) I The Simple Life LLC. 535 S. Zerex Street Unit C-205 Fraser Co 80482 Box 3364 Winter Park Co 80482

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 January 5, 2015

;

.)

Re: Petition ofThe Simple Life LLC (SL). for Exemption Pursuant to Sectiorl333 ofthe FAA .Modernization and Reform Act of2012
,/,:·;:·--·:-\ Dear Gentlemen: 

## !/ )**~** '\

..... 

# "'":

../,**/-;~:_.,.,,** Pursuant to

### Secti~fi<333'S)Ithe FAA Modernization and Reform Act of2012 ("FMRA") and 14 C.F.R. Part 11,**Tli~.:~#p}~(Life** LLC ("SL") hereby applies for an exemption from Federal Aviation**Regulation~-{'-~EA.Rs',J)** identified below, to allow commercial operations of

... t' ./'./ .•. small, unmanned aerial vehicles by; and t4t'ough small unmanned aerial systems ("sUAS"). 

### y'/1/<'>\ " /'· This exemption is requested

### i~**subje~t}~'(.lnd** in conformance with those operations and protocols outlined in this Petition, the enclosed SL' Flight Operations Manual ("Flight Operations Manual") 1

, the sUAS

### Operato~:.~·:H~ndl>O~~, which includes component parts manufacturers' operations and/or

### instructions.fl1ab:q~Js:(:'pperator's Handbook") and any other requirements established by the FAA pursuant**to,~~e~~~~·** I. 

### Description ofPetitioner
, (/

# f/>.~ 

# /'·;,,

'·/ /_../ .,) The Simple Life LLC is a Colorado corporationthat

# t?:~viyi(sa-:wjde range ofReal Estate, videography and Photography services.

### <'~:-<~~·'j/ 

## /

.. II. Statutory Authority 

# z1.:/.**'···~}·** This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 ofthe Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion ofthe formal UAS rulemaking, based on the following considerations:

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

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

1 The Flight Operations Manual contains confidential, trade secret and proprietary information that the Petitioner has not and will not share with others. Petitioner submits the Flight Operations Manual and all information contained therein as proprietary and confidential information pursuant to 14 C.F.R. § 11.35(b). The Flight Operations Manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom ofInformation Act, 5 U.S.C. § 552 et seq.U.S. Department of Transportation February 18, 2015 Page 2



### • Operation ofthe UAS within the visual line ofsight ofthe operator

.
Ifthe Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the National Airspace System".
Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C.§ 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716, et seq.). A party requesting an exemption must explain the

reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existing rules). See 14 C.P.R. § 11.81 (p,etrtiqns for exemption).
I, ) (./ 

### III.

### Qualificat~«;)nsf~~ Approval Under Section 333 ofthe FMRA \·., ,/·/ /' The proposed**opera1Jofis/~ii.this** petition for exemption qualify for expedited approval /r / /• under Section 333 ofthe Reform;·Act:·Each ofthe statutory criteria and other relevant factors • fi .· 1// /;F<

. are satls ted.**~/** /,<. 

### ··<> 

### (/ "<:> /)

/'// ,./'., The proposed operations would**p~~~'lhe:use** ofsmall and relatively inexpensive UAS under controlled conditions in airspace thaf is: (V) li}llited; (2) predetermined; (3) controlled as

. ' ' ' / 

## " to access; and that (4) provides an increasectlevel/6fsafety beyond that existing when fixed or / ' ' rotor wing aircraft are used to accomplish the**s~e··P.JliJ?ose.**
' 

### ' / ·.**~·-.** /·/. Petitioner's sUAS are rotorcraft and

## fixed-~ti~,**~Yrghir~g** 45 or fewer pounds including payload. The rotorcraft operates, under normal conditioh'S·; atJow.:speed and have the capability to hover, and move in the vertical and horizontal plane.**T~e fix~.~Wing**  operates, under normal conditions, at low speed and moves in the horizontal plane.**Petitione(s~U-ASs** will operate in line of sight and will only operate within those areas described

