1

26 October 2015

Larry R. Field DBA Arizona Aerial Imaging Solutions (AAIS ) 64400 E. Squash Blossom Ln Tucson, AZ 85739

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

Re: Petition for Exemption Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from : 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91 .119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernizat ion and Reform Act of 2012 (the Reform Act ) and 14 CFR Part 11, Arizona Aerial Imaging Solutions (Petitioner) (AAIS) hereby applies for an exemption from the listed Federal Aviation Regulations (FAR) to allow commercial operation of a designated unmanned aerial system (UAS), provided such operations are conducted within the conditions outlined herein or as may be established by the FAA as required by Section 333.

AAIS seeks the requested exemptions to permit it to offer aerial d ata collection services in the fields of remote sensing, aerial imaging, aerial mapping and scientific survey.

As described in the following pages, the requested exemption would permit the operation of a designated

UAS as set forth in this document under controlled conditions in the National Airspace System (NAS) that would be operated safely. Approval of this exemption would provide services that would reduce the risk associated with manned solutions, in both flight and other methods of completion of the pr oposed

services.

The name and address of the Petitioner is as follows:

Larry R. Field Arizona Aerial Imaging Solutions (AAIS) 44000 E. Squash Blossom Ln Tucson, AZ 85739 Ph: ( 505 )

- 577

- 0588
Pilot Cert # 3157427
E

- mail: larryfield35@msn.com2



## Unmanned Aerial System Description

Arizona Aerial Imaging Solutions (AAIS) will employ both the 3DR Robotics Iris+ Clone and the 3DR

Aero

- M Clone for data collection operations. These system s are clones of Iris+ and Aero

- M manufactured by 3DR Robotics, have been extensively tested and have a proven safe flight history. Both system s includes an a ir frame, a Pixhawk flight controller, and a Minim OSD (onscreen telemetry display). A
varie ty of small cameras, radio telemetry receivers, and other sensors can be attached to the se platform s to accomplish the desired objecti ves. Both aircraft are flown by the pilot

- in

- command (PIC) using a radio control system. The se platform s have a sophisticated flight control system (Pixhawks) that enables the PIC to locate the unmanned aircraft (UA) on a mo ving map as a part of a ground control system in addition to being continually in visual line

- of

- sight and has safety systems to warn and manage low battery

- voltage situations. These aircraft can be flown manually b y the PIC or fly a pre

- planned route using the ground control system. Both of these aircraft will be flow n under a comprehensive set of operational standard procedures focused on the sa fe operation of the plat form to minimize risk. Each
aircraft has a LED lighting system to communicate key elements of opera tional status at all times, in
addition to the on

- screen display showing flight parameters relevant to the safe operation of the UA.

The Iris+ Clone and the Aero

- M Clone have a maximum ta ke

- off weight of 3 .8 and 6.8 pounds

, respectively . The UA flight s peed will not exceed 30 knots, and it will not be flown in controlled airspace
or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely
terminated with a reserv e battery power of 30% maximum charge.

These UAs does not carry any flammable propellant or fuel.

Command, control, and telemetry communications for both UAs occur on the 2.4 G Hz frequency band. The communications link is frequency hopping, spread spectrum which greatly reduces the potential for interference. The specific radio frequency devices used by the se UAs have been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the Federal Communications Commission. The programming of the respective Pixhawk controllers in each UA is such that, if a lost communication link occurs the UA will return to its starting point and automatically lan d /or circle with no user interaction necessary.



## Granting an Exemption Would Serve the Public Interest

In the absence of a UAS, many of the proposed activities would have to be carried out by a helicopter, fixed wing airc raft, a bucket truck, or a lineman climbing a tower. All of these conventional methods involve a risk to human lives and property that is clearly higher than risks to human lives and property posed by the utilization of UAS.

UAS utilization in accord ance with the typical terms of an exemption grant does not require the interaction of Air Traffic Control (ATC). Where such use replaces manned aircraft, a net reduction in
ATC burden is realized.3

The Iris+ and Aero

- M clones are battery powered and the refore creates no noxious emissions hazardous to the environment. Further, as a battery powered vehicle the noise levels are substantially lower than any internal combustion engine driven aircraft.

Survey, mapping, and aerial data c ollection techni ques utilizing UAS technology is substantially more cost effective than the conventional methods to accomp lish these tasks. Cost savings by UAS utilization have the potential to find their way to ratepayers thereby reducing energy costs to the consumer.



