### 1 IN THE MATTER OF THE PETITION OF

EXEMPTION OF AERIAL SOLUTIONS FOR AN

EXEMPTION SEEKING RELEIF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS SECTIONS:

333 EXEMPTION DOCUMENT

CONCERNING COMMERCIAL OPERATION

OF 3DR SOLO & 3DR AERO M

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM

ACT OF 2012 (PUBLIC LAW 112

- 95) Dawnstar Exploration LLC

Jeremiah Jolliff

### 2 

## Table of Contents

SUMMARY

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

PROPOSED OPERATIONS of D awnstar Exploration LLC

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

THE 3DR SOLO & 3DR AERO M

................................ ................................ ....................... 3
Specifications of the 3DR SOLO

................................ ................................ ................................ ...... 4 Specifications of the 3DR AERO M

................................ ................................ ................................ 5



### THE OPERATOR

................................ ................................ ................................ ..................... 6

OPERATING PARAMETERS

................................ ................................ .............................. 6

REGULATORY STATEMENT

................................ ................................ ............................ 6

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(a))

........................ 6

SECTIONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR WHICH

RELIEF IS SOUGHT

................................ ................................ ................................ ............... 7

Part 61

................................ ................................ ................................ ................................ .................... 7

Part 91

................................ ................................ ................................ ................................ .................... 7



### EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))

................................ .................. 9

STATEMENT OF PUBLIC INTEREST

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

REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT PUBLIC SAFETY (14 C.F.R. § 11.81(e))

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

FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(f))

................................ ........ 12

ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.8 1(g))

.................... 13

Proposed specific operating limitations

................................ ................................ ............. 13

CONCLUSION

................................ ................................ ................................ ....................... 16

### 3 

## SUMMARY

Petitioner, Dawnstar Exploration LLC., is seeking exemption from the requirements of Title 14 of

the Code of Federal Regulations (C.F.R.) Part 61 Sections 61.113(a) and (b), Part 91 Sections 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) in order to commercially operate the 3DR SOLO & 3DR AERO M for the purpose of aerial survey and photography in support of ag ricultural operations , surveying

, civil

e ngineering services, infrastructure inspections, power out age surveying, real estate photography

.

This Petition is submitted in accordance with the authority found in Section 333 of The FAA Modernization and Reform Act of the 2012 and Title 14 C.F.R. Section 11 Subpart A.



## PROPOSED OPERATIONS of Dawnstar Exploration LLC

Dawnstar Exploration LLC is seeking an exemption that will permit it to perform aerial photography and surveying services for property owners, individual farmers, agribusinesses, surveying \ engineering companies, infrastructure, contracts

, and insurance \ finance companies. These services would be used to provide information and enhance decision

- making abilities through aerial based surve y and photography.



## THE 3DR SOLO & 3DR AERO M

The 3DR SOLO & 3DR AERO M are pl atform s for aerial photography and videography. They

include camera s ideal for virtually any application and flight times that run as high as 2 3 minutes

and 40 minutes

, respectively

The 3DR SOLO comes with a 2.4 GHz transceiver that offers precision control of images and

f light with the ease of a 3DR SOLO application system. Actual Direction Control, Return Home and programmable w aypoints provide pilots with tools allow ing the Operator to focus on creative vision and flight control.

The 3DR AERO M i s a fixed wing aircraft and comes with a DX7s radio control Grou nd station

radios in 433 or 915 MHz . The 3DR AERO M is used for aerial survey and mapping purposes and makes use of the Pix4Dmapper Mosaic 3DR Edition software.