### i~**·tlie~~rtcl<;,s~d** Flight Operations M 1 1/ --··**~.** 

## 0#

.,.,::..,

......**<~--,_.** Given the small size ofthe sUASs involved and the restricted environment within which they will operate, this petition exemption falls within the zone ofsafety 

### i.e., an equivalent level ofsafety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion offormal rulemaking. Also, due to the size ofthe sUASs and the restricted area in which the sUASs will operate, approval ofthe application presents no national security issue.
Considering the clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended, the equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, the grant ofthe requested exemptions is also in the public interest.U.S. Department of Transportation February 18, 2015 Page 3

Accordingly, Petitioner respectfully requests the FAA grant the requested exemption without delay.



### IV. Proposed Operations

The enclosed Manuals describe, in detail, the policies and procedures for Petitioner's proposed sUAS operations. To assist the FAA in its safety assessment ofPetitioner's proposed

sUAS operations, below is a summary ofoperational limitations and conditions, which will

ensure an equivalent or higher level ofsafety to operations conducted under current regulatory guidelines:**/?~'·** 

### (l' )) 1.

### Th~:§:lJ~~wi~lJ weigh less than 45 pounds. 

### I{**X~** 2. Flights

### ~ill::b'{dP,'brated within line ofsight ofthe Operator.**,~?/I·** ,./> <;i/ 

## rl/;:/**.~~** 3. Maximum

### total\:flignf~i¢e for each operational flight will be limited to the v /'•"i<'-.**~}** amount oftime tne sUAS&an be flown and still maintain a reserve battery /· power ofno less than

### Y.>/~ 4. Flights will be operated

# ~~~:u~alt~thd~ ofno more than 500 feet above ground level ("AGL").

### d"'·"~'-'0

.

## ~~-,**~** 5. Flights will be operated at a safe

### Yateta;l/9i~{~~e from, and not directly above, any inhabited structures, buildings, veijicles,"ye'sJels, or people not associated with

### t~e operation or who have not

### signe<J;;'·~a}~er in advance ofthe operation.

### <fYct~ 

## ....::-".e:;:::;. 

### ".? ¢**~-J/** .·'> 6. The sUAS Pilot with Pilot in Command

## responsibQ;fi~/ror the flight will be the designated Operator ("Operator").

### ~
7. The sUAS will operate only within confined areas as described in the Flight Operations Manual.

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be present for this briefing.

9. The Operator will have been trained in operations of sUAS generally and received up-to-date information on the particular sUAS to be operated as required in the Flight Operation Manual.U.S. Department of Transportation February 18, 2015 Page 4

10. Written and/or oral permission from the relevant property holders will be obtained.

11. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

12. Ifthe sUAS loses transmission signal, the sUAS will have the capability to return to a pre-determined location and land.

13. Contingency plans will be in place to safely terminate flight ifthere is a loss oftransmitter communications or a loss ofGPS signal.

14.**Th~:BUJ\S** will have the capability to abort a flight in case ofunpredicted obstacles or emergencies.

i \
__,,**""·~',** ·:_:--.**~~--- -~**  

### V.

### Regulatio~~**Fr~~_)Yhich** Exemption is Requested ."':::::-::<//,/! The Federal Aviation

### Mt/~~Rt:e's~ly grants the FAA the authority to issue exemptions. This statutory authority, by its**tetnis,,(~ci~des** exempting civil aircraft, as the term is defined under 

### § 40101 ofthe Act, including

### sUAS~,<from its safety regulations and minimum standards when the Administrator decides a**request¢'d}~X'emption** is in the public interest.**(/~/** 

### )'>
Petitioner seeks an exemption from

## '~ey~r~l~inte:g_elated provisions of 14 C.F.R. Parts 21, 45 and 91 for purposes ofconducting

### inspectio~'using"sUASs. Listed below are (1) the specific sections of 14 C.F.R. for which exemptidp.

### i~ts~ught, and (2) the operating procedures and safeguards that Petitioner has established

### which~hi.~n:Sill:~,a level ofsafety better than or equal to the rules from which exemption is sought. (/ /

### ~;:>~

/_,/ /-:> A. 14 C.F.R. Part 21, Subpart H-

### Airworthl~ess~Cer,ti(icates and 14 C.F.R.

§ 

### 91.203(a)(1)

### <~~~\Jy/ 

## p

I,_, /./ Petitioner seeks an exemption from 14 C.F.R. Part 21,

## s'it~p~rt H, which establishes the procedural requirements for the issuance ofairworthiness cerifficates as required by 14 C.F.R.