## OPERATIONAL LIMITATIONS TO ACHIEVE AN EQUIVALENT LEVEL OF

SAFETY

AAIS proposes the following operational limitations to achieve an equivalent or higher level of safety than under the current regulatory structure, particularly in comparison to the use of manned aircraft.

1. All operations will be carried out with strict adherence to the operating procedures outlined in the Pilot s Operating Handbook s (POH ) contained in the manufacturer’ s user manual (Attachment A) The POH includes the following:

a. General description, specifications, and warnings

b. Limitations

c. Emergency Procedures

d. Normal Procedures

e. Performance

f. Weight and Balance/Equipment List

g. Air Vehicle and Systems Description

h. Handling, Service, and Maintenance

i. Supplements

2. The UA s wi ll weigh less than 3 .8 and 6.8 lbs, respectively , for the two UAs

. 3. The UA s , will operate at a true airspeed maximum (V NE ) of 15 m/s (approximately 30 knots) which is within manufacturer specifications.

4. Minimum crew for each operation will consist of the UA Designated Pilot in Command (PIC) and at least one Visual Observer (VO). The PIC and VO will be able to communicate verbally at all times during the flight and will not exchange roles during the flight. Electronic messaging or texting is not permitted d uring flight operations. The PIC will ensure that the VO can perform the required duties of the VO.4

5. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot
certificate. In addition the PIC must hold a valid U.S. driver s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government.

6. Flights will be operated within visual line of sight (VLOS) of the PIC and VO at all times. AAIS

understands that definit ion of VLOS is human vision unaided by any device other than corrective

lenses.

7. The primary responsibility of the VO will be to enhance the safety of flight operations by verbally communicating potentially unsafe observations to the PIC. Such co nditions m ay include, but are not limited to, conflicting aircraft, hazardous terrain, features, or weather, UA approaching VLOS limits or altitude limits, assisting the PIC in monitoring battery vol tage, and advising the PIC if

non

- participating personnel move with in a potential danger zone. V O s will be familiar with the UAS normal and emergency procedures and aircraft limitations in su fficient detail as to provide
the PIC with recommended corrective actions.

8. Maximum flight time for each operational flight will be approxi mately 3 0 minutes. The actual flight time will depend on a variety of variables including win d conditions, sensor payload, mission requirements, and the choice of battery capacity. All flights will be conduc ted under a strict battery management reg ime that alerts the operator to end fligh t at a pre

- determined battery capacity. If the PIC exceeds this limit, the UA will autonomously return to the departure point
and land /circle upon reaching the first critical battery level (first alert) a nd will lan d immediately

upon reading the second critical battery level (second alert).

9. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL).

10. All operating documents will be accessible to the PIC at the grou nd control station during UAS operations. Operating documents will include the curren t POH and a copy of the FAAs Exemption, if granted. If a discrepancy exists between the various operating documents, the FAA s Exemption, the Exemption will take precedence. The POH will be updated as necessary. Such updates will be tracked.

11. A safety briefing will be performed prior to each day’s flights consi sting of all the day’s flight operations. All parties involved in the flight operations will participate in the safety briefing.

12. T he PIC will conduct a pre

- flight inspection for the UAS. The pre

- f light inspection will account for all systems to insure that the UAS is in a condition for a safe flight. As a minimum, the pre

flight inspection will follow the checklist procedures in the POH. If the pre

- flight inspection reveals a condition that may affect the safe operation of the UAS, the aircraft will not be operated until necessary maintenance has been completed.

13. In the event of an emergency or other unpredicted obstacle to the co mp letion of a flight, the PIC will abort the flight in the safest manner possible.

14. AAIS will not permit a PIC to operate the UAS unless the PIC demon strates the ability to safely operate the UAS safely and competently within the framework of the measures outlined herein and the POH. This will include normal and emergency procedure s and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification f light hours will be logged in a manner consistent with 14 CFR ß61.51(b).

15. The PIC and VO will have been trained in operation of UAS and receive current information regarding operation of the UA.5

16. PIC and VO training and evaluation flights will only be conducted during dedicated training sessions. During such sessions, the PIC will operate the UA a manner consistent with 14 CFR ß91.119 by maintaining the prescribed distance from non

- participants.

17. All aircraft utilized as a part of this request will be registered and subsequently assigned a serial
number in accordance with 14 CFR part 47 and display identification markings in accordance with 14 CFR part 45, subpart C. N

- number markings will be as large as practicable.

