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

Regulatory Docket No.__________



# Exemption Request Under Section 333 of the FAA Reform
Act and Part 11 of the Federal Aviation Regulations

Submitted on July 02

, 2015

Craig Taylor Abington Jr. Project Lead, Commercial UAS
4905 Research Drive Northwest Huntsville, Alabama 35805

- 5905

Tel: (256) 327

- 7182 taylor.abington@avioninc.com1

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Table of Contents

Table of Contents

................................ ................................ ................................ ................................ .......... 1

Glossary of Abbreviations

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

Summ ary Letter

................................ ................................ ................................ ................................ ............ 4

Introduction and Interests of Avion

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

Basis for Petition

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

Name and Address of Avion

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

14 CFR Sections for Requested Exemption

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

Reasons Why Requested Exemption Would Be In Public Interest

................................ ......................... 21

Reasons Granting Exemption Would Not Adversely Affect Safety

................................ ......................... 23

Key Personnel

................................ ................................ ................................ ................................ ............. 25

General

................................ ................................ ................................ ................................ .................... 25

Operators

................................ ................................ ................................ ................................ ................ 25

Requirements

................................ ................................ ................................ ................................ ...... 25

Training

................................ ................................ ................................ ................................ ............... 25

Visual Observers

................................ ................................ ................................ ................................ ..... 25

Requirements

................................ ................................ ................................ ................................ ...... 25

Training

................................ ................................ ................................ ................................ ............... 25

Maintainers

................................ ................................ ................................ ................................ ............. 26

Requirements

................................ ................................ ................................ ................................ ...... 26

Training

................................ ................................ ................................ ................................ ............... 26

Operations

................................ ................................ ................................ ................................ .................. 27

Maintenance

................................ ................................ ................................ ................................ ........... 27

Training

................................ ................................ ................................ ................................ ................... 28

Flight

................................ ................................ ................................ ................................ ....................... 28

Privacy

................................ ................................ ................................ ................................ ......................... 31

Aircraft

................................ ................................ ................................ ................................ ........................ 33

DJI Innovations Phan tom 2

................................ ................................ ................................ ..................... 33

DJI Innovations Phantom 3

................................ ................................ ................................ ..................... 35

DJI Innovations Inspire

................................ ................................ ................................ ............................ 38

DJI Innovations Spreading Wings S1000

................................ ................................ ................................ . 42

Summary That Can Be Published In the Federal Register

................................ ................................ ........... 442

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Conclusion

................................ ................................ ................................ ................................ ................... 45

Appendices

................................ ................................ ................................ ................................ .................. 46

A. Avion Solutions Inc. Unmanned Aircraft Systems (UAS) Standard Operating Procedures

............. 46

B. DJI Phantom 2 Documentation

................................ ................................ ................................ ....... 47

C. DJI Phantom 3 Documentation

................................ ................................ ................................ ....... 48

D. DJI Inspire 1 Documentation

................................ ................................ ................................ ........... 49

E. DJI Spreading Wings S1000 Documentation

................................ ................................ ................... 503

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Glossary o f Abbreviations

AGL Above Ground Level

ATO Air Traffic Organization

AV Aerial Vehicle

Avion Avion Solutions Incorporated

C.F.R. Code of Federal Regulation

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CS Control Station

CTAF Common Traffic Advisory Frequency

DOD Department of Defense

FAA Federal Aviation Administration

FAR Federal Aviation Regulation(s)

FCC Federal Communications Commission

GCS Ground Control Station

GHz Gigahertz

NAS National Airspace System

NM Nautical Mile

NOTAM Notice to Airman

PIC Pilot In Command

POC Point of contact

R&D Research and Development

Avion Avion Solutions Inc.
Phantom Phantom Unmanned Aircraft System

RTB Return to Base

Section 333 FAA Modernization and Reform Act of 2012

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft Systems

UAS Unmanned Aircraft System(s)

VFR Visual Flight Rules

VLOS Visual Line of Site

VO Visual Observer4



### Summary Letter

July 02 , 2015 U.S. Department of Transportation
Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Exemption Request under Section 333 of the FAA Modernization and Reform Act of 2012
and 14 C.F.R. Part 11

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration ( FAA ) Modernization and Reform Act of 2012 and 14 CFR Part 11, Avion Solutions Inc.

, Operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein, as des cribed in the attached appendices, or as may be established by the FAA as required by Section 333.

These limitations provide for at least an equivalent or higher level of safety (LOS) to operations under the current regulatory structure. Specifically, Av ion Solutions Inc. will provide a safety
enhancement and economic relief to those individuals/corporations who currently rely on manned aircraft to perform aerial data collection services.

