatio ns and flight conditions, where Global Positions, LLC (Operator) which will safeguard flight operations conducted under current regulatory guidelines:



### 1. Flights will be operated within line

- of sight of the Operator.


### 2. A Visual Observer (VO) will provide observation of the sUAS while in flight to alert the Operator of any risk factors inflight such as traffic or obstructions in the flight area. The VO will maintain communic ation with the Operator at all
times.


### 3. No flight shall occur within 5 miles of an established ai rport as noted and published on FA A published aeronautical charts, unless a letter of agreement with that airport’s manager is obtained.


### 4. The Operator will have sufficient training in operations of sUAS and will
have received and reviewed up
- to

- date material on the specific sUAS operations and protocol as per the manufacture and Flight Operation Manual.


### 5. The Operator of the sUAS will use eye protection ( safety gear ) when operating sUAS.


### 6. The sUAS will weigh less than 55 pounds.


### 7. Before conducting any operations, the Operator will inspect components of the sUAS for any visible indications of damage, to include but not limited to the propeller blades, motors, aircraft frame and landing apparatus

. 

### 8. Prior to each sUAS flight, Operator will conduct extensive pre

- flight planning including observations of weather conditions, weather forecasts, population density, and location of potentially hazardous flying conditions. P re
flight checks using established protocol s carries primary importan ce

. 

### 9. While sUAS is in flight, Operator will actively analyze flight data, wind speeds, weather conditions, forecasts and other sources of information to constantly update and enhance safety protocols.


### 10. Maximum flight time for each operationa l flight will be limited to a duration,
where no less than 25 % of battery life remains to power the sUAS

. Battery life information is displayed on the remote controller’s display, and is coded on the sUAS using different color flashing light

- indicators.


### 11. sUAS operations wi ll not be conducted during the night

.Request for Exemption: Global Positions, LLC Page 10



### 12. The Operator will operate said sUAS at an altitude not greater tha n 4 00 feet above ground level.


### 13. The sUAS will not be operated less than 5 00 feet below or le s s than 2,000 feet horizontally from a cloud or when visibility is less than 3 miles from the Operator.


### 14. Contingency plans will be in place to safely terminate a flight if there is a loss of transmitter communications or a loss of GPS signal.


### 15. Auto return

- to

- home and l anding function will be utilized to increase safe return of the UAS to the ground.


### 16. The aircraft will be flown only in class G airspace. Each operation will be conducted in a way that avoids conflict with other ongoing operations in the NAS.


### 17. The sUAS Pilot will be minimum holder of Private Pilot C ertificate with a Class 3 Medical or State issued Driver License.


### 18. During the planning phase of each operation
, the Operator will ensure that the sUAS, controller, and intelligent batteries have valid firmware updates from the manufacturer. Electronic comp ass and sensors will be recalibrated after
each firmware update.


### 19. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, power lines, transformers, elevated lights and structures unless barriers or st ructures are existing that satisfactorily protect nonparticipating persons, or, the Operator has been granted permission for operating closer to those objects and has determined that it does not present a hazard.


### 20. The sUAS will not be used for the purpose of closed

- s et motion picture filming.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012, including weight, speed, size, safety measures, operating capabilities, operation within visual
line

- of sight, operation under certain weather conditions, proximity to airports and populated areas, provide adequate justification for the grant of the requested exemptions, allowing commercial operation ap plicant’s sUASs pursuant to the conditions and operations described above.Request for Exemption: Global Positions, LLC Page 11

Safety and Public Interest : Global Positions, LLC has produced safety protocols that
afford a level of safety equal to or exceeding existing rules. Benefits of using sUAS over conventional gasoline

- powered fix

- wing aircraft or helicopters include:

 UAS's do not carry humans on the aircraft therefor potential loss of life is diminished. Global Positions, LLC will only operate its UAS in specific areas away from mass populat ions.

 Flammable fuel is not used to power sUAS and the potential for fire or explosions is greatly diminished as compared to an aircraft using flammable fuel.

