Scott Eveld

Aerial Information Technologies

27543 Ethan Allen Way

Menifee,CA 92585

I am seeking relief from the following regulations:

Part 21 prescribes the procedural requirements for issuing and changing design approvals,

productions approvals, airworthiness certificates, and airworthiness approvals.

Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and

the registration number is displayed on limited, restricted or light­sport category aircraft or

experimental or provisionally certificated aircraft, 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,” “light­sport,”

“experimental,” or “provisional,” as applicable.

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a 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.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an

airworthy condition.

Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for

determining whether that aircraft is in condition for safe flight and that the PIC shall

discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.

Section 91.9(b)(2) prohibits operation of U.S.­registered civil aircraft 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.

Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway

lengths at airports of intended use, and takeoff and landing distance information.

Section 91.109(a) prescribes, in pertinent part, 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.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An 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 weight­shift­control 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; and

(2) A powered parachute or weight­shift­control aircraft may be operated at less than

the minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain

cruising altitude by reference to an altimeter that is set “...to the elevation of the departure

airport or an appropriate altimeter setting available before departure.”

Section 91.151(a) prescribes that no person may begin a flight in an airplane 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, (1) during the

day, to fly after that for at least 30 minutes [emphasis added].

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless

it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective

U.S. registration certificate 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).

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft

unless the airworthiness certificate 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.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that

aircraft inspected as prescribed in subpart E of the same part and shall, between required

inspections, except as provided in paragraph (c) of the same section, have discrepancies

repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been

approved for return to service by a person authorized under § 43.7 of the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had an inspection for the issuance of

an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) 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 100­hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each
engine, 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; and

(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 life­limited 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 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 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 the 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 chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

My UAV is an X-8 from 3D robotics

The X8+ includes

● Controller with live on-screen flight data

● Flight battery and charger
● Operation Manual and Flight Checklist

● Ground station radio with USB and Android adapters

Specs:

● Battery: 4S 14.8V 6,000 mAh 10C

● Battery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 cm x 6.5 cm x 3.5 cm)

● Battery Weight: 803 g

● Autopilot hardware: Pixhawk v2.4.5

● Autopilot firmware: ArduCopter 3.2

● GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)

● Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz)

● Motors: SunnySky V2216-12 KV800 II

● Controller: FlySky FS-TH9X with FrSky telemetry module

● Frame Type: X

● Propellers: APC Propeller 11x4.7 SF (4), APC Propeller 11x4.7 SFP (4)

● Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm)

● Payload Capacity: 800 g (1.7 lbs). Additional payload possible up to over 1kg with

reduced flight time.

● Vehicle Weight with Battery: 2.56 kg (5.6 lbs)

● Maximum Estimated Flight Time: 15 min

● 915 MHz ground station radios allow communication with the aircraft wirelessly in

flight.

I am wanting to use this UAV for the purpose of collecting data for mapping and GIS

applications, as well as remote sensing. The X8 is fitted with a gyro stabilized gimbal that will

accept a gopro camera. Flight times are limited to no longer than 10 minutes and at an

altitude of no more than 400 feet. Because of the precision, of the maps, we hope to achieve,

our flights are usually less than 200 feet. We will never exceed 400 feet. There may be times

that we will need to be closer than the 5 mile radius of an airport, if the need arises, we would

first check with the airport, and apprise them of our intent and accommodate them in anyway

necessary.

I have more than 50 hours UAV flight time and 16 hours course study of UAV safety, theory,

and maintenance and I have been certified through UVU (Unmanned Vehicle University). I

realize that there is no officially recognized training for UAV’s in the United States at this time,

however, I feel that the training that I received from UVU was invaluable. I have 25 years

experience as a land survey professional, as well as an OSHA 30 Safety certificate.