The issuance of these requested exemptions will permit Avion Solut ions Inc. to safely operate
UAS under controlled conditions and in the National Airspace ( NAS ) for the purpose s of UAS flight trainin g, research and development (R&D)

, and aerial data collection. Approval of this

e xemption request will provide for safe, professional , commercial UAS operations, and fulfill the FAA Administrator's responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system" Consistent with Section 333(c) of the
Reform Act

.5

Acknowledging the FAA’s mission to provide the safest and most efficient airspace system in the world, our commercial operation of UAS will comply with applicable FARs, as well as the
Avion Solutions Inc. Proprietary Standard Operating Procedures (SOP)

, to include safety,

tr aining and aircraft maintenance procedures , which are attached as appendices

.

Avion Solutions will operate its UAS in accordance with all applicable FARs, this exemption, and any additional guidelines as provided by the Administrat or.

Thank you for your consideration. Any additional information required by the FAA for approval purposes will be provided in an expedited manner.

Respectfully,

Evan Wagner Vice President, Chief Operating Officer Huntsville, AL 35805
Office: (256)

- 327

- 7109, Fax: (256)

- 721

- 7007
Email: ewagner@avioninc.com6

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Introduction and Interests o f Avion

Avion Solutions Incorporated (Henceforth identified as Avion Solutions or Avion) is a national engineering, logis tics, software engineering, test and evaluation small business, specializing in material solutions and technical support for military grade products. H eadquartered in Huntsville, Alab ama , t he company has been providing aviation related support to the U.S. Army for over 23 years in the form of contract support and subject matter expertise in a
number of technical areas and o n all of the Army 's rotary

- wing, fixed

- wing and u nmanned platfo rms. Avion has worked to develop a strong reputation for quality services within the military aviation community and is seeking to expand into the commercial UAS market.

Much of our company expertise is in aviation, with a workforce consisting primaril y of retired military aviators, maintainers, Airframe and Powerplant (A & P) mechanics, A & P with Inspection Authorization (IA), instructor pilots, maintenance test pilots, and technicians that support airworthiness standards. Avion has expertise in devel oping and conducting aviation related training in both the classroom and field environments. Avion Solutions will rely heavily on this experience and technical knowledge to operate commercial UAS in the NAS, develop unique product solutions, standardize U AS operating procedures, and train UAS Operator s and support elements in this highly technical field. Avion is focused on providing solutions for utilizing unmanned aircraft to safely and efficiently collect actionable data for the customer

.

Avion Soluti ons seeks exemption in order to commercially operate UAS in a n actively managed environment, for the purposes of training , conducting R&D , and aerial data collection

. Avion
proposes to use small, lightweight UAS for all of the requested operations

. A ircraft to be
utilized are electric powered rotorcraft

, equipped with four t o eight electric motors. The weight of these aircraft will not exceed 55 lbs., and they will be operated at all times by an
FAA and exemption compliant UAS Operator

. Additional information about the aircraft to be
utilized and key personnel can be found in this petition for exemption, and in the Avion SOP.7

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Basis f or Petition

Avion Solutions Inc. requests exemptions from several provisions of the FARs in accordance
with Section 333 of the FAA Modernization and Reform Act of 2012. Avion Solutions seeks exemption in order to commercially operate small Unmanned Aircraft Systems (sUAS) in a sterile environment clear of people and objects for the purposes o f training and educating UAS Operator s, Visual Observer s, and M aintainers . In addition to training

, A vion intends to
conduct research and d evelopment and data collection to include but not limited to, aerial survey, agricultural inspections, building/infr astructure inspections, aerial imagery for real estate purposes, and any other approved FAA UAS operations not associated with closed set cinematography.

Avion may update or revise its operating documents. Avion will track such revisions and present upd ated and revised documents to the Administrator or any law enforcement official
upon request. Avion will track all changes to documents approved in this Exemption Request in accordance with the Avion SOP. Avion will also present updated and revised docum ents if it petitions for extension or amendment to this grant of exemption.

Avion requests the included exemptions and offers the following docum ents located in the appendices for supporting information:

 Avion Solutions Inc. Unmanned Aircraft Systems ( UAS) Standard Operating Procedures