 Modern GPS

- enabled UAS’s can be controlled and maneuvered with great precision, and can be contro lled to avoid hazards quickly

.

Use of the sUASs will reduce the need to have a manned aircraft provide a platform for obtaining video and/or photographs resulting in safety for life and property

. Manned aircraft often carry combustible fuel and can weigh in excess of 900 pounds. The sUASs
in this g rant petition do not carry combustible fuel and weigh less than 10 pounds
, significantly lessening the potential for damage to life and property. The amount of energy required to obtain aerial photographs or aerial video is significantly less than the energy required to obtain the same data using conventional fixed wing aircraft. These
environmental factors are in the public interest and in favor of gra nting the exemption.
Because of the relative low noise levels produced by sUAS, data collection (photos and video) can be obtained in a relatively quiet manner (as compared to conventional fixed

wing ai rcraft), which has the potential reduce p otential disturbance levels for humans
and other non
- human life . Additionally, operating a sUAS in flight has a negligible environmental impact as compared to conventional ma nned aircraft which consume
fossil fuel
, and produce airborne pollution.Request for Exemption: Global Positions, LLC Page 12

Attachments : A ttachments listed are referenced in the request for exemption and contain trade secret and commercial proprietary information that Global Positions, LLC has not and will not share with others except under a ppropriate confidentiality agreements. Global Positions, LLC is requesting that these attachments be preserved as proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from release under the Freedom of Informati on Act. See 5 U.S.C. 552 et seq.

1. Standard Operating Procedures and Checklist for DJI Inspire 1
2. DJI Inspire 1 Operating Manual
Exemption Request : What follows are the sections of Title 14 of the Code of Federal Regulations from Which Global Positions, LLC Requests Exemption:

14 CFR . Part 21; 14 CFR . 43.7; 14 CFR . 43.11; 14 CFR . 45.11; 14 CFR . 45.27; 14 CFR

. 45.29; 14 CFR . 61.113; 14 CFR . 91.7(a); 14 CFR . 91.9(b)(2); 14 CFR . 91.9(c); 14 CFR

. 91.103(b)(2); 14 CFR . 91.105; 14 CFR . 91.109; 14 CFR . 91.119; 14 CFR . 91.121; 14 CFR . 91.151; 14 CFR . 91.203(a) & (b); 14 CFR . 91.215; 14 CFR . 91.403; 14 CFR

. 91.405; 14 CFR . 91.407; 14 CFR . 91.409; 14 CFR. 91.417; and CFR 61.195.

D escription of Specific Regulations that Global Positions, LLC Requests and Exemption From : 14 CFR . Part 21, and particularly Part 21(h). Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. An equivalent level of safety with airwor thiness certification can be achieved by the use of sUASs and the conditions and limitations imposed on operations which have been proposed in this petition.

14 CFR . 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, a ppliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. Global Positions, LLC has experience repairing and modifying sUASs included in this grant. An equivalent level of safety will be obtained by Global Positions by conducting inspections and maintenance to ensure safe operation of sUAS.

14 CFR . 43.11: Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§ 135.411(a)(1) and 135.419 of this chapter. BecauseRequest for Exemption: Global Positions, LLC Page 13

there are no cert ificated maintenance workers or inspectors for sUAS anticipated by this section, § 43.11 provides for no extra safety in flight. Global Positions, LLC propose s an equal level of safety will be attained by testing and inspecting the sUAS before and after

ea ch flight.

14 CFR . 45.11: Marking of products. The sUASs have a small size and footprint and do not have adequate space for required identification cards. A dditional weight from the
identification cards could depreciate the flight stability and performa nce of the aircraft. An equivalent level of safety will be obtained by Global Positions by storing and archiving information related to the sUASs, including the serial number, user manual, and nomenclature at the ground station and affix the N

- Numbers, once obtained from the FAA Registration Office.