### 4 

### Specifications of the 3DR SOL O
Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4 Streaming video quality: 720p Flight time: 25 minutes; 20 minutes with payload* Range: .5 miles** (.8 km) Max speed: 55 mph (89 km/h) Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode Max descent speed: ditto Max payload: 420 g Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV Propellers: 10 ′′ diameter 4.5 ′′ pitch self

- tightening (24 cm diameter 144 cm pitch); glass

reinforced nylon Autopi lot: Pixhawk 2 Software: APM:Copter

Communication: 3DR Link secure WiFi network Frequency: 2.4 GHz Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor

- to

- motor Flight battery: Lith ium polymer 5200 mAh 14.8 Vdc Battery charge time: ~1.5 hours Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion App requirements: iOS 8.0 or later / Android 4.3 or later

### 5 

### Specifications of the 3DR AERO M
Pixhawk autopilot system Motor: Tiger Motor 2820 830 kV Propeller: Gemfan 11x7 Flight battery: 4S 6000 mAh 35C LiPo Aircraft weight with battery: 6.8 lbs (3 kg) Aircraft dimensions: 74 in (188 cm) wingspan, 51 in (129 cm) length Case dimensions: 60.75 in x 14.5 in x 15.5 in (154 cm x 37 cm x 3 9 cm) Payload capacity: 1.1 lbs (500 g) Radio range: 1 km Flight time: 40 min Maximum operational wind conditions: 25 mph Area coverage: 250 acres (1 km 2 ) Ground sampling distance: 2 inches per pixel (5 cm per pixel)* Orthomosaic accuracy: 3

- 16 ft (1

- 5 m) Henge MD933 servos Dubro control linkages External LED indicator and USB port Digital airspeed sensor Minimum speed: 22 mph (9.8 m/s)

### 6 

## THE OPERATOR

The proposed Operator, defined as the person who manipulates the controls of the System, would hold, at minimum, a Private Pilot Certificate. To the extent the operation would dictate , the Petitioner proposes that the Operator would have the ability to augment the crew with a visual observer (Observer) to assist with scanning for hazards and maintain awarene ss of the 3DR

SOLO & AERO M’s precise location, as noted in proposed Part 107

.



## OPERATING PARAMETERS

Dawnstar Exploration LLC is committed to the safe and compliant operation of the System at all

times. Because the 3DR aerial platforms doe not carry c rew or passengers on

- boa rd, are small, light , and slower than manned aircraft. T he Petitioner seeks relief from several aspects of 14

C.F.R. Part 91. Before each operation, the Operator will inspect the System to ensure that flight operations can be conducted safely and in accordance with instructions provided by the manufacturer. Operations will be primarily in rural areas, and over private property. All operations will be conducted in Class G airspace, or in compliance with Certificate of Waiver or Authorization (COA) obtained through the Air Traffic Organization (ATO).



## REGULATORY STATEMENT

In accordance with the FAA Modernization and Reform Act of 2012, Section 333, entitled Special Rules for Certain Unmanned Aircraft Systems, and 14 C.F.R. §§ 11.6 1(b) and 11.81, the

Petitioner submits the following:



## PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(a))

The name and address of the Petitioner is: Dawnstar Exploration LLC

P

. O. Box 146 Camden, Ohio 45311

The point of contact for purposes of this Petition is:

Jeremiah Jolliff

P.O. Box 146 Camden, Ohio 45311

Tel. (740) 590

- 6329 jdjolliff@gmail.com

### 7 

## SECTIONS OF TITLE 14 CODE OF FEDERAL

REGULATIONS FOR WHICH RELIEF IS SOUGHT

(14 C.F.R. § 11.81(b)) Relief is sought from the following provisions of Title 14 of the Code Of

Federal Regulations:



### Part 61
§ 61.113 (a) and (b), which state: Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot c ertificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command

of an aircraft. (b) A private pilot may, for compensation or hire , act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or

hire.



### Part 91

§ 91.7 (a), which states: Civil aircraft airworthiness. (a) No person may operate a civil aircraft unless it is in an airworthy condition.

§ 91.119, which states: Minimum safe altitudes: General. Except when necessary for takeoff or landing, no person may operat e an aircraft below the following altitudes: (a) Anywhere a n altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be operated

closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conduct ed without hazard to persons or property on the surface

— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes spec ifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

§ 91.121(a), which states: Altimeter settings. a) Each pers on operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a sta tion along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the c ase of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92 ʺ Hg.

§ 91.151, which states: Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough

### 8 fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) Durin g 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 rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enoug h fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

§ 91.405(a), which states: Maintenance required. Each owner or operator of an aircraft

— (a) 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;

§ 91.407(a)(1), which states: Operation af ter maintenance, preventative maint en ance, rebuilding,

or alteration. (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a

perso n authorized under §43.7 of this chapter; and...

§ 91.409(a)(1) and (2) which state: Inspections (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has

had

— (1) An a nnual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of thi s chapter.

§ 91.417(a) and (b) which state: Maintenance records. (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, prope ller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certifi cate number of the person approving the aircraft for return to service. (2) Records containing the following

information: (i) The total time in service of the airframe, each engine, each propeller, and each

rotor. (ii) The current status of life

- limited pa rts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the me thod of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by

§43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section sh all be

retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

### 9 

## EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))

61.113 (a) and (b). Relief is requested to the extent necessary to permit the holder of a private pilot certificate, with at least a current third

- class medical certificate holder to conduct the proposed flight operations for compensation or hire.

91.7(a). Dawns tar Exploration LLC seeks relief from 91.7(a) to the extent that the 3DR system is not eligible for an airworthiness certificate under 14 C.F.R. 21 and therefore can not be airworthy

in the context of the regulation.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations and the limited capabilities of the System. Dawnstar Exploration LLC can ensure that each operation is

conducted within the requirements of 91.119(a) and is therefore not seeking exemption from that

secti on of the regulation. With respect to 91.119 (b) and (c) Dawnstar Exploration LLC seeks relief for two reasons. First, the small size and flight envelope of the UA, and the limited range of the System necessarily restrict operations to that of low level, l ow speed, line of sight operations.

The intent of the operations will primarily be survey and photography of property; commercial operation simply could not be done without exemption. Second, while not a manned helicopter,

the 3DR system is more analogous to a helicopter than to other aircraft, which a private pilot is permitted to operate at less than the minimums prescribed in paragraph (b) or (c) of section 91.119 so long as the operation is conducted without hazard to persons or property on the surface. 14. C.F.R. § 91.119(d).

91.121. Relief is sought from 91.121 due to the design of the system. While not possessing an

altimeter that can be set in compliance with the regulation, however the System contains GPS derived altitude capabilities. Dawnstar Ex ploration LLC is not proposing relief to the extent that the Operator is not expected to check the System settings prior to each flight.

91.151. Dawnstar Exploration LLC requests relief from 91.151 due to the limited design range

and associated battery storage ca pacity.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that 3DR

aircraft are not certificated pursuant to Part 21, nor issued airworthiness certificates, and due to the fact that the technology of the System is so different from traditional manned aircraft, the System does not fit well into the regulatory scheme of Part 91 Subpart E. As such Dawnstar Exploration LLC seeks relief fr om the above noted regulations. However, Dawnstar Explorations

LLC will maintain all m aintenance records related to the system. Dawnstar Exploration LLC does

not intend to document each battery replacement or charge, because the battery is analogous to fuel in manned aircraft, and documenting each charge would be as laborious as documenting each fueling of a certificated aircraft in that aircraft’s maintenance records.

### 10 

## STATEMENT OF PUBLIC INTEREST

(14 C.F.R. § 11.81(d)) The public benefits commensurate with the commercial operation of the

3DR UAS by Dawnstar Exploration LLC are numerous. By implementing this technology into the National Airspace System, the public’s interest will be served in that environmental impacts will be lessened, economies will be more efficient and relative public safety will increase. Being

small elect rically powe red s ystem s, environmental impacts are mitigated when used in place of

present ly approved manned aircraft operations. Because no fossil fuel is burned, the System itself

has a low impact on the environment . Th e low weight and tiny motors reduce fuel consumption, reduce noise and reduce the likely hood of other negative environmental impacts such as bird strikes and fuel spills. Because the System is sm all and quick to deploy , crops can be monit ored more closely for less cost. The need to dispense agri cultural chemicals can be further minimized. Infrastructure such as roads, bridges, pipelines, and power lines, can be quickly assessed without the need for heavy equipment such as trucks, cranes, hoists and aircraft that run on fossil fuels.