This UAV would be used to fly in areas that conventional aircraft cannot fly. We use the

information to turn out maps that have more, and better information than is possible through

traditional means. I would be the PIC and always have a spotter with me that would also have
the ability to initiate the auto land or return to launch sequence(RTL). The X8 has a standard

flight mode, GPS assisted mode, and an autonomous flight mode. During autonomous flight,

corrections can be give directly to the UAV for course change (altitude or directional) as well

as loiter, auto land and RTL. All flights for the collection of data will be done through the

autonomous mode. If communication is lost with the UAV it will stop and loiter in position for

one minute while trying to reacquire communication. If it is unable to establish communication

it will RTL and land. GPS is also required for autonomous flight, if the gps signal is lost , the

UAV will loiter in position and try to establish a GPS signal. If a GPS signal can not be

acquired, it will land at that position. If the GPS signal is lost the UAV can also be controlled

safely through the RC controller.

The X8 is powered by a 6000MaH battery, there would be no chance of fuel spillage, and

reduces the chance of igniting fires.

All safety and maintenance is always strictly adhered to following guidelines that will be

included in this application.

Copter Safety

Copters can be hazardous if operated incorrectly. Make safety your first priority, and always

follow these best practices.
Handling

Spinning propellers can cause serious injury. Become familiar with your copter’s arming

procedure, and always disarm before handling the propellers. On 3DR RTF and other

Pixhawk­powered vehicles, the safety button provides an additional safety measure by

blocking power to the motors while the button is disabled (blinking red), allowing you to handle

the copter safely.

When flying, always make sure to keep a safe distance between yourself and the copter.

Don’t take off with the copter facing towards you or fly directly over your head. It is your job to

ensure

the safety of the people around you; make sure that spectators maintain a safe distance from

your copter at all times.

Visual line of sight
Maintaining visual contact with your aircraft is the best assurance of a safe flight. Don’t let the

copter get too far away from you; keep it where you can easily see its orientation from the

ground. This is called your visual line of sight and prevents a situation where you cannot

recover the copter safely.

Flying within visual line of sight is also a good way to ensure that your radio signals (from the

RC and telemetry radio systems) aren’t blocked by buildings or other obstructions. If you can’t

see through it, it’s likely that your radio signal can’t either.

Under 400 feet
Keep your copter flying below 400 feet (120 meters) altitude to avoid conflict with full­scale,

manned aircraft and maintain visual line of sight. To give you an idea of how high that is, the

Statue of Liberty is 300 feet (93 meters) tall.

At least 100 feet from people, vehicles, and property

Always maintain at least 100 feet (30 meters) between your copter and people, vehicles, and

buildings. This rule is important for flying near crowds, buildings, and roads due to potential

hazards from unplanned landings.

At least 5 miles from airports
To prevent conflict between your copter and manned aircraft, always fly at least five miles

(eight kilometers) away from all airports and other locations where manned aircraft are in use.

Research your area to find all areas of restricted airspace near you.

Failsafes

A failsafe is a pre­programmed behavior designed to prevent a crash in the event of an

unsafe situation. All ArduCopter vehicles include a GPS failsafe activated by default. 3DR

RTF copters are also preset with radio control (RC) and low battery failsafe behaviors.

Loss of GPS signal
If the copter looses GPS signal in a flight mode that requires GPS (loiter, auto,

return­to­launch, guided), it will land automatically, indicated by a blinking blue and yellow

status LED and a high­high­high­low tone. Always fly outside in an open area to improve GPS

signal strength.

Loss of RC signal

If the copter looses contact with the RC transmitter, it will land automatically, indicated by a

blinking yellow status LED. If it looses RC signal during a mission, it will return to the launch

point before landing.

Low battery

If the battery reaches 25% charge, the copter will land automatically, indicated by a blinking

yellow status LED and a quick repeating tone. If the battery runs low during a mission, the

copter will return to the launch point before landing.
Common sense

Your common sense is the best failsafe. Always be ready to regain manual control of the

copter in the event of an unsafe situation. Before you fly, determine the boundaries of your

safe flying area. If the copter moves outside the designated area or exhibits instability in flight,

switch to stabilize mode and land the copter manually. Remember that, despite specific

regulations, flying recklessly or creating an unsafe situation for the public is always illegal. As

the operator, you take responsibility for the behavior of your drone at all times.
Thank you for your consideration, Scott Eveld.