January 8, 2015 U.S. Department of Transportation

Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave. SE Washing ton, DC 20590 

### Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. January 8 , 201 5 U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave. SE Washington, DC 20590



### Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407

I NTRODUCTION

P ursuant to Section 333 of the FAA Modernizations and Reform Act of 2012 and 14 CFR Part 11, ArrowData, LLC , operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for KLAS

- TV for the purpose of electronic news gathering in Las Vegas, NV, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUASs under the conditions outlined here or modified by the FAA.

In the detailed explanation to follow, the series of exemptions being requested would allow operation of the commercially procured, off

- the

- shelf Cinestar 8 Okto XL

, an eight engine and blade, light weight, relatively sl ow (<50 knots) unmanned rotary aircraft (or like pla tform) in and around the city of Las Vegas during active news , traffic and weather events using very controlled conditions and operational procedures to provide robust safety buffers both vertically and horizontally to ensure personnel and property safety

. These flights would only fly within 150 feet of the control vehicle with a dismounted pilot and safety team using an auto

- pilot system that would control speed, vectoring and hovering. At no time would the vehicle fly directly over locally assembled crowd s or over any ongoing
fires or crime scenes

. The launch and recovery point would be cordoned off by the safety team in coordination with law enforcement and/or first response units. Approval of this exemption would help to prove the safe concept of UAS act ivity while conducting electronic news gather (ENG) during active

news , weather or traffic events in a major metropolitan environment with safety controls to provide proactive risk management that i s technically within the National Airspace System, but rea listically segregated well below any other air traffic and well clear of the McCarran Class B airspace (beneath the lateral confines). ArrowData, LLC is a partner with Bowhead Business and Technology Solutions who is currently pr oviding contract support as the PMO to one of the six FAA approved commercial UAS test ranges operated by the Nevada Institute for Autonomous Systems (NIAS)

. The composition of this team is unparalleled in the unmanned aviation industry, uniquely qualified to leverage the collective capabilities of UAS operations, FAA approved range testing and Analytical Risk Management. This exemption application will be accompanied with an Operations Plan, Maintenance Plan, and Risk Assessment that will depict all contingencies.Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. T he following is c ontact information for the applicant:

ArrowData, LLC. 777 N. Rainbow Boulevard, Suite 380 Las Vegas, NV 89107 Attn: Michael Bradshaw Tel: 702

- 816

- 5088

EXEMPTIONS ( Regulations from w hich the exemption is requested)

 14 CFR Part 21, Subpart H

– Airworthiness Certificate s

 14 CFR 45.23 (b)

, ,

o Aircraft Marking

o Certification and Registration

 14 CFR 61.113 (a) & (b)

o Pilot in Command

 14 CFR 9 1.7 (a)

o Civil aircraft a irworthiness

 14 CFR 91.9 (b) (2)

o Document/Flight Manuals

 14 CFR 91.103 (b)

o Preflight action

 14 CFR 109

o Flight instruction

 14 CFR 91.113

o Right

- of

- way rules

 1 4 CFR 91.119

o Minimum safe altitude

 14 CFR 91.121

o Altimeter setting

 14 CFR 91.131 (a) (1) (c) (2) (d) (1)

o Operations in Class B airspace

 14 CFR 91.145 (b)

o Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events.

 14 CFR 91.151

o Fue l requirements for VFR flight

 14 CFR 91.203 (a) & (b)

o Civil Aircraft: Certifications required

 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. o Maintenanc e and maintenance inspections

 14 CFR 407

o Operation after Maintenance, preventive maintenance, rebuilding and inspections

 14 CFR 409

o Inspections

 14 CFR 417

o Maintenance records

 NOTAM 9/5151

o Flying Around Sporting Events

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFETY

Section 333 refers to exemptions for sUASs for commercial operations. Those operations could include a vast array of events such as electronic news gathering (ENG)

. Much like the movie industry, aerial news and traffic/weather information g athering is both useful and entertaining to the general public. The quick deployment and less restrictive weather constraints will create a safer environment, while delivering a superior and timelier product to the general public, providing near real time information for traffic, severe weather and crime scene avoidance considerations.