14 CFR . 45.27 : Location of marks; non

- fixed

- wing aircraft where each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. The sUASs used by Global Positions, LLC has a small size and do not have a cabin for humans. An equivalent level of safety will be obtained by Global Positions by displaying its N

- Number(s) (when
received by the FAA) ; they will be displayed on the fuselage of the aircraft as large as possible. This exemption provides an equivalent level of safety to 14 CFR . 45.27

14 C FR . 45.29: Size of marks on aircraft . Global Positions, LLC requests an exemption
from 14 CFR . 45.29. as the UASs have very little, if any surface areas large enough to allow placement of markings of that size. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. An equivalent level of safety will be obtained by Global Positions after they receives the N

Number(s) . N

- Numbers wi ll be displayed on the UAS’s body or fuselage. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167,
10167A and 10700.

14 CFR . 61.113: Private pilot privileges and limitations: Pilot in command. This part prohibits persons with private pilot certificates from operating an aircraft for hire. Global
Position s, LLC requests an exemption from 14 CFR . 61.113. Global Positions, LLC understands that the intent of necessitating a commercial certificate before operating anRequest for Exemption: Global Positions, LLC Page 14

aircraft for hire is to protect human lives as most flights for hire are manned. Instead, G lobal Positions, LLC will attain an equal level of safety by ensuring all Operators go through a rigorous training program including flight simulation, practice flights, and a minimum of ten ( 10 ) flight hours in a multirotor sUAS

.

14 CFR . 91.7(a): Civil aircraft airworthiness. The FAA has previously stated that no exemption is required for a member of the DJI Phantom 2 family. Global Positions, LLC requests a similar for its sUASs: the DJI Inspire 1. The Inspire 1 is significantly similar to
the Phantom 2 in structure and operation, but with additional safety features

. Since there will be no airworthiness certificate issued for the aircraft at issue in this petition, it is not possible to comply with this regulation.

14 CFR . § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Global Positions, LLC requests exemption from 14 CFR . § 91.9 (b) (2) as there are no on board pilots or passengers, and given the size of the UAS, this regulation is inapplicable. An equ ivalent level of safety will be achieved by maintaining a safety and flight manual easily
accessible to the Controller . The FAA has previously issued exemptions to this regulation in the past.

14 CFR . 91.9(c): Civil aircraft flight manual marking, and placa rd requirements. Global Positions, LLC requests an exemption from 14 CFR . 91.9(c). An equivalent level of safety will be obtained by Global Positions when they place on the aircraft, an N

- Number
obtained from the FAA.

14 CFR . 91.103(b)(2): Preflight action. The FAA has previously determined that relie f from this section is not necessary. Global Positions, LLC requests that a similar determination be made with respect to this petition as Global Positions, LLC requires specific preflight actions to be followed prior to each flight including the review o f maps, and charts, weather data including wind speed, c alibrating the compass and verifying the aircraft has adequate GPS satellite signals for flight.

14 CFR . 91.105: Flight crewmembers at stations. Global Positions, LLC requests an exemption from 14 CF R . 91.105 since this section is not applicable due to the sUASs carrying no flight crewmembers. Global Positions, LLC will not operate the aircraftRequest for Exemption: Global Positions, LLC Page 15

unless someone is at the controls at all times. An equivalent level of safety will be obtained by Global Positions , as t he Operator will always remain at the ground station in

co ntrol of the sUAS. This will result in an equivalent level of safety as the requirements of § 91.105.

14 CFR . 91.109 Flight instruction; simulated instrument flight and certain flight tests. Global Positions, LLC requests an exemption from 14 CFR . 91.109 . This regulation requires dual controls for aircraft when conducting flight instruction. The remote controller can be easily transferred to another person midflight.

14 CFR . 91.119: P rescribes safe altitudes for the operation of civil aircraft. Global Positions, LLC requests an exemption from 14 CFR . 91.119. Global Positions, LLC intends to operate its sUAS at an altitude no greater than 400 AGL; safely within the standard 400 AGL as recommended by the FAA Modernization and Reform Act of 2012

. The sUAS operated by Global Positions, LLC have GPS

- aided flight stability integrated into the flight control system which permits the sUASs to preserve their location when there are no inputs given through the remote controller.