Additionall y, studies regarding all aspects of land use, soil, and topography become possible where they were previously restricted due to economic reasons. The information collected by Dawnstar Exploration LLC will have a broader environmental impact that will benef it society

. In support of commercial operations, the public at large will benefit from the information this system brings into the aerial survey market. 3DR UAS services in agriculture will allow farmers to have access to aerial based crop studies performe d on a more timely basis which will allow them to reduce input costs (f uel, fertilizer, chemicals, etc ).

In support of agricultural operations, 3DR UAS operation s will provide the American consumer

with lower food prices, better g rain and income from the export of agricultural products.

3DR UAS will also contribute to relief operations in an efficient way. Government Agencies will be able to align their teams closely at disaster sites . The use of 3DR UAS in disaster scenarios

will ensure tha t liv e s are saved and safety measures are efficient

. Dawnstar Exploration LLC hopes to help emergency response agencies if requested during these unfortunate and unforeseen

circumstances.



## REASONS WHY A GRANT OF THIS EXEMPTION WILL

NOT AFFECT PUBLIC SAFETY (14 C.F.R. § 11.81(e))

Dawns tar Exploration L LC is firmly convinced that these platforms will not affect public safety in any adverse way, but will in fact enhance safety

. With respect to the safe operation of the aircraft, the Administrator, in exemption No. 11138 has already evalua ted the technical specifications of similar aircraft. In noting their small size, limited speed and numerous safety features (such as low battery autonomous landing, lost

- link event autonomous procedures, auto

pilot and stabil ity control ), Dawnstar Exploration LLC believes that the Adm inistrator’s finding

that these s ystem s can be safely operated in the NAS system was correct.

In order to ensure safety, Dawnstar Exploration LLC wou ld utilize a certificated pilot as the Operator, and abide by common sen se operating limitations to ensure that the safety of the public is ensured. A list of proposed specific operating limitations is included in the additional

information section below. The Petitioner is only seeking relief from very specific regulations

tha t relate to the operation of these System s , and is suggesting specific alternative procedures to

### 11 ensure safety in lieu of those regulations from which Petitioner is seeking relief.

Dawnstar Exploration LLC further notes that by replacing certain ma nned op erations with operations conducted by this small System, public safety will actually be enhanced. In those operations where traditional manned aircraft are presently used, the public bears the risk of the crash of a much larger, heavier vehicle travelling at a much higher rate of speed.

Furthermore, many of those manned operations contribute to congestion in the NAS, increasing

risk of collision with other aircraft. Because 3DR UAS will be operated away from the airport environment, it will reduce the ris k of collision by manned aircraft. With respect to each particular regulation for which relief is sought, Dawnstar Exploration LLC believes safety is

insured:

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a private pilot certificate, with at least a current third

- class medical certificate holder to conduct the proposed flight operations for compensation or hire, or that the operator be properly trained in the

use of 3DR UAS within the limited area it will be operati ng. Dawnstar Exploration LLC notes that private pilots are allowed to operate aircraft for compensation or hire so long as doing so is incidental to their business and they do not carry passengers. This is done in much heavier, faster aircraft, which pose a greater risk to persons or property on the ground. In the case of the

3DR aircraft, through it’s limited speed and weight poses less risk to those on the surface. The fact that the very small UA will be operated in accordance with the manufacturer’s inst ructions and over limited parcels of land, combined with it’s limited range, negates the long cross

- country flying experience required for a commercial pilot certificate. Therefore Petitioner believes that an equivalent level of safety with respect to mann ed aircraft is met with a minimum certification

level of Private Pilot.