The sUAS airc raft to be employed by ArrowData , LLC has a number of safety features that make it ideal
for use in this environment. T he state of the art Cinestar 8 Okto XL wi th dual 21 ,000 mAh, 22.2 volt battery technology and the ability to fly with two engines inoperable. It is well under 55 pounds with a top speed of approximately 50 knots . Additionally, there is redundancy in the power system to the data link, motherboard, and wireless communications within the sUAS team operating the system. The mobile vehicle to be used with the UAS is already fitted with redundant power sources for satellite and camera operations and would be available to the UAS safety team as well. The aircraft would be employed utilizing Line

- of Sight ( LOS) operations not to exceed 150 and launched from a sterile area created upon arrival at the news event by the safety team in coordination with local law enforcement and first responders. Any vertical obstructions would be noted upon arrival and the pilot and safety team would ensure operations remained well clear of those obstructions. The pilot would launch the aircraft and navigate to an acceptably safe hover point at which time a waypoint would be d esignated
and the auto

- pilot would be engaged in an auto

- hover mode while filming commences. A loss of
communication “return to base” fail

- safe system is integrated as well. The battery life is approximately
45 minutes with a planned flight time of not mor e than 2 5 minutes

. ArrowData , LLC will file a FAA Form
7711

- 1 or any such form deemed appropriate with the local Flight Standards District Office (FSDO)

. Additionally, an Operations Plan would be submitted on a mutually agreed periodical basis to the FSDO

.
All sUAS pilots being employed by ArrowData , LLC for this mission will have a FAA Commercial Pilot Certificate with Instrument Rating and a second class FAA medical certificate with additional experience
in unmanned aircraft operations. Pilots will be req uired to have a minimum of 200 hours of manned flight time and 500 hours of unmanned flight time

. The team composition will consist of a minimum ofCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. one pilot , one camera operator and one Safety Observer during all mobile news events, giving
redundanc y to the human element as well . Pilots will be well trained in areas of both normal and abnormal operations equipped with checklists and operations and maintenance manuals to be able to contend with any scenario. After extensive range testing and pilot training , t he sUAS team will perform “dry

- runs” to simulate and practice actual news events and s ituations. Additionally, a simulation evaluation will be completed by using the Monte Carlo modeling program. This program simulates 10,000 flights and provides a fail ure expectation value. To help prepare for actual flight and news gathering with a UA S, the team would deploy with the mobile news team and observe conditions and scenarios where future operations might take place. This would give the team a feel for the “ cadence”
of an active news event to a llow them to be able to plan timing and coordination issues. Unlike other uses for sUASs, these flights would be mostly shorter in length, obviating the need for a backup pilot. The designated Safety Observer would help to provide greater situational awareness for the team in order maintain alertness and vigil ance at all times. A radio frequency spectrum assessment will be
conducted before the first operational mission. Additionally, an environmental assessment will be

p erformed to measure such parameters as noise and hazardous material concerns.

14 CFR Part 21, Subpart H

– Airworthiness Certificates 14 CFR 91.203 (a) (1)

Subpart H (Airworthiness Certificates) defines the requirements for airworthiness certificate
issuan ce IAW FAR 91.203 (a) (1). Existing law (49 USC 44701 (f)), Part 11 and Section 333 allow the FAA to exempt aircraft from the requirements of an airworthiness certificate upon consideration of the size, weight, speed, operational capability and proximity t o airports and populated areas of the identified
sUAS. Unlike a manned helicopter, the sUAS being employed is lightweight, has no flammable fuel or other lubricants, operates at very slow speeds and stays well below any conflicting air traffic thereby

prov iding , an equivalent level of safety when compared to currently employed manned aircraft

.
The proposed sUAS to be employed is under 55 lbs. when outfitted with all equipment and batteries. There are no flammable liquids or other hazardous materials that would propose a danger to the public or event participants. Accordingly, no threat to national security exists due to the inability of carriage of any external stores or ordnance . Additionally, t he re is exhaustive vetting of team personnel, most of whom possess a current or recent DoD /government security clearance. All activities will be closely monitored by a team of aviation professionals and using a system with redundancies in all areas.

14 CFR 45.23 (b) Display of Marks; general

CFR 45.23 states:

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionallyCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. certificated ai rcraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisi onal,” as applicable.