 DJI Phantom 2

o DJI Phantom 2 User Manual

o Phantom 2 Quick Start Guide

o Zenmuse H4

- 3D Gimbal Quick Start Guide

o Smart Flight Battery Safety guidelines

o Phantom 2 FPV Hub Kit Instructions v1.0

o Naza

- M(v2) Quick Start Guide v1.22

o 2.4G Bluetooth Datalink and iPad Ground Station User Guide v1.12

o DJI New Pilot Experience 2015

o Avion Solutions Phantom 2 Checklist

 DJI Phantom 3

o DJI Phantom 3 Professional User Manual v1.0

o DJI Phantom 3 Safety Guidelines and Disclaimer

o DJI Phantom 3 Professional Quick Start Guide

o DJI Phantom 3 Intelligent Flight Battery Safety Guidelines

o Avion Solutions Phantom 3 Checklist

 DJI Inspire 1

o DJI Inspire 1 User Manual v1.2

o DJI Inspire 1 Quick Start Guide v1.2

o DJI Intelligent Flight Battery Safety Guidelines

o DJI Inspire 1 Safety Guidelines8

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

o DJI Inspire 1 Maintenance Manual v1.0

o DJI Disclaimer & Warning

o DJI 1345s Quick Release Propellers for the Inspire 1 Quick Start Guide

o Avion Solutions Inspire 1 Checklist

 DJI Spreading Wings S1000

o DJI Spreading Wings S1000+ User Manual v1.2

o Avion Solutions S1000 Checklist9

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Name and Address o f Avion

The name and address of Avion is:

Avion Solutions Inc.
4905 Research Drive Northwest Huntsville, Alabama 35805

- 5905

The Signature Authority for this petition is :

Evan Wagner Vice President, Chief Operating Officer Huntsville, Alabama 35805 Office: (256)

- 327

- 7109, Fax: (256)

- 721

- 7007

E

- mail: ewagner@avioninc.com

The point of contact (POC) for this Petition is:

Craig “Taylor” Abington Jr.

Pro ject Lead, Commercial UAS
4905 Research Drive Northwest Huntsville, Alabama 35805

- 5905 Tel: (256) 327

- 7182 Fax: (256) 721

- 7007 Cell: (615) 604

- 1428

E

- mail: taylor.abington@avioninc.com
UAS@avioninc.com

Daniel Michael Carbone Assistant Project Lead, Commercial UAS
4905 Research Drive Northwest Huntsville, Alabama 35805

- 5905 Tel: (256) 327

- 7182 Fax: (256) 721

- 7007 Cell: (931) 302

- 2633

E

- mail: daniel.carbone@avioninc.com
UAS@avioninc.com10

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### 14 CFR Sections f

or Requested Exemption

The Federal Aviation Act expressly grants the FAA Administrator the authority to issue exemptions. By its terms, this statutory authority includes exempting civil aircraft, a s the term
is defined under § 40101 of the Act, including sUAS

, from its safety regulations and minimum standards when the Administrator decides a req uested exemption is in the public interest.

Avion asks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 , 61 and 91 for purposes of conducting aerial data collection, R&D, inspections and training utilizing

sUAS . Listed below a re: (1) the specific sections of 14 C.F.R. for w hich exemption is sought; (2) The extent of relief Avion seeks exemption; (3 ) the operating procedures and safeguards that

Avion has established which will ensure a level of safety equal to or higher than the rules from which exemption is sought. The full Code of Federal Regulations (Including the specific Title 14 requested exemptions) is available on eCFR.com, excerpts or recaps of these regulations
included in this document are for reference only.

S pecific sections of 14 C.F.R. for which exemption is sought:

Title 14

– Aeronautics and Space

PART 21

– CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

S ubpart h

- airworthiness certificates

PART 45

– IDENTIFICATION AND REGISTRATION MARKING

§ 45.23 (b )

– display of marks; general.
§ 45.27

– Location of marks; nonfixed

- wing aircraft.
§ 45.29

– size of marks

PART 61

– CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

§ 61.101 (e) (4) and (5)

– recreational pilot privileges and limitatio ns. § 61.113 (a) and (b)

– private pilot privileges and limitations: pilot in command

. § 61.315 (a) and (c)

– what are the privileges and limits of my sport pilot certificate?

PART 91

– GENERAL OPERATING AND FLIGHT RULES

§ 91.7 (a)

– civil aircraft airw orthiness.
§ 91.9 (b) (2) and (c)

– civil aircraft flight manual, marking, and placard requirements.
§ 91.103

– preflight action.
§ 91.109

– flight instruction: simulated instrument flight and certain flight tests.
§ 91.119

– minimum safe altitudes: general.11

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com PART 91

– GENERAL OPERATING AND FLIGHT RULES (cont.)

§ 91.121 (a) (1)

– altimeter settings.
§ 91.151 (a) (1)

– fue l requirements for flight in VFR conditions.
§ 91.203

– civil aircraft: certifications required.
§ 91.4 05 (a)

– maintenance required. § 91.407 (a) (1)

– operation after maintenance, preventive maintenance, rebuilding, or
alteration. § 91.409 (a) (1) and (2)

– inspections. § 91.417 (a) (1) and (2)

– maintenance records.