### § 91.203(a)(1). Given the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an exemption from Part 21, Subpart H, meets the requirements ofan equivalent level of safety under Part 11 and Section 333 ofthe Reform Act.

The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS.U.S. Department of Transportation February 18, 2015 Page 5

In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe as, or safer than, a conventional rotorcraft operating with an airworthiness certificate without restrictions and conditions ofthe proposed sUAS operations.


### Equivalent Level ofSafety

The sUAS to be operated hereunder, DJI Innovations S800 multi-rotor rotorcraft, weighs less than 35 pounds with payload, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and sterile area. Unlike other civil aircraft, the proposed operations will be controlled and monitored by the Operator pursuant to the Flight Operations Manual's requirements. /: //' These safety enhancements, which already apply to civil aircraft operated in connection wfth:existl.ng'inspection operations, provide a greater degree ofsafety to the Petitioner's

### emplot~:_s,$%]Jers ofthe public, and property owners than conventional

/- !

. ' operations conducted with ail)Votjhiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, applicat1ori

## .of these same criteria demonstrates that there is no credible threat to national security

### p"os~d'by**t~~~sUAS,** due to its size, speed ofoperation, lack of explosive materials or flammable Jiqmd/,fqels, and inability to carry a substantial external
.( ,•' // \ load. "**/,~** .' ···-;\, /l/'**~,,~~~~~·· f~l**  , '**·,·~<:** ' 

### B. 14 

### C.F.R. Part 27**Airworthine$'s'St~ndards:** 

### Normal Category Rotorcraft**·----~,** 

# './/< 1
14 C.P.R. Part 27 sets forth the

### procedlifalrequi~bp1ents for airworthiness certification ofnormal category rotorcraft. To

### the:,extent~the.,Petitioner's sUAS would otherwise require certification under Part 27,**Petitiort~fsee~~an** exemption from Part 27's airworthiness standards for the same reasons identified in_.$.e exemption request <'/**./'/~·** /1 from 14 C.P.R. Part 21, Subpart H.**<(>-~<)'/** 

# /**:·~** I**~</..,** ,.-" 

### C. 14 CFR § 

### 61.113: Private Pilot Privileges And**Limt~tions ·-......\_~).**  Petitioner seeks an additional exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also have the effect ofrequiring a second class medical certificate.


### Equivalent Level ofSafety

In Grant ofExemptionNo. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a Operator with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Additionally, as previously determined by the Secretary of Transportation, the requirement to have an airman certificate ameliorates security

concerns over civil UAS operations conducted in accordance with Section 333. The siteU.S. Department of Transportation February 18, 2015 Page 6

surveys and structural inspections conducted by SL occur in areas where access to the public is strictly limited and controlled. Under virtually all circumstances, all ofthe only property or structures are owned and operated by the same entity. As a result, the operation has no substantial impact on any third persons not involved in the inspection.

Because SL will operate in a sterile area, the sUAS will be flown based on visual line-of-sight at altitudes below 500' AGL. Accordingly, SL request that this exemption be granted.

C.14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

Petitioner seeks an exemption from the aircraft marking and identification**requirements 9'6iita~!led**  in 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a).
,( .f 14

### C.F.:R:~:§· 9l::;9(c), Civil Aircraft Flight Manual, Marking and Placard requirements,

### pro~ides tllat:..._ \'-, // /··'**'=~~"** > / /:;• 

### i No person may

## op~r,!~f4~~.-registered civil aircraft unless that aircraft is identified in accordance**wi!h/~.a;ij4~\of**this chapter. /

..,.... ..; <../ ''<> /) Equivalent Level ofSafety

# o

.. /"/**--~** 

# ...**·0~·--**

"'- f /

.....