An exemption to this section is needed due to the lack of a cabin, cockpit or pilot station where any reference to the term “Experimental” could be affixed. Accordingly, the wording will be placed on the fuselage. This equivalent lev el of safety will allow the team to clearly see “Experimental.” Previous precedence exists within Exemptions 10700, 10167, and 10167A.

CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command

CFR 61.113 (a) & (b) states:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate 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.

To reach an equivalent level of safety, the self

- imposed experience and training requirements would more than offset any risk introduced by using private pilots to fly an un manned aircraft in very
restricted and controlled areas.

CFR 91.7 (a) Civil aircraft worthiness

CFR 91.7 (a) states:

No person may operate a civil aircraft unless it is in an airworthy condition.

Assuming no airworthiness certificate will be required du e to relief from Subpart H, no regulatory standard exists for determining airworthiness. The equivalent level of safety will be achieved through the employment of flight manual and maintenance manual procedures, pilot training and analytical risk managemen t for each event.Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

CFR 91.9 (b) (2) states:

No person may operate a U.S.

- registered civil aircraft

—
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 combinatio n thereof.

Given the size of the sUAS being utilized in this endeavor, there is no room onboard for an aircraft flight manual.

The equivalent level of safety will be achieved by keeping the flight manual with the pilot/team on the ground with easy access . Previous precedence is resident in Exemptions 8607, 8737, f8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, f32827, and 10700.

CFR 91.103 (b) Preflight action

CFR 91.103 (b) states:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

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

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

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, oth er reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

This regulation dictates that a pilot conduct preflight acti vities. Without an FAA approved flight manual, relief is required from this regulation. Extensive pre

- flight planning will provide an equivalent level of safety by using the operations plan, aircraft flight manual, maintenance manual and available
weather and NOTAM information.

CFR 91.109 Flight instructionCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. CFR 91.109 states:

No 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 clea rly have no onboard flight controls. An equivalent level of safety will be accomplished by conducting pilot training via the control system that communicates with the aircraft from the ground.
ArrowData , LLC intends to conduct this training on the Nevada t est site under controlled conditions.

CFR 91.113 Right

- of

- way rules: Except water operations.

CFR 91.113 deals with the many scenarios whereby different types of aircraft in different states must give way to other aircraft.

Because the sUAS PIC does not have “see and avoid” capability, the petitioner requests relief from this regulation. All operations will be within LOS of the pilot and well below any airspace where other flight activity is taking place.

CFR 91.119 (d) (1) Minimum safe altitudes; general

CFR 91.119 states:

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted 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 specifically prescribed for helicopters by the FAA

.
Recognizing that this relief is unprecedented, the petitioner asks that the FAA recognize the inherent capability of the ArrowData , LLC /BBTS/NIAS team. With a proven leader in risk management ( ArrowData , LLC ) and a leading FAA test site ( NIAS/ Nevada), we feel that an acceptabl e level of safety
can be achieved . Extensive range testing and additional on

- site testing in a benign environment would
be conducted in real or near

- real time conditions. The current altitude and/or horizontal restrictions on
rotorcraft assumes a much heavier manned aircraft loaded with fuel and possible external stores. The light

- weight sUAS being proposed for use in this activity along with its precise guidance and redundant
systems create an entirely different paradigm that should be considered by regulatory bodies.

The activities being proposed by this petiti oner are in a very controlled and open area. The flights would be co nfined to the immediate area of the mobile control center (MCC)

. Given theseCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. considerations, ArrowData , LLC proposes allowing flights to operate no more than 150 feet from the
MCC and well clear of the Class B airspace and attendant manned air traffic.

CFR 91.121 Altimeter settings

CFR 91.121 states:

Each person 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

—

Below 18,000 feet MSL, to

—
The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

The sUAS aircraft intended for this activity will not be equipped with a barometric altimeter. Instead it will incorporate radio altimetry via the onboard GPS . An equivalent level of safety will be
ach ieved through use of the operations and maintenance manuals governing altitude control. A preflight
calibration of launch site altitude will be accomplished.

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace

CFR 91.131 states:

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with § 91.129 and the following rules:

(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.

(c) Com munications and navigation equipment requirements. Unless otherwise authorized by ATC, no person may operate an aircraft within a Class B airspace area unless that aircraft is equipped
with

—
(2) For all operations. An operable two

- way radio capable of communications with ATC on appropriate frequencies for that Class B airspace area.

(d) Other equipment requirements. No person may operate an aircraft in a Class B airspace area unless the aircraft is equipped with

—
(1) The applicable operating transponde r and automatic altitude reporting equipment specified in § 91.215 (a) , except as provided in § 91.215 (e)

.Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. Much of the city of Las Vegas lies within th e limits of the Class B airspace. Because the planned sUAS to be employed lacks an onboard transponder or two way communication capability, relief from this regulation is required. An equiv alent level of safety will be achieved by limiting the operating ceiling
of the sUAS to altitudes well below any conflicting manned air craft traffic (no higher than 15 0 feet). This

assures de

- confliction with all other traffic and specifically traffic with in the Class B airspace. Additionally, the sUAS will remai n clear of the McCarran Class B airspace at all times. ArrowData , LLC will periodically report to the FSDO on operations and risk management issues.

CFR 91.145 (b) Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events.

CFR 91.145 states:

In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FA A considers the following factors:

(1) Area where the event will be held.

(2) Effect flight restrictions will have on known aircraft operations.

(3) Any existing ATC airspace traffic management restrictions.

(4) Estimated duration of the event.

(5) Degree of public interest.

(6) Number of spectators.

(7) Provisions for spectator safety.

(8) Number and types of participating aircraft.

(9) Use of mixed high and low performance aircraft.

(10) Impact on non

- participating aircraft.

(11) Weather minimums.

(12) Emergency procedures that will be in effect.

If KLAS intends to use the sUAS to cover sporting events from the outside of the activity, coordination will be completed by contactin g the FSDO prior to the event to ascertain the presence of any other unmann ed activities. Flight activity will be conducted using the same operations plan as with any other ENG activity with particular attention to the avoidance of overflight of large concentrations of people. All of the concerns in the above twelve subparagraphs have been or will be addressed in otherCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. portions of this exemption application. However, specific relief from this regulation is still necessary to ensure compliance with FARs.

CFR 91.151 (b) Fuel requirements for flight in VFR conditions.

CFR 91.151(b) s tates:

No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that fo r at least 20 minutes.

The batteries that power the Cinestar 8 Okto XL have a mission life of approximately 45 minutes. To meet the 20 minute reserve requirement, the airborne mission would be limited to approximately 25
minutes. Given the limitation of t he proposed flight area during any ENG , a more liberal flight time is a reasonable request. The aircraft would never be further than 150 feet from the recovery area. In no case would the aircraft be operated with less than 25% battery life remaining.

No night time operations are currently planned.

CFR 91.203 (a) & (b) Civil Aircraft: Certifications required

CFR 91.203 (a) & (b) states:

(a) Except as provided in § 91.715 , no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the ap plicable operations specifications issued under § 21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c) , or an authorization under § 91.611 ) must have on it the registration number assigned to the aircraft under part 47 of this chapter . However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to
the aircra ft. A revised airworthiness certificate having on it an assigned special identification number
that has been affixed to an aircraft

, may only be obtained upon application to an FAA Flight Standards
district office.

(2) An effective U.S. registration certif icate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c) , or a registratio n certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.Corporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. The sUAS to be employed has no cockpit or pilot and therefore has no ability to carry onboard any certificat ion or registration documentation.

The equivalent level of safety will be achieved by keeping these documents with the pilot/team on the ground at the event. Previous precedence is resident in Exemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A and 107 00.

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance

These CFRs state:

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 ;

Operation after maintenance, preventive maintenance, 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 person authorized under § 43.7 of this chapter; and

(2) The maintenance record entry required by § 43.9 or § 43.11 , as applicable, of this chapter has been
made.

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

—
(2) An inspection for th e issuance of an airworthiness certificate in accordance with part 21 of this chapter

.

The 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 en gine, propeller, 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; andCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. (iii) The signature, and certificate 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 parts 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 air craft, 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 method 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 th e periods prescribed:

(1) The records specified in paragraph (a) (1) of this section shall 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 ch apter shall be retained until the defects are repaired and the aircraft is approved for return to service.

These FARs only concern aircraft with an airworthiness certificate and therefore would not apply in this situation. All maintenance and inspections w ill be conducted IAW the maintenance manual and operations manual. The ability for an almost immediate safe recovery and landing if a malfunction occurs and the eight engine configuration with the ability to fly with loss of thrust on 2 engines provides

a comfortable operating envelope and ensures an equivalent level of safety.