18. AAIS will conduct routine inspections o f the UA to ensure that they are in a condition for safe operation. As a minimum, inspections will be conducted as per the POH and as per manufacturer recommendations. Additional inspections will be completed as deemed necessary. AAIS will comply with all safety bulletins issued by the manufacturer.

19. AAIS will conduct maintenance on the UA as necessary. Maintenance procedures will follow manufacturer s recommendations regarding replacement, overhaul, and life limited components.

20. After maintenance or alterations that affect the operational or flight chara cteristics of the UA, a test flight will be conducted to determine that the UA is properly functioning prior to resuming commercial operations. Flight tests will be conducted by a PIC and a VO and will remain at least
500 feet from other non

- participants. Further, the flight test will be conducted in a manner so as not to pose an undue hazard to persons and property.

21. AAIS will also obtain a Certificate of Waiver or Authorization ( COA) from the FAA Air Traffic Organization (ATO) prior to conducting operati ons within the NAS.

22. No UA flights will be conducted at night and all flights will occu r under Visual Meteorological Conditions (VMC). The UA will not be operated less than 2,000 feet horizontally from a cloud or when the visibility is less than 3 statute miles from the PIC.

23. The PIC will ensure that the UA remains clear of and gives right

- of

- way to all manned aviation operations.

24. The PIC will not operate the UA from a moving device or vehicle.

25. The UA will not be operated within 5 nautical miles of an airport reference point (ARP) unless a
letter of agreement with that airport’ s management is obtained or it is otherwise permitted by a
COA issued to AAIS

. 26. The UA will be operated in a manner that maintains at least a 50 0 foot clearance from all non

p articipating persons, vessels, vehicles and structures except in the case of the following
conditions:

a. Barriers are present to protect non

- participating persons in the event of an accident. AAIS
will ensure that non

- participating persons utilize these protective barriers. If a non

participating person leaves a barrier and is within 500 feet of the UA, flight operations will be terminated in a manner that ensures the safety of non

- participating persons.

b. The owner or controller of any vessels, vehicles , or structures has to grant permission to operate closer than 500 feet to those obs tacles and the PIC has to complete a safety assessment of the proposed operation in order to determine that the operation c an be completed safely.

27. Flight operations will only be conducted over property where the permission is granted by the property owner or otherwise authorized representative.

28. The UAS s automatically determine its failsafe return

- to

- home position upon liftoff. If the UAS

loses communications with the rem ote controller, it will return to a liftoff location and land or circle autonomously.6

29. AAIS will report any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents wi ll be reported to the National Transportation Safety Board (NTSB).



## SPECIFIC EXEMPTIONS REQUESTED

In pursuit of this petition the follo wing exemptions are requested:

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR ß91.203 (a) (1).

Given the size and limited operating area associated with the aircraft to be utiliz ed by AAIS , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.ß44701 (f)) and Section 333 of
the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criter ia demonstrates that the UAS operated without an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating
with an airwort hiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates ex clusi vely within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator. These safety enhancements provide a greater degr ee of safety to the public and
property owners than conventional operations conducted with airworthines s certificates issued under 14 C.F.R. Part 21, Subpart H.

Lastly, there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is required by ß21.5 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.

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the PIC will have immediate access to it.7

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. These actions include the following:

a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been ad vised by ATC; 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, other reliable information appropriate to the aircraft, relating to aircraft performance und er expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as state d in the POH under Normal Procedures including but not limited to reviewing weather, flight battery requirements, and aircraft performance data before initiation of flight.

Section 91.103 provides that 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.

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio signals. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the UA and by the small size, weight, and generally slow speed of the UA. Thus, an exception is requested.

Section 91.119 establishes safe altitudes for operation of ci vil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopte r complies with any route or altitudes prescribed for helicopters by the FAA.

As this request is for a U AS that is helicopter like and the exemption re quests authority to operate at altitudes up to 400 AGL an exemption may be needed to allow such operat i ons. As set forth herein, the UA will never operate at higher than 400 AGL It will only be operated in a co ntrolled environment, where structures, vessels, vehicles, and non

- participating people will not be exposed to operations.

The equivalent level of safety will be achieved given the small size, low weight, and slow speed of the UAS as well as the controlled environment where it is operated. No flight will be initiated without the permission of the property owner or authorized representative. Unlik e co nventional aircraft, the UA requires no flammable fuel, a safety enhancement at low altitude. Further, since the UA will be operated8

at 400 AGL or less, it will maintain separation from manned aircraft that are required to comply with Section 91.119.

This regulation requires each person operating an aircraft below 18,000 feet MSL to maintain cruising altitude by reference to an altimeter that is set to a particular barometric pressure (altimeter setting) or the elevation of the departure airport.

Manned aircraft have an altimeter that displays altitude in MSL. The intent o f this regulation is to ensure that all aircraft in an area are displaying the same altitude when they at the s ame true altitude MSL. In this way aircraft can maintain vertical se paration in cruise flight as per ß91. 159 for VFR flights and as per ß91.179 for IFR flights. Further it ensures that aircraft assigned a parti cular altitude by ATC or as per published altitude requirements such as traffic pattern altitudes will have the a b ility to accurately
determine that altitude.

Conversely, the UA’s Pixhawk Controller automatically sets its zero altitude based on the departure site. Thus, all altitude readings displayed on the Ground Control Station are in AGL from the departure site. In order comply with the limitations specified herein to maintain an altitude below 400 feet AGL, it is appropriate for the altimeter to display in AGL instead of MSL thereby maintaining separation from manned aircraft and achieving an equivalent level of safety.

Section 91.151 specifies fuel reserve minimums for airplanes and helicopters. Specifically, 91.51 (b) states that no person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) the re is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

Since the UA is battery powered and lacks a combustion engine, there is no conventional fuel consumption. Furt her, the flight times for the UAs are co nsiderably shorter (maximum of 3 0 minutes) than combustion engine powered manned aircraft. An equivalent level of safety will be achieved by landing the aircraft when the battery power, as monitored at the ground con trol station, reaches 30% of the capacity of a fully charged battery. A further safety feature is that the UAs Controller will automatically return to its departure point with no PIC interaction required if the battery voltage falls below 20% of the capaci ty of a fully charged battery.

The regulation provides in pertinent part:

a. Except as provided in ß91.715, no person may operate a civil aircraft unless it has within it the following: 1) An appropriate and current airworthiness certificate. . 2)

. An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second duplicate copy (pink) of the Aircraft Registration Application as provided for in ß47.31(b), or a registration certificate issued under th e laws of a foreign
country.9

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 un der ß91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

As previously discussed, an exemption is sought regarding the requirement to acquire an airworth iness certificate. Further, these UAS s fully loaded weig h <6.8 pounds and are operated without an onboard pilot. As such, there is no ability or place to carry a registration certificate or to display it on the UAS. An equivalent level of safety will be achieved by keeping the registration certificate at the ground control point where the PIC will have immediate access to it.

These regulations cover maintenance, preventative maintenance, and aircraft alterations. In summary for VFR aircraft, and not including all exceptions, it requires the following:

1. Annual inspections or 100

- hour inspections (for commercial ope rations) with approval for

return to service by a person authorized by ß43.7.

2. A test flight by an appropriately rated pilot after repairs or alterations that may have appreciably changed the aircraft s flight characteristics have been made

3. Logging of all maintenance performed according to particular standards

These sections, collectively part of Subpart E, and Part 43 only apply to aircraft with an airworthiness certificate. As previously discussed, an exemption is sought regarding the req uirement to acquire an airworthiness certificate. However, an equivalent level of safety will be achieved by implementing the concepts of these sections as follows:

1. Inspections will be performed at intervals recommended by the POH and the manufacturer.

2. A test flight will be performed after any maintenance or alteration is performed that may affect
the UA s flight characteristics. The test flight will be performed prior to return to commercial service by an appropriately rated and experienced PIC.

3. All m aintenance will be logged.



## CLOSING

Arizona Aerial Imaging Solutions (AAIS) appreciates the opportunity to submit this petition for exemption to the Federal Aviation Administration. I have endeavored to provide the appropriate information required bas ed on guidance from the FAA s website. If there are any questions or I can provide further information, please contact me.

Larry R. Field

Owner, A rizona Aerial Imaging Solutions
Instrument Rated Private Pilot10 

# Appendix A

Owner Manual s Containing Pilot Operating Handbook

for

3DR’s Iris+ Quadcopter and Aero

- M Drone

These Links are for POHs and Manuals that are directly applicable to the cloned versions
of the Iris+ and Aero

- M referenced in this document.

Aero

- M POH & Manual: https://3drobotics.com/wp

- content/uploads/2014/10/AeroM

Operation

- Manual

- v1.pdf

3DR Iris+ POH and Mapping Manual: https://3drobotics.com/wp

content/uploads/2015/04/Mapping

- Package

- Instructions

- v1.pdf