PART 21

– CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

Subpart h

- airworthiness certificates

The Extent Of Relief Avion Seeks Exemption:

Avion seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural requirements for the issuance of airworthiness certifi cates as required by 14 C.F.R § 91.203(a)(1). Given the size and limited operating area associated with the UAS to be utilized by Avion , 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

. 5

The Federal Aviation Act 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 criteria 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 rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

Equivalent Level of Safety: An equivalent level of safety for an exemption to the airworthiness requirements stated within Part 21, Subpart H

– airworthiness certificates, will be achieved by operating a UAS that is under 55 lbs, carries neither a pilot nor passengers, carries no explosive materials or flammable liquid fuels, and operat es exclusively within a known secured area as set out by the issuance of this exemption request and a Certificate of Authorization or Waiver (COA)

. Additionally, Avion will ensure compliance with any guidance regarding UAS airworthiness made by the FAA.

The FAA has issued the following exemptions to 14 CFR, Part 21, Subpart H

– Airworthiness requirements : Exemptions Nos. 10700, 8738, 10167 and 10167A.12

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com PART 45

– IDENTIFICATION AND REGISTRATION MARKING

§ 45.23 (b)

– display of marks; general.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.23 which identifies the registration number marking requirements for aircraft. This regulation requires aircraft to be marked with not less than nor more than 6 inch Roman lettering identify ing the aircrafts registered N

- number. This regulation also requires the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable, to be placed near the cockpit of the aircraft.
Given the size of the UAS to be op erat ed, two inch lettering is not possible. Official marking systems for small UAS have not yet been established by the FAA for operations inside the NAS. The aircraft utilized by Avion are not configured with a cockpit and are not currently identified by on e of the five classifications listed above.

Equivalent Level of Safety
Avion Solutions will meet an equivalent level of safety by placing the registered N

- Number on the aircraft as large as practical, utilizing Roman capital lettering. The ground contro l Station (GCS) will also be marked with the N

- number of the aircraft it is operating. The GCS will be marked in a manner similar to the aircraft, using Roman Capital lettering and as large as practical. These internal requirements for marking airc raft a nd GCS are identified in the Avion SOP. Additionally, Avion will ensure compliance with any guidance regarding UAS marking by
the FAA.

Given the nature of the specific relief sought by this exemption request, Avion requires relief
from the associated mar king and identification requirements of § 45.27 and § 91.9, which would require compliance with§ 45.23(b).

The FAA has issued the following exemptions to 14 CFR, § 45.23

– display of marks; general: Exemptions Nos. 10700, 8738, 10167 and 10167A.

§ 45.2 7

– Location of marks; nonfixed

- wing aircraft.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.27 which identifies the location of marks for non

- fixed wing aircraft. This regulation states that the Operator s of a rotorcraft must display the marks as required by §45.23 horizontally on both sides of the aircraft. Because this regulation specifically references compliance with §45.23, a regulation identified for exemption by Avion

, an exemption will be require d

.

Equivalent Level of Safety Avion will meet an equivalent level of safety by placing the registered N

- number on both sides of the aircraft in a location that allows for the largest possible lettering. The GCS will also be13

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com marked with the N

- number of th e aircraft it is operating. The GCS will be marked in a manner
similar to the aircraft as identified in the Avion SOP. The locations of all aircraft and equipment markings are identified in the Avion SOP. Additionally, Avion will ensure compliance with a ny guidance regarding UAS marking/location by the FAA.

The FAA has issued the following exemptions to 14 CFR, § 45.27

– Location of marks; nonfixed

wing aircraft: Exemptions No

. 11188

§ 45.29

– size of marks

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.29 which establishes the size requirements for markings on aircraft. This regulation specifically identifies height, width, thickness and spacing of marks. It also calls out a 12 inch height requirement for marks on rot orcraft.

Avion has requested exemption from § 45.23 and § 45.27, which cover the display and
location of marks on aircraft. Due to the size of the UAS to be operated, twelve inch lettering

is no t possible, and a standard for UAS marking has not yet been identified by the FAA.

Equivalent Level of Safety Avion will meet an equivalent level of safety by placing the registered N

- number on both sides of the aircraft in a location that allows for the largest possible lettering. The GCS will also be
marked with the N

- number of the aircraft it is operati ng. The GCS will be marked in a manner
similar to the aircraft as identified in the Avion SOP. The locations of all aircraft and equipment markings are identified in the Avion SOP . Additionally, Avion will e nsure compliance with any guidance regarding UAS marking/location by the FAA.

The FAA has issued the following exemptions to 14 CFR, § 45.29

– size of marks : Exemptions Nos. 11136, 11157, 11170, 11185, 11193

PART 61

– CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

§ 61.101 (e) (4) and (5)

– recreational pilot privileges and limitations. § 61.113 (a) and (b)

– private pilot privileges and limitations: pilot in command. § 61.315(a) and (c)

– what are the privileges and limits of my sport pilot certificate?