/ /' )

.. ' <</ 1 The equivalent level ofsafety

## Ior~~:(~~pttpps to the aircraft marking and identification requirements of§§ 91.9(c**),:45">2~.(b)~nd** 45.27(a) will be provided by having the sUAS marked on its fuselage as':requtted by§ 45.29(£).
'\'> /·/ .'I
,., 

### The FAA

### has previously issued the

# fol~:~i4~;~)~ipns to the aircraft marking requirements of§ 45.23(b): ExemptionNos. 10700, }Or67 apd 10167A. /- ...,-,**~~-** '

..**~_..~::~i** ' D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight**Man(i~~tin**JJ;le Aircraft**),~/** Petitioner seeks an exemption from the flight manual

# re~dj(~:nents of 14 C.F.R. § 91.9(b)(2), which states:**"";~'>** (b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings and placards, or any combination thereof.

Given its physical dimensions, configuration and load capacity, the sUAS has no ability to carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simply no room or capacity to carry such an item onthe aircraft.U.S. Department of Transportation February 18, 2015 Page 7



### Equivalent Level ofSafety

The safety related purpose ofthis manual requirement can be equally satisfied by maintaining the sUAS flight manual at the ground control point where the Operator will have immediate access to it. Accordingly, Petitioner requests an exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the sUAS flight manual be available at the control point during each operation.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299,9299A,9565,9565B, 10167, 10167A, 10602,32827,and 10700.



### E. 14 C.F.R. § 

### 91.7(a): Civil Aircraft Airworthiness 

### /**;;;=-::::::.~\** Petitiotxer sedks an exemption from 14 C.F.R. 

### § 91.7(a), which requires that a civil aircraft be in \iirw<?rtliy:cBndition to be operated. Inasmuch there will be no airworthiness certificate issued 

### f9l the/§UAS, should this exemption be granted, no FAA regulatory standard will exist for:dete"rnlining airworthiness.**/..~/'** 

### II /)

. ·/ ; '/,r/ 

### />· Equivalent Level**o(.S~f~~y ~~)**  .,;/**'"~** ,;;.' // /' The DJI Innovations S800**9-~S:a/~tel!~r** safety record, demonstrating that the sUAS is airworthy. Further, given the

### size~{t'the/~~~S and the requirements contained in the Flight Operation Manual for maintertanee**an~:rpf~-flight** safety check lists, an equivalent 

### level ofsafety will be provided. 

# <("\,**~ ~·t:'/'l/**  

## #

The FAA has issued the following

# exem;ti~~{~~SJegulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167{,10167-:A, 10602, 32827, and 10700. ,¥,

### ~~·50 

### <...--'""'<':-1/ /) F. 14 C.F.R. § 

### 91.103: Preflight Action 

# Z/({//

Petitioner seeks an exemption from 14 C.F.R. 

### § 91.103, w'ilich requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved flight manual on board the aircraft. While the Operator will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved flight manual is required on board the aircraft.


### Equivalent Level ofSafety

An equivalent level ofsafety will be provided by following the Operator's Handbook. The Operator will take all required preflight actions

- including reviewing weather, flight battery requirements, landing and takeoffdistance, and aircraft performance data

- before initiation offlight. The Operator's Handbook will be kept atU.S. Department of Transportation February 18, 2015 Page 8

the ground station with the operator at all times.

G.14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. 

### § 91.109(a), which provides that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." sUASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa box that communicates with the aircraft via radio communications.
Equivalent Level ofSafety

Given**~~Gsizf** and speed ofthe sUAS, an equivalent level ofsafe training can still be**performed~**without dual controls because no pilot or passengers are aboard the sUAS, and all

### person~:WiU;6e~~.afe distance away in the event that the sUAS experiences any difficulties during;flight instruction.**\--,-<~':** 