14 CFR . 91 .121: Altimeter settings. Global Positions, LLC requests an exemption from
14 CFR . 91.121. This regulation states that setting the altimeter of an aircraft referenced to mean sea level (MSL) is required. The sUAS operated by Global Positions, LLC uses G PS to determine altitude, which is displayed to the operator as a digital readout to the video screen

. GPS sensor is accurate to approximately 2.6 feet
Vertical and 8.2 feet Horizontal. Global Positions, LLC intends to maintain flight in class G airspace within VLOS during VMC at altitudes less than 400 feet AGL which will safeguard that the sUASs do not impede with the flight of other aircraft.

14 CFR . 91.151: Fuel requirements for flight in VFR conditions. This regulation requires
aircraft to have an amount of fuel that would carry the aircraft either 20 or 30 minutes beyond the intended landing point. Global Positions, LLC requests an exemption from
14 CFR . 91.151. It is difficult to comply with this regulation due to the face that the sUAS in this p etition use an onboard battery as power, and carry no liquid fuel at allRequest for Exemption: Global Positions, LLC Page 1 6

14 CFR . 91.203(a) & (b): Civil aircraft: Certifications required. The FAA has previously determined that exemption from 14 CFR . 91.203(a) and (b) is not necessary. Global Positions, LLC requests an exemption from 14 CFR . 91.203(a) & (b). This regulation cannot be complied with due to there being no certification process in place for aircraft of this type. Global Positions, LLC will reach an equivalent level of safety by confirming that the Operator perform its responsibilities in accordance with the manufacturer’s i nstructions and recommendations, including, but not limited to, prescribed firmware and software updates, visual inspections of the equipment, and regular test flights an d simulated flights.

14 CFR . 91.215: ATC transponder and altitude reporting equipment and use. Global Positions, LLC requests an exemption from 14 CFR . 91.215 as it is virtually not possible to comply with the requirement of this section at this time as sUASs are not equipped with radio equipment that can transmit electromagnetic signals produced by a transponder. Adding a third

- party digital transponder would add an additional weight burden to the existing lightweight sUAS jeopardizing it’s flight perfo rmance and safety.

An equivalent level of safety will be achieve by Global Positions, LLC by limiting all sUAS flights to altitudes no greater than 400 feet AGL within class G airspace only. Additionally, flights will not be piloted within 5 nautical mile s of an airport reference point
as denoted on a current FAA

- published aeronautical charts. These measures will diminish the risk of impact with another aircraft to a minor level.

14 CFR . 91.403: Aircraft must maintain it in an airworthy manner and any mai ntenance performed on an aircraft must be done in a manner consistent with Part 43 of Title 14 of
the CFR . Global Positions, LLC requests an exemption from 14 CFR . 91.403. An equivalent level of safety and care will be attained by inspecting sUAS and tes ting sUAS after each and every repair, firmware update, or alteration by Global Positions, LLC or DJI, Inc. An equivalent level of safety will be obtained by Global Positions as the Controller will pilot a test flight prior to each operation in order to confirm appropriate functioning of the flight operations.Request for Exemption: Global Positions, LLC Page 17

14 CFR . 91.405: This regulation necessitates maintenance personnel to make repairs in
accordance with Part 43 of Title 14 CFR . and to make entries in the maintenance records consequently. Global Positions, LLC requests an exemption from 14 CFR

. 91.405. Thes e Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Global Positions, LLC sUAS. However, as a safety
preca ution Global Positions, LLC will inspect Global Positions, LLC s UAS before and after each flig ht. Standard i ndustry standard and guidelines do not exist for sUAS; Manufactures provide suggestions as to when components of the aircraft b e replaced based on usage, damage, and the number of hours of operation. Global Positions will inspect , on a regul ar basis, the four electric motors which power the propellers . R epair s or replace ments of said motors will be based on necessity, pre scheduled maintenance

or on manufactures recommendations.