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 61.101 (e) (4) and (5), § 61.113 (a) and (b), and § 61.315(a) and (c). These parts estab lish that a person who holds a Recreational, Private, or S port pi lot certificate may not act as pilot in command of an aircraft for compensation or hire, or, in furtherance of a business. Regulations iden tifying the requirements for a UAS pilot have not yet been established by the FAA. The FAA has however approved exe mptions requiring the14

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Operator of an UAS to hold at a minimum a Sport Pilot certificate. Additionally, Avion will

ensure c ompliance with any guidance regarding UAS pilot certifications by the FAA.

Equivalent Level of Safety Pilots operating a UAS for Avi on will hold at a minimum, a Sport P ilot certificate. Each pilot will maintain currency requirements for the rating they hold as required by the appropriate FARs. Avion will maintain flight and currency records for all pilots operating Avion UAS. The

mi nimum training standards will be met prior to the operation of any aircraft for commercial use. Training will be conducted during specific training flights and recorded per the Avion

SOP.

The FAA has issued the following exemptions to § 61.101 (e) (4) an d (5)

– recreational pilot privileges and limitations. § 61.113 (a) and (b)

– private pilot privileges and limitations: pilot in
command. Exemptions Nos. 11371, 11370, 11388

PART 91

– GENERAL OPERATING AND FLIGHT RULES

§ 91.7(a)

– civil aircraft airwort hiness.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be operated. There are currently no airworthiness certificates for the UAS
identified in the Exemption Request. Because there are no airworthiness certificates for these UAS, there is no standard on which to base an airworthy condition

. Additionally, Avion will ensure compliance with any guidance regarding UAS airworthiness by the FAA.

Equival ent Level of Safety
All Avion Operator s will rec eive training to accurately pre

- and post

- flight any UAS in which the Operator is r ated . Given the size of the UAS

, the requirements contained in the
manufacturer’s user manual

, and the use of safety checklists prior to each flight, an equivalent level of safety will be provided. Avion will maintain a maintenance log book and record any/all deficiencies noted during pre

- flight, flight and post

- flight inspections. The corrective actions required/taken to return the aircraft to service will be logged in accordance with the appropriate manufacture r’s manual and the Avion SOP.

The FAA has issued the following exemptions to § 91.7(a)

– civil aircraft airworthiness : Exemptions Nos

. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 1111015

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com § 91.9 (b ) ( 2) and (c )

– civil aircraft flight manual, marking, and placard requirements.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.9 (b) (2) and (c) which provide that n o person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter and has a current approved rotorcraft flight manual available in the aircraft

. Compliance with § 91.9 i s impossible given the exemptions requested from specific portions of part 45 earlier in this document , and the lack of space on the aircraft for rotorcraft manual placement . Additionally, Avion will ensure compliance with any guidance regarding UAS
markin g/placarding requirements by the FAA.

Equivalent Level of Safety

Avion has requested an exemption from § 45.23

– display of marks; general, § 45.27

– Location of marks; non fixed

- wing aircraft, and § 45.29

– size of marks. Due to the request for exemption from these regulations, Avion will not be able to comply with § 91.9. As previously stated Avion will maintain an equivalent level of safety by marking the aircraft in the most practicable manner. Avion will maintain all of the required documentation for flight, to
include a manufacturer ’ s rotorcraft flight manual ( or equ ivalent) accessible to the Operator of
the UAS at all times of operation . The documentation to be maintained and its location are
outlined in the Avion SOP.

The FAA has issued the following exemptions to § 91.9 (b)(2)

– civil aircraft flight manual,
mark ing, and placard requirements: Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195, 11204

.

The FAA has issued the following exemptions to § 91.9 (c)

– civil aircraft flight manual, marking, and placard requirements: Exemptions Nos

. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 1 1114, 11136, 11138, 11150, 11153, 11156, 11157, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11174, 11177, 11178, 11184, 11185, 11189, 11192, 11193, 11195.

§ 91.103(b) (2)

– Preflight action.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from§ 91.103 (b) (2), which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA approved Flight Manual on board the aircraft. Because an FAA approved flight manual will not be provided fo r the aircraft , an exemption is requested. Additionally, Avion will ensure compliance with any guidance regarding UAS preflight actions by the FAA.16

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Equivalent Level of Safety An equivalent level of safety will be provided by following the Avion Solutions Inc. a ircraft comprehensive checklist s . The Operator will take all actions, including reviewing weather, flight battery requirements, landing and t akeoff clearance , and aircraft performance data, before initiation of flight.