### ,/,. )
The FAA has

# ~~p~~~d/e£emptions for flight training without fully functional dual controls for a number of

### aitct~:f{~'a~for flight instruction in experimental aircraft. Exemptions include: Nos.**57~78K~ilnd-9862A.** 

## /.)///A
H.14 C.F.R. § 91.119:

# Mi~-fi~~fe Altitudes '•,'- /'.' /·


### Petitioner requests an

# exempti~~-t4~~mwn safe altitude requirements of 14 C.F.R. 

### § 91.119. Section 91.119 prescnh,e.s tl}.{tpinimum safe altitudes under which aircraft may not operate, including 500 feet 

## ab'6ve,1 thistl:rface and away from any person, vessel, vehicle, or structure in non-congested

### are~l,~{~Se7J)4~.F.R. § 91.119(c). Section 91.119(d) allows**f~r** a helicopter to operate at less**th'}h/th~se~ininimum altit~des**  when it

can be operated "Without hazard to persons or property**9:9-:~8:;§/~face,"** prov1ded that

-

.......- . .._,._, / /0 "each person operating the helicopter complies with any**route~,or/~Hfitudes** specifically prescribed for helicopters by the FAA."

### >~ ((**-,~** To provide the intended inspections, the sUAS is normally operated below 500 feet AGL. Additionally, due the nature ofthe proposed operations, the sUAS will maintain a safe lateral distance from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.
Equivalent Level ofSafety
Comparedto flight operations with rotorcraft weighing far more than the maximum 3 5 pounds proposed herein, and given the lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated. As set forth in the Flight Operation Manual, theU.S. Department of Transportation February 18, 2015 Page 9

sUAS will be operated in a restricted and sterile area, where buildings and people will not be exposed to operations without their pre-obtained consent. Because ofthe advance notice to the property owners and participants, all affected individuals will be well aware ofthe planned flight operations as set forth in the Flight Operation Manual.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record ofthe DJI S800 demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments.



### I. 14 C.F.R. § 

### 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, whichrequires a person operating an**~1rcraft** to maintain cruising altitude or flight level by reference to an altimeter tha(is**set-~to** the elevation ofthe departure airport or barometric pressure. An exemption

### is\requirea:-be~ause the sUAS does not have a barometric altimeter, but rather a GPS altitude read

### ~\~t.**~/)**

### /0**~<~:::::</'.**/

..**-~~.'** l
// '' /'> 

### EquivalentLevel'!of $.af1Jty,
,
An equivalent level

# f~~J:l be achieved by following the procedures set forth in the Flight Operation Manual.

### A~;P~e.jcti})ed in the Flight Operation Manual, the operator will confirm the altitude<o{-"tne la#c!J: site shown on the GPS altitude indicator before flight. Moreover, the**Operator~-:wHl"us~tQ:((** GPS altitude indicator to constantly monitor the sUAS's height, thus

### ensurinw6p~rati8n.at safe altitudes.**'·,~~'>** v 

## f.J/ ' ' J. 14 C.F.R. § 

### 91.151(a): Fuel Requirelite#!s:fur,:J(Iight in VFR Conditions f**'~/** / ··'·,

""' // '>.,) Petitioner requests an exemption from 14**C.F.~§ 91,~~51(a)'s**  fuel requirements for flight in VFR conditions. Section 91.151 states: 

# ij;.::{jl

(a) No person may begin a flight in an airplane under

## VFR.,~ditions unless (considering wind and forecast weather conditions) there is

### eno~gh fuel to fly to the first point ofintended 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.

Here, the battery powering the DJI Innovations S800 provides approximately 15 minutes ofpowered flight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location ofits proposed operations within a predetermined
area, a safety margin based on a reserve amount ofbattery life is needed. Petitioner will
not be conducting any sUAS flights at night.U.S. Department of Transportation February 18, 2015 Page 10



### Equivalent Level ofSafety

An equivalent level ofsafety will be achieved because the operations will be conducted on-site without significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event ofan unexpected occurrence. Operation ofthe sUAS with less than 30 minutes ofreserve fuel does not include the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS, and the proximity ofthe flight operation to the landing

zone.

This request for exemption falls within the scope ofprior exemptions, including Exemption**~<!sff0~73,** 2689F, 5745, 10673, and 10808. 

### 1/**~~**
\\ <**---~.** 

### K.14**C,~F:R,.~§91~~03(a)** 

### and (b): 

### Carrying Civil Aircraft Certification and Registration (( ))

.
Petitioner

# se~~mj)tion from civil aircraft certification and registration requirements of 14 C.F.R.

### !§':91;~~3{~) and (b). The regulation states in pertinentpart: (> '<> /_:.

# _(a~**E~cept** as

# pro~ided**in§(~~~** person may operate a civil aircraft unless it
has W1th1n 1t the follow1ng: 

# <<-...--"/)./**/.~:><."'** ..**-~ -~-** **/:.~:,.** 

# '" ( 1) An appropriate and current

### airwortiUne.~s/certificate... ""'' v

../.. ;

''\,'·'\... //?I

'.> / / ; i /., (b) No person may operate a civil aircraft**·~le~s"t~~,.airworthiness** certificate required by paragraph (a) ofthis section or a spec'ia'l

### fligpt·~uthorization issued under 

### /)/**'~"** 

### § 91.715 is displayed at the cabin or cockpit

# en'~~)'lj1tt it is legible to passengers or crew. ·

### <::'/"-..Y. /. // 

## (/h// In addition to the fact that Petitioner is seeking an exemptl6n from the ".,;"., airworthiness certificate requirements, an exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacity and size does not allow it to carry certification and registration documents; (2) the sUAS does not have a cabin or cockpit entrance at which documents could be displayed; and (3) there are no passengers or crew for whom the certificates need to be displayed.U.S. Department of Transportation February 18, 2015 Page 11



### Equivalent Level ofSafety

To the extent these regulations are applicable to the proposed sUAS operations,

an equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the Operator will have immediate access to them.

The FAA has issued numerous exemptions to this regulation, including: Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.



### L.14 C.F.R. § 

### 91.405(a), 91.407(a)(l), 91.409(a)(l), 91.409(a)(2); 91.417(a) and (b):

### Mainte.,ait~~~l~spections .1 ( ) i
·,\ ""-!

## Petitiori~t-als6:fe6k's anexemption from the maintenance inspection requirements contained in 14 

### C.F\.R.**?'1~.405(a),** 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and (b). These**regtilaftQiyS~spesiry** maintenance and inspection standards in reference
to 

### </'. ·' .: /·.· ///

. .r·

'· v/

-- /<'· 14 

### C.P.R. Part 43. See,**e.g~/1}!(~**.. 

## f:k. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have tne'**aircr~f}1nS,pected** as prescribed in subpart E ofthis part and shall between required inspectfons<?:llave discrepancies repaired as prescribed in part 43 ofthis chapter"). An

### exe~pt{<;)~**tq;th~se** regulations is needed because Part 43 and these sections only apply to

### airc~hfC\\i~t(_an>~irworthiness certificate, which the sUAS will not have. 

# <(**'-.,~,** 

# ·/--\

"-'\.. /./! ,'

"..·' /,**·~>**

### (~ i··.l /. "'' It//**"'~** 

### Equivalent Level ofSafety

I /**(~'** <.0, An equivalent level ofsafety will be achiev:d

# ~~usffuaintenance and inspections will be performed in accordance with the

### Op/r~toJ~f;Handbook as referenced in the**<.:;-·-~~I** /,) Flight Operation Manual. As provided in the Flight

### Operatiorr:M~riual, the operator will ensure that the sUAS is in working order prior to initiatin{tlight, perform
'\'>) required maintenance, and keep a log ofany maintenance performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Ifmechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limited periods oftime during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation.



### VI. Public Interest
Granting SL's exemption request furthers the public interest. National policy set byU.S. Department of Transportation February 18, 2015 Page 12

Congress favors early integration ofUAS into the national airspace in controlled, safe working environments such as those propose in this petition. In addition, maintaining industrial safety has been a priority of state and local governments for decades.