91.7(a). Dawnstar Exploration LLC seeks relief from 91.7(a) to the extent that the 3DR UAS is not eligible for an airworthiness certificate under 14 C.F.R. 21 and therefore can not be airworthy

in the context of the regulation. The Operator can, before each flight, determine whether or not the aircraft is capable of safe flight by visually inspecting the System, accomplishing appropr iate

pre

- flight inspections, and ensuring compliance with the manufacturers operating manuals and therefore an equivalent level of safety will be met.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations and the limited capabilities of the System. Dawnstar Exploration LLC can ensure that each operation is

conducted within the requirements of 91.119(a) and is therefore not seeking exemption from that

section of the regulation. With respect to 91.119(b) and (c) Dawnstar Exploration LLC seeks

relief for two reasons. First , the small size and flight envelope of the UA, and the limited range of the System necessarily restrict operations to that of low level, low speed, line of sight operations.

Combined with the intent of the operations primarily being the survey and photogr aphy of property; commercial operation simply could not be done without exemption. Second, while not a manned helicopter, the 3DR SOLO is more analogous to a helicopter than other aircraft, which a private pilot is permitted to operate at less than the min imums prescribed in paragraph (b) or (c) of section 91.119 so long as the operation is conducted without hazard to persons or property on the surface. 14. C.F.R. § 91.119(c).

With respect to operating the 3DR UAS over or near a structure, Dawnstar Explora tion LLC would like to point out that it is often more dangerous for those involved if a person were to, for example, fall off of a roof or a ladder, or drop a heavy tool such as a hammer, than it would be for

the 3DR to fall, so long as the Operator ensur es that he has permission from the owner and

### 12 requires that any structure the 3DR is operated over or near is not occupied, nor are people in the immediate vicinity, a high level of safety can be achieved.

Due to the Systems limitations with respect to sp eed and altitude, light weight, and ability to

maneuver like a helicopter (with an equally trained Private Pilot), and a restriction than any

structure flown over with permission, Dawnstar Exploration LLC respectfully submits that an equivalent level of sa fety is assured if relief is granted from 91.119 (b) and (c).

91.121. Relief is sought from 91.121 due to the design of the system. While not possessing an

altimeter that can be set in compliance with the regulation, an equivalent level of safety can be

m et due to the fact that the System contains GPS derived altitude capabilities, thus ensuring an equivalent level of safety. That being said, Dawnstar Exploration LLC is not proposing relief to

the extent that the Operator is not expected to check the System settings prior to each flight.

91.151. Dawnstar Exploration LLC requests relief from 91.151 due to the limited battery storage capacity. The Petitioner feels that a good balance of safety and utility can be met if the Operator is permitted to plan and initiate a daytime VFR flight to the first intended point of landing, at normal cruising speed which would require no more than 70% battery power. This System possesses several safety features with respect to power, including a low battery warning that first alerts at 30% remaining, and an automated landing function when a low battery is detected by the System. Should conditions change during the flight, this will leave 30% battery capacity to fly to a safe alternative landing zone.

91.405(a), 91.407(a )(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that 3DR aircraft are not certificated pursuant to Part 21, nor issued airworthiness certificates, and due to the fact that the technology of the System is so different from traditional mann ed aircraft, the System does not fit well into the regulatory scheme of Part 91 Subpart E. As such Dawnstar Exploration LLC seeks relief from the above noted regulations. In order to ensure an equivalent

level of safety, Dawnstar Exploration LLC will use t rained technicians to perform maintenance, alterations, or preventive maintenance on 3DR UAS using the methods, techniques, and practices prescribed in the manufacturer’s manuals. Dawnstar Exploration will maintain all maintenance records related to the sy stem.

Dawnstar Exploration LLC does not intend to document each battery replacement or charge because the battery operated systems are analogous to fuel in manned aircraft, and documenting

each charge would be as laborious as documenting each fueling of a certificated aircraft in that

aircraft’s maintenance records.



## FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(f))

Dawnstar Exploration LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)& (b). This exemption will permit Aerial Solutions LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial survey and photography

within the United States.

### 13 

## ADDITI ONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81(g))

Documents and Manuals

The documents and manuals for the 3DR UAS can be found at: https://3drobotics.com/

These documents are incorporated into this petition by reference. However, due to file size

limit ations they are not being attached.



## Proposed specific operating limitations

1. Operations authorized by this grant of exemption are limited to the 3DR Unmanned Aircraft System s

.

2. The UA may not be flown at an indicated airspeed exceeding 30 knots.

3. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC

must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at

all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

5. The operating documen ts and this grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between

the conditions and limitations in this exemption and the procedures outlined in the operating

docu ments, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s re sponsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if he petitions for extension or amendment to this grant of exemption. If the ope rator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

6. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight.

If the inspection reveals a condition that affects the safe operation of the UAS, the UA S is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be pr operly documented in the aircraft

records.

7. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who

conducts the functional test flight must make an entry in the aircraft records.

### 14 8. The pre

- flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sect ions of the operating documents.

9. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

10. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person ret urning the UAS to service.

11. Each UAS operated under this exemption must comp ly with all manufacturer Safety

Bulletins.

12. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

13. UAS operations must be conducted by a PIC possessing at least a private pilot certificate and

at least a current third

- class medical certificate or be properly trained in the operation. The PIC must also meet the flight review req uirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. Prior to operations conducted for the purpose of aerial survey or photography (or similar operations), the PIC must have accumulated and logg ed, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under this grant of exemption to accomplish the required flight time. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience14 building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR

91.119.

15. Prior to operations conducted for the purpose of ae rial survey or photography (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations under the exemptio n; 5 hours make and model time may be included in the

10 hours of multi

- rotor time prescribed above. The PIC must accomplish 3 take

- offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, experience building, and

take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. However, said training operations may only be conducted during dedicated training sessions. During training, proficienc y, and experience

- building flights the PIC is required to operate the UA with appropriate distances in

accordance with 14 CFR 91.119.

16. The operator may not permit the PIC to operate the UAS for the purpose aerial survey or photography (or similar opera tions), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency

maneuvers a nd maintaining appropriate distances from people, vessels, vehicles and structures.

### 15 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

18 . If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

19. The PIC must abort the flight in the event of u npredicted obstacles or emergencies in accordance with the operating documents.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations in Class E airspace. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to that operation.

22. Before conducting operations, the radio frequency spectrum used for operation and control of

th e UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

23. The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the

Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforce ment official upon request. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all

times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; The aircraft is operated near vessels, vehicles or

structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons

per § 91.119(a).

26. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the operational area as defined by an applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) wi thin 24 hours. Accidents must be reported to the National

### 16 Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.



## CONCLUSION

As set forth above, Dawnstar Exploration LLC seeks an exemption from certain parts of the

Federal Aviation Regulations to permit Dawnstar Exploration LLC to operate a 3DR UAS, for compensation or hire, commercially in the United States for the purposes of conducting aerial photography and survey. Dawnstar Exploration LLC believes that a grant of exemption is in the public interest and that p ublic safety will not be negatively affected. By use of an unmanned system in scenarios where manned aircraft are traditionally operated Dawnstar Exploration LLC believes that public safety will actually be enhanced.

PETITIONER, Dawnstar Exploration , in a ccordance with the Federal Aviation Regulations and

the FAA Modernization and Reform Act of 2012, Section 333, respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) and (b), 9 1.7(a), 91.119(b) and (c), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) and (b), and permit Dawnstar Exploration LLC to operate

the 3DR UAS commercially for the purpose of conducting aerial survey and photography over

ce rtain areas of the United States.

Respectfully Submitted,

__________________________________ Jeremiah Jolliff

P.O. Box 146 Camden, Ohio 45311

Tel. (740) 590

- 6329 jdjolliff @gmail.com