The FAA has issued the following exemptions to § 91.103(b) (2)

– Preflight action : Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 11153, 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176,11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

§ 91.109 (a)

– flight instruction: simulated instrument flight and certain flight tests

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from 14 C.F.R. § 91.109(a), which 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 functional dual controls.” Remotely piloted aircraft and UAS, by their design

, do not have fully functional dual controls. Aircraft control surface manipulation is accomplished through the use of an electronic controller, communicating with the UAS via FCC approved radio communications

. Additional ly, Avion will ensure compliance with any guidance regarding UAS flight instruction by the FAA.

Equivalent Level of Safety

G iven the size and speed of the UAS, an equivalent level of safe training can still be performed without dual controls because no pi lot or passengers are aboard the UAS. All personnel unrelated to the training event will be a safe distance away in the event that the UAS Operator experiences any difficulties during flight instruction. All flight training will be conducted during
dedi cated training sessions, in a dedicated training area. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft.

The FAA has issued the followi ng exemptions to § 91.109 (a)

– flight instruction: simulated instrument flight and certain flight tests: Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 1 1 109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 11184, 11185, 11189, 11191, 11192, 11193, 11194, 11195, 11206, 1120817

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com § 91.119

– minimum safe altitudes: general.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. This Section prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non

- congested areas. Section § 91.119(d) (l) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the h elicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA.

During certain types of operations

, to include but not limited to aerial inspections, the UAS will be required to maintain a distance of approximately 50 f eet or less in order to collect the necessary data. Because of these operation requirements an exemption from this regulation is required. Additionally, Avion will ensure compliance with any guidance regarding UAS
minimum safe altitudes by the FAA.

Equi valent Level of Safety Compared to flight o perations with rotorcraft weigh ing far more than the maximum aircraft weight proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented wi th conventional aircraft. An equivalent level of safety will be a chieved given the size, weight and speed of the UAS as well as the location where it is operated. Personnel associated with flight operations will be briefed of the expected route of flight a nd the associated risks to per sons and property on the ground prior to conducting flight operations.

The FAA has issued the following exemptions to § 91.119

– minimum safe altitudes: general : Exemptions Nos. 11162 , 11163, 11164, 11165, 11166, 11108, 11 109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

§ 91.121 (a) (1) : Altimeter Settings

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.121 (a) (1) , a regulation which requires an aircraft operator to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exe mption is required
because the UAS does not have a barometric altimeter, but rathe r a GPS altitude shown in an

on

- screen display.

Equivalent Level of Safety An equivalent level of safety will be achieved by following t he procedures set forth in the

airc raft checklists

. Prior to lifting off the Operator will confirm a zero altitude reading, and18

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com monitor this reading as the aircraft climbs to a hover following take off. The Operator will use the GPS altitude indicator to constantly monitor the UAS height, thus ensuring operation at
safe altitudes (Below 400 Ft AGL)

. Select aircraft, to include the Inspire 1 and Phantom 3 employ the use of a Vision Positioning Sensor (VPS) to maintain stable flight at low altitudes. All of the aircraft to be utilized by Av ion have t he ability to program maximum allowable
altitude. This maximum altitude limit will be confirmed at 400 Ft AGL prior to flight.

The FAA has issued the following exemptions to § 91.121: Altimeter Settings : Exemptions Nos. 11162, 11163, 1116 4, 11165, 11166, 111080, 111109, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

§ 91.151 (a) (1)

– fuel requirements for flight in VFR conditions.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.151 (a) (1) which identifies the Fuel requirements for flight in VFR conditions. A “fuel requirement ” to reach the first point of intended landing is achievable by all of the aircraft in whi ch Avion will operate. A “fuel reserve ” of at least thirty

minutes is not achievable . The aircraft that Avion intends to operate have a maximum flight time of approximately 25 minutes. Additionally, Avion will ensure compliance with any guidance regarding UAS f uel requirements by the FAA.

Equivalent Level of Safety
Avion Solutions has developed an extensive series of checklists, mission briefs and safety/risk

matrices. All Avion Operator s and Visual Observer s wi l l actively monitor the battery status to

ensure safe levels of operation, and at no time will the aircraft be operated at a distance where it cannot, under its own power return to the origination point. The UAS are set for low battery warning at thirty percent (30%) and automatic “Return to home” at ten percent (10%) battery power. These internal standards can be reviewed in the Avion SOP.

The FAA has issued the following exemptions to 14 CFR, § 45.27

– Location of marks; nonfixed

wing aircraft: Exemptions Nos. 10700, 10167, 10167A

, 11110, 11153, 111 56, 11161; 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11160, 11161, 11166, 11167, 11170, 11171, 1 1 172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

§ 91.203(a) (1)

– civil aircraft: certifications required

.