14 CFR . 91.407: This regulation provides, in part, that no one may operate an aircraft after maintenance has been conducted upon it, unless the maintenance was in conformity with Part 43 of Title 14 CFR . Global Positions, LLC requests an exemption to
14 CFR . 91.407. An equivalent level of safety will be obtained by Global Positions personnel as t hey will inspect the physical parts of the sUAS for wear, damage, malformations, and other defects prior to and after each flight. The self

- diagnostic
software of the sUAS will be used as an aid to determine flightwo rthiness as well resulting in an equivalent level of safety

.

14 CFR . 91.409: This section provides detailed requirements for inspections of aircraft, including annual inspections for airworthiness certification. Global Positions, LLC requests an exemption from 14 CFR . 91.409. Although Global Positions, LLC strongly
believes th at airworthiness is critically important, the certification of this is largely unsuitable to sUASs given there are no standard or approved certification process in
existence for sUASs

. An equivalent level of safety will be obtained by Global Positions,
LLC by performing inspections of the sUASs prior to and after each flight operation. Inspections of the sUASs will be much more frequent as compared to the interval of inspections required by § 91.409.Request for Exemption: Global Positions, LLC Page 18

14 CFR . 91.417: This section is on ly applicable for aircraft with an airworthiness certificate. Global Positions, LLC requests exemption from 14 CFR

. 91.417 because sUASs will not have airworthiness certificates. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. An equivalent level of safety will be achieved by Global Positions, LLC by keeping m aintenance records for its sUAS and following manufacture’s recommendations for service and repair

.

14 CFR 61.195 : Defines the requirements for flight instructors and states flight instructor limitations and qualifications. Global Positions, requests an exemption from 14 CFR
61.195 because it is our understanding that none of the s UAS operations proposed by
Gl obal Positions, LLC require such flight instruction as § 61.31(l) permits operation of the UAS by an individual who is up
- to

- date per 14 CFR § 61.56 (Flight Review) without a category and class rating. Instruction provided toward obtaining the pilot certificate required by this exemption would need to be provided by a certificated flight instructor. Global Positions, LLC will reach an equivalent level of safety by reviewing and understanding maneuvers and procedures necessary for the pilot to demonst rate the safe exercise of sUAS flight. DJI’s flight simulator may be used to for flight review and training for performing practical flight tests and general procedural flight operations

.

Conclusions : Currently, knowledge of geography, spatial awareness, aerial filming
, aerial videography/photography, and data collection for mapping relies primarily on the use of larger aircraft running on combustible fuel . Because these aircraft are heavy and carry combustible fuel, they pose potential risk to the huma ns, other forms of life , and property.

Granting Global Positions, LLC request for exemption will reduce existing risk levels and thereby enhance safety. Global Positions, LLC s UAS does not contain potentially explosive fuel, is lighter , smaller, and more controllable than conventional fixed

- wing
aircraft. There are no humans or animals on board Global Positions, LLC UAS and the likelihood of death or serious bodily injury is significantly diminished. Global Positions,Request for Exemption: Global Positions, LLC Page 19

LLC operation of its UAS, weighing les s than 10 pounds and travelling at lower speeds
within limited areas will deliver an equivalent level of safety as that attained under
current FARs. The sUA S piloted by Global Positions, LLC will operate at lower altitudes and in controlled airspace therefore removing potential risk to the public.

Global Positions, respectfully request the grant of an exemption allowing Global Positions, LLC to operate remote controlled UAS’s. Granting the requested exemption will benefit the public interest as a wh ole in many ways. Global Positions, LLC is willing to cooperate in sharing information and experiences to benefit the FAA.

Respectfully submitted,

Jere P Folgert Global Positions, LLC 3215 Warbler Way, #5 Bozeman, MT 59718 (406) 580 1314 Jfolgert@GlobalPositions.com