By their nature, structural inspection sites present unique difficulties for persons attempting to inspect and maintain the structure. The components can be tall and have limited

access. Sending a human observer or using helicopters to inspect such elevated structures carry certain risks. These risks can be avoided by using a small UAS under controlled conditions to photograph and document the state ofthe equipment. This helps to facilitate repairs and identify issues before they become problems. Current options for inspecting structures is**li~ited** to using**hum~erso~el.** Inspectors will either use a normal**~~tor** wing mannedarrcraft or crane**ba~J<ets"'tR** rmse a human observers to an elevated position. The use ofan sUAS reduces the fisk to'blJP!an life by removing them from dangerous aspects ofthe inspection**process.\~_:}~~~----~~\** ,f r! \\**~/** /> In addition,

### grantin'~'llie~ei9~pti9n will help advance the knowledge base for conducting

## ~ommercia~**UAS<'ripe~~!i~!l~<Jhis** additional data will

## ~elp**t~e** FAA set

## fu~ure rules regarding UAS fhght operatiOJlS/maintenance, and crew qualifications. The pubhc also has an interest in reducing the hazatds .dnd"(missions associated with alternate use of helicopters to conduct similar

### inspectio~r6P.,~{atl9ps. The UAS in question is very light weight and does not carry any flammabledi.iel, fUrther reducing the risk from any potential accident. '\'>.:**.::::..-~/ ".,~~** **/~** v \**-,~ ~**  

### VII. Privacy**.,.,~** /,/jl 

## (/I'**1>~~>-** /,/ 

### ,, All flights will occur over property with the

### prop~ri)r**o/~~iYs**..prior consent and knowledge. .:)/ /(//

_ 

### VIII. FederalRegistry Summary

# :C~J)'; 

# //'
l/ //**(!~/·** Pursuant to 14 C.F.R. Part 11, the following summary is**provide~** for publication in the Federal Register, should it be determined that publication is needed: ·.¢

The Simple Life LLC seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(l); 14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b).
Approval ofthese exemptions allowing commercial operations ofsmall and lightweight unmanned aircraft("sUAS") to conduct structural inspections will enhance safetybyreducing risk to SL's employees, the general public and property owners.

The DJI Innovations sUAS, weighing less than 35 pounds, with payload, and powered by batteries, eliminates virtually all ofthat risk given the reduced mass and lack ofU.S. Department of Transportation February 18, 2015 Page 13

combustible fuel carried on board. The sUAS is transported to the designated survey area set up. It is not flown from an external location to the work-site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation ofthis small UAS will provide an equivalent level ofsafety, supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, and in a controlled environment. As a result, they

are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.



### IX. Conclusion 

# f?**-~** Satisfaction

# &t:l~teria provided in Section 333 ofthe Reform Act of2012-size,**""·~** ,..,.,,, ..**~** ./'**,~ ~**  ... . :-

.... weight, speed, operating/capabilities, proximity to airports and populated areas and operation within visuall1ne

### oJ/J;igh~ and national security-provides more than adequate justification for the grant

### 'ati}\eie**qu~_sted** exemptions to permit The Simple Life LLC to operate sUASs in support of

## its**s_i~~:s4rv~~s** and structural inspections, teaching and videography in accordance with theJl}tght;Operation and Operator's Handbook appended (/ ·..,) /,'' hereto. · /;/ 0 . / ,.·**~-''"\\** Granting the requested

# exemptio~,~~ilhe_n]fit..the public interest as a whole in many ways, including (1) significantly

### improving<safe.,.i)(~ii'tl~,educing risk by alleviating human exposure to danger, (2) improving the inspectioij:process"and decreasing operating costs, and (3) providing an environmentally conscientious

### WayL9:f~~nst)l~ting site surveys and structural inspections, and (4) providing the general public a**plac~Lt§'pr~pxrlY** learn about sUAS, and (5) utilizing this technology to capture video and stills foc**~a:fketil)g** purposes.**<>/~<-/** / -·-<.0 ·/·**..,.-/~,/'!/**

<:,:>,, / 

### /)'>

., 1 / ) (' '' '.I /:r/ VI'/' Sincerely,**·--,:::~**

Parnell Quinn