The Extent of Relief A vion Seeks Exemption

Avion seeks an exemption from § 91.203(a) (1) which identifies that no pilot may operate any aircraft unless it has an appropriate and current airworthiness certificate. Currently, none of the aircraft to be utilized by Avion hold an airworthiness certificate. Avion will maintain each19

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com aircraf t to a level equivalent to the aircraft’s original condition as determined by the aircraft
manufacturer. Aircraft will be inspected routinely in accordance with the manufacture
manuals and the Av ion SOP. Additionally, Avion will ensure compliance with any guidance regarding airworthiness requirements by the FAA.

E quivalent Level of Safety
Avion Solutions will maintain strict adherence to its SOP and maintenance standards. Operator s and M aintainers will ensure that all aircraft are maintained to the aircraft
manufacture r specifications, and that all maintenance is properly logged in accordance with
the SOP. In the event that specific maintenance technique s are n ot outlined in the
manufact urer manuals, m aintenance will be performed utilizing standard aviation maintenance practices as identified in AC 43.13

- 1B

- Acceptable Methods, Techniques, and

Practices

- Aircraft Inspection and Repair. Maintenance records for each aircraft will be

av ai lable for inspection at the Avion Solutions Inc. building.

The FAA has issued the following exemptions to 91.203(a) (1)

– civil ai rcraft: certifications required : Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111,

11112

, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195

§ 91.405 (a)

– maintenance required. § 91.407 (a) (1)

– operation after maintenance, preventive maintenance, rebuilding, or

alteration. § 91.409 (a) (1) and (2)

– inspections. § 91.417 (a) (1) and (2)

– maintenance records

.

The Extent of Relief Avion Seeks Exemption

Avion seek s exemption from § 91.405 (a)

, § 91.407 (a) (1), § 91.409 (a) (1) and (2), and §

91.417 (a) (1) and (2) . These regulations address maintenance activities and require that an aircraft operator or owner, “shall have that aircraft inspected as prescribed in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...” and others shall inspect or maintain the aircraft in compliance with Part 43.

The four UAS airframes identified in this exemption request do not hold an airworthiness certificate; t herefore they may not be maintained in accordance with the above regulations.

Equivalent Level of Safety

Because Avion Solutions is an aviation centric

, company we understand the absolute requirement for safety during flight operations, and the equivale nt requirement during maintenance performed on the aircraft and its systems while on the ground. An equivalent level of safety will be achieved by maintaining the UAS in accordance with the manufacturer’s guidelines

. W hen no manufacturer reference is ava ilable, standard aviation maintenance20

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com practices will be utilized . An aircraft logbook will be maintained for each airframe and a ll maintenance performed, to include functional test flights

, will be logged

. A dditional information in regard to maintenance can be found in this P etition and the Avion SOP.

The FAA has issued the following exemptions to § 91.405 (a)

– maintenance required

, § 91.407 (a) (1)

– operation after maintenance, preventive maintenance, rebuilding, or altera tion, §

91.40 9 (a) (1) and (2)

– inspections, and § 91.417 (a) (1) and (2)

– maintenance records : Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 1120421

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Reasons Why Requested Exemption Would Be In Public Interest

By granting this exemption request, Avion Solutions will be able to promote the fundamentals of safe UAS operations to students who participate in our training programs. Our training methods were developed to help new operators identify the risks associated with these operations and to prepare for and mitigate them. By c ultivating a growing industry of UAS professionals, Avion is acting in the public interest, as this ensures that future operators are sufficiently trained with an added level of awareness and safety when conducting UAS operations.

Avion’s existing relatio nships within the aerospace community promote awareness of UAS operations and the inherent benefits of their use. G ranting this petition allows Avion to share valuable experience obtained through operations and training, and promote the UAS research
effor ts of policymakers including the FAA, NASA, and DoD. This would provide significant
benef its to the public interest

.

Avion Solutions is an active member of the Huntsville community. Our participation in local events gives us an opportunity to address the safe and responsible use of unmanned aircraft during public awareness campaigns, local technology events, school job fairs, law enfor cement demonstrations, and hobby/RC events. Public education is critical for two reasons; 1) If the public has a better understanding of the UA and how it can be used safely, they will be less likely to fear or dismiss the technology, and 2) Hobbyists and private owners of UA learn the repercussions of not adhering to FAA requirements from both a legal and a safety standpoint. For these reasons, granting this exemption request would provide a benefit to the public interest that would continue to grow over time.

The efficiency of utility operations is heavily dependent upon constant monitoring of assets and facilities, right

- of

- way, vegetation encroachment, and infrastructure inspection. There are a wide variety of factors that can affect operating conditio ns and cause problems for infrastructure. Avion’s UAS services would provide the capability to identify and report infrastructure damage. This would greatly reduce downtime and improve the cost, speed, and efficiency of repair efforts resulting in a measur able benefit to the public interest.