The reasons why granting ArrowData, LLC’s request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption to ArrowData, LLC would allow the public to safely view breaking news from a dynamic and unprecedented aerial perspective. ArrowData, LLC has created a unique way to view news

events that benefits the general public socially and eco nomically. ArrowData, LLC sets the industry standard in using purpose built Small Unmanned Aircraft Systems (sUAS) with multiple redundant features that enhance safety. ArrowData, LLC builds and engineers its Cinestar 8 Okto XL platform withCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. dual electro nic motherboards and flight control systems, dual high

- capacity batteries rated at 21,000
mAh each , and the ability to maintain controlled flight with the loss of 2 engines.

The reasons why granting the exemption would not adversely affect safety:

ArrowD ata, LLC is leading the sUAS industry by using a safe and beneficial business model. ArrowData, LLC is a partner with Bowhead Business and Technology Solutions, LLC (BBTS). BBTS currently provides contract support as the Program Management Office (PMO) contractor to one of the six FAA approved commercial UAS test ranges operated by the Nevada Institute for Autonomous Systems (NIAS). The composition of this team is unparalleled in the unmanned aviation industry, uniquely qualified to leverage the collect ive capabilities of UAS operations, FAA approved range testing and Analytical Risk Management.

In addition, enhanced safety is achieved by using an unmanned aircraft that does not carry passengers or crew and does not carry flammable fuel.

IAW 14 CFR Part 11 .81 , the following summary is provided for publication in the Federal Regis ter, should it be deemed necessary:

Applicant seeks relief from the following rules:

14 CFR Part 21, Subpart H

– Airworthiness Certificates, 14 CFR 45.23 (b),14 CFR 61.113, (a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103 (b), 14 CFR 109, 14 CFR 91.119, 14 CFR 91.113, 14 CFR 91.121, 14 CFR 91.131 (a) (1) (c) (2) (d) (1), 14 CFR 91.145 (b), 14 CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a); 407 (a) (1); 409 ( a); 417 (a) & (b), 14 CFR 407, 14 CFR 409, 14 CFR 417, NOTAM 9/5151

The unparalleled operational and testing capabilities created by the partnership between ArrowData, LLC , Bowhead Business and Technology Solutions (Program Management Office contractor
fo r NIAS), and the Nevada Institute for Autonomous Systems (the Nevada test range) will enable the Federal Aviation Administration to allow for the introduction of sUASs into environments not previously allowed with an acceptable level of safety. This is an opportunity to use highly dependable, multi

redundant unmanned aircraft in a major metropolitan area , but to do so with stringent controls, pervasive risk management and detailed mitigation strategies to ensure that the public is not at any time exposed to unsafe conditions. Extensive range te sting, “dry

- run” testing under benign conditions and simulated emergencies will demonstrate that this activity can be accomplished without hazard to the general public. Additionally, a simulation evaluation will be com pleted by using the Monte Carlo modeling program. This program simulates 10,000 flights and provides a failure expectation value. The rotorcraft being proposed for this operation has redundancy in every conceivable are a : thrust,
communication s , and electri cal power for both the aircraft itself and the supporting system. Eight engines powered by two separate 21 ,000 mAh batteries and a data link system with “fly home” capability ensure that at no time will the aircraft not be able to land safely should that n eed arise. Pre

plotted waypoints using Geographic Instrument System coordinates and auto

- pilot “fly to” commandsCorporate Headquarters 4900 Seminary Road, Ste

. 1200 | Alexandria, Virginia 22311 | 703.578.5566 Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 70 2.816.5087

ArrowData is a subsidiary within the UIC Government Services Division of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation. provide extremely precise navigation. A Safety Management System will be employed and will address such issues as environmental impact (noise a nd hazardous material) and coordination with local Emergency Services/Incident Management personnel to include:

 Fire fighting

 Medical response

 Incident investigation

These capabilities, in total, provid e a level of safety that should be satisfactory to the FAA and general public.

In view of the beneficial advantages to public safety, we respectfully submit our Section 333 exemption request.

Sincerely,

Michael S. Bradshaw President ArrowData, LLC 777 N. Rainbow Blvd, Suite 380 Las Vegas, NV 89107