July 10, 2015 Jason Greer Rocky Mountain UAV 6531 Sugarberry Lane Colorado Springs, CO 80927

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J greer2 13@gmail.com U.S. Department of Transportation
Federal Avia tion Administration 800 Independence Ave, SW Washington, DC 20591

RE: Petition for e xemption under Section 333 of the FAA Reform Act from m ultiple parts o f the Fed eral Aviation Regulations from Title 14 C

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Dear Sir or Madam:

I (Jason Greer) / Rocky Mountain UAV respectfully request and exemption from Section 333 of Title 14 of the Code of Federal Regulations to permit the use of small (under 55 lb s ) unmanned aerial systems (UAS) for use of safe aerial photography and video in the construction /engineering , real estate, and agricultural industries

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Construction / Engineering

– Aerial photography and video will be used to evaluate the progress of construction projects and

review mine sites in real time. The technology will also be used to evaluate the existing conditions of potential construction projects to assist in engineering and project startup.

Real Estate

– The UAS will be used as a marketing tool to allow client s to show case their properties by use of aerial photography.

Agriculture

– The UAS will be used to assist ranchers in searching for their livestock and assist farmers in reviewing their crop

, both in real time.

Public Interest & Safety

General

– 1. No operation over pedestrians, vehicles or potential congested areas.
2. No operation over private property without the property owner ’s consent.
3. No operation in restricted airspace / near airport / government facilities. If equipped on the UAS, utilize the GPS and computer to ensure UAS does not enter restricted airspace.

4. Understand local and state laws, they may differ from federal requirements. In case of conflict between laws, the more stringent law applies.

5. No operation beyond line of site of the operator.

6. Ensure the UAS computer will stop the UAS from going more than 4 00 feet into the air.

7. Follow the manufactures operating manual along with their safety guidelines.

a. http://www.dji.com/product/phantom

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- vision

- plus/downloadb. http://www.dji.com/product/phantom

- 3/download

c. http://www.dji.com/product/inspire

- 1/download

8. THE OPERATOR ALWAYS HAS THE AUTHORITY TO STOP OPERATIONS IF HE/SHE HAS ANY

SAFETY CONCERN.

Pre Flight Requirement s – 1. R eview surrounds for pedestrians, obstacles and changing conditions.

2. Understand the boundaries wher e the operation will take place and stay within the designated boundaries.

a. Is there private or public property adjacent to the operation?
b. Is potential for pedestrian, vehicles or wildli fe to enter the operation area?

c. If possible

, m ark the operation boundary on the “ on screen map ” (DJI Phantom 3 or DJI Inspire 1)

3. Inspect UAS for damage

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a. Propellers
b. Body

c. Motors
d. Exposed Electronics / Wire Connections

e. Landing Gear
f. Cargo / Payload / Camera

4. Ensure all hardware firmware is updated to the latest version.

5. Ensure UAS has been calibrated, minimum once per week or if o peration is more than 50 miles from previous operation.

6. At least once per month, test the “ Return to Home ” function to ensure that it work properly.

7. Allow time for UAS to “ warm up ” before flying

– typically 2 minutes.

8. Start all flights in GPS Mode to make there are a proper amount of s atellites available for safe flight.

Flight Requirements

– 1. Operator must m aintain eyesight of the UAS

. 2. The UAS must be kept below 4 00 feet from the ground

. 3. Keep UAS speeds below 70 MPH . Excessive speeds are not necessary for commercial use

. 4. Utilize real time video playback to the operator if possible.

5. If possible have a backup operator to assist in maintaining eyesight of the UAS.

6. Monitor battery life

– if low (below 25%) , bring the UAS back to its home position.

7. Monitor for changing conditions

– Weather, Pedestrians, Wildlife and other dynamic factors.

Post Flight

– 1. Inspect UAS for damage / wear

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a. Propellers
b. Body

c. Motors
d. Exposed Electronics / Wire Connections

e. Landing Gear
f. Cargo / Payload / Camera

2. Allow UAS to cool down before storage

– typically 2

– 5 minutes

3. Check batteries for bulging or excessive heat.Radio Frequencies

Only standard UAS frequencies ( 2.4 GHZ & 5.8 GHZ ) will be utiliz ed for operation s

. These frequencies will be used for flight control and for cameras. One or both frequencies may be utilized at

one time.

Operator Qualifications

Jason Greer

– 1. Over 100 Hours of UAS flight time with modern style quad

- copters
2. OSHA 10 HR

– For Construction Clients

3. MSHA Certified

– For Access to m ine sites

4. First Aid / CPR

Future Employee Minimum Requirements

– 1. Onsite Flight Training

– By Company

2. First 20 hours of actual flight time is supervised

3. OSHA 10 HR

– Prior to Entry on to Construction Sites

4. MSHA New Miner Certified

– Prior to Entry to Mine S ites

Reg ulations from which the exemption is requested :

List of Exemptions Requested

– 14 CFR

- 21

14 CFR

- 45.23(b)

14 CFR

- 61

14 CFR

– 91. 7(a)

14 CFR

– 91. 9(b) (2)

14 CFR

– 91. 103

14 CFR

– 91. 109

14 CFR

– 91. 119

14 CFR

– 91. 121

14 CFR

– 91. 151

14 CFR

– 91. 405

14 CFR

– 407

14 CFR

– 409

14 CFR

– 417

Details for Exemptions Requested

– 14 CFR

– 21 Given the size, weight and speed; an exemption from 14 CFR part 21 is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and
section 333 of P.L. 112

- 95 (Sect ion 333)

14 CFR

- 45.23(b) As the aircraft does not have a cabin, cockpit or pilot station which will not allow for any internal markings. Due to the size of the aircraft e xterior marking must be smaller thanthe 2 inch requirement. Company information will be marked o n the UAS in using an appropriate size to allow for the full company name to be displayed.

14 CFR

- 61

14 CFR

– 91. 7(a) This regulation is in not applicable for our operation as there is no certificate available
for our operation

. 14 CFR

– 91. 9(b) (2) This regulation is not applicable as the size of the aircraft wi ll not allow for the safety

man ual to be in the aircraft. We will keep a safety manual at the ground station to achieve an equal safety measure.

14 CFR

– 91. 103
This regulation requires each pilot to take certain actions before flight to insure the
safet y of flight. As the FAA approved UAS flight manuals will not be provided for the aircraft and exemption will be needed. T he operator will take, at a minimum, the actions prescribed above in the safety section of this docum ent as well as follow
manufacture ’ s recommendations

. 14 CFR

– 91. 109

UAS ’ s do not have duel controls; therefor this regulation does not apply. The UAS will be operated by remote from the ground and the operator will maintain eyesight of the

UAS . One additional measure is that the UAS will have a fail

- safe function that will land

or return the UAS to the home position if the UAS and Remote lose connection.

14 CFR

– 91. 119
The altitude levels prescribed do not apply t o our operations. Operations will not go
above 4 00 feet above ground and will stay wi thin eyesight of the operator. These
measures and the safety measures as described above are applicable and equivalent to
the prescribed measures in 14 CFR

– 91. 119

14 CFR

– 91. 121

T his regulation does not apply as the UAS utilized GPS and a barometric sensor.
14 CFR

– 91. 151
This regulation does not apply as the UAS does not use fuel. The UAS is 100% electric
and measures battery life. The UAS measures its distance from it s home position an d will alert the operator when it must be returned home without exhausting the battery.
The UAS also has a fai l

- safe , when the battery reaches 25% it will automatically land or return home, depending on the setting the operator has chosen

. 14 CFR

– 91. 405 , 407, 409, 417 Maintenance inspections do not apply as there is no airwothiness certificate. However there will be a standard safety inspection completed pre and post flight per the manufactures recommendation and our internal polices as describ ed above.

If there are any questions, please feel free to contact me at any time.

303

- 229

- 5077

J greer2 13@gmail.com

Jason Greer