Avion Solutions currently works closely with the Alliance for System Safety of UAS through Research Excellence (ASSURE) which includes twenty

- one of the world’s leading research universities and a hundred leading indus try and government partners. Through ASSURE, Avion supports UAS research and development efforts associated with Air Traffic Control Interoperability, Airport Ground Operations, Control and Communication, Detect a nd Avoid (DAA), Human Factors, Low Altitud e Operations Safety, Noise Reduction, UAS Traffic Management (UTM), and a number of additional research topics of interest to the FAA and the NAS. Avion will leverage our aviation experience and provide valuable input to these programs, proving our commit ment to safe integration of UAS into the NAS.

Given the clear direction in Public Law 112

– 95 § 333, the equivalent level of safety22

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com surrounding the proposed operations, and the significant public benefit including reduced noise levels and lower operatin g costs through more efficient equipment, granting this petition is deemed to be in the public interest.23

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Reasons Granting Exemption Would Not Adversely Affect Safety

The enhanced safety achieved using an unmanned aircraft (UA) with the specifications
des cribed within this petition and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, would provide the FAA good cause to find that the UAS operation enabled by this exemption would not adversely affect safety

.

Prior to conducting any UAS operations, Avion will conduct a mission brief as identified in the Avion SOP. Aircrews will also conduct a risk assessment and discuss any additional safety issues identified by the client before conducting UAS operations. All Avion UAS aircrew members will comply with quali fication, currency, and training requirements as outlined in the Avion SOP prior to conducting flight operations. Safety to the public and property will be of the highest priority when conducting flight operations. Avion will only employ well trained and competent Operators and VOs. Operations will be conducted through the use of checklists to ensure safe, predictable, and consistent outcomes.

All current and future UAS operated by Avion will employ the use of automated safety features to provide an addi tional level of safety in the event of a lost communications link between the Operator and aircraft. The automated safety features will direct the UA to a pre

determined “home” point if the control signal is interrupted. This same feature will safely land the aircraft in the event of a low battery condition. Avion will continue to pursue technology which employs the use of sensors on future platforms. These safety features are designed to improve the level of safety and not adversely affect it.

Avion wi ll conduct annual safety training and document this training in accordance with the Avion SOP. Training will include current practices, lessons learned from prior operations, FAA guidance and policy, and industry

- specific safety measures. Flight data, ins pection results, recorded observations and lessons learned from UAS operations will be periodically compiled and reviewed to further enhance Avion’s current safety program.

Based on Avion Solutions ’ extensive manned and unmanned aviation experience, grant ing an exemption would not adversely affect safety. Avion employees already adhere to exacting military aviation safety standards, and our industry partnerships with like

- minded organizations prove Avion’s commitment to safety. Avion will also abide by l ocal safety laws and ordinances and communicate with the proper authorities if discrepancies or inconsistencies exist that might adversely affect safe operation.

Avion ’s proposed operations to perform training, R&D, and aerial data collection will reduce the unnecessary exposure of personnel and property to dangerous activities by decreasing the requirement for personnel to climb structures and/or operate costly manned aircraft. This would not adversely affect safety, but instead greatly reduce the level of risk associated with performing these operations.24

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com The limitations provided by the FARs, this exemption request, and any additional guidance provided for commercial UAS operations by the FAA Administrator, will ensure a level of safety previously una ttainable by manned aircraft. Based on the size and the limited area of operations of the aircraft, approval of this request presents no threat to National Security.25

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Key Personnel

General

All Avion Solutions employees participating in UAS activities will receive formal UAS training in the area of their assigned responsibility. This training will be outlined and tracked in
accordance with the SOP.



### Operator

Requirements

 Must hold at a minimum a sport pilot certificate

.

 The PIC must also hold a current FAA airman medical certificate as required for the type of certificate held

.

 Must meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the Operator is rated as identified on the pilot certificate.

 Must meet UAS flight hour minimums as outline in the SOP.

 Must meet all training requirements of the assigned responsibility in accordance with
the SOP.

Training

 5 flight hour minimum, per airframe prior to operating commercially.

 1 0 flight hour minimum, per aircraft type prior to operating commercially.

 25 flight hour minimum total UAS time prior to operating commercially.

 Completion of UAS Operator Training IAW the SOP.

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operator Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP.



### Visual Observer

Requirements

 Must meet all training requirements of the assigned responsibility in accordance with
the SOP.

Training

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operator Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP.26

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Maintainer

Requirements

 Must exhibit familiarity with the aircraft systems being operated.

 Must comply w ith all maintenance guidelines for aircraft in accordance with manufacturer manuals, safety bulletins, guidelines and warnings.

 Must comply with all guidelines for per forming aircraft maintenance in accordance
with the SOP.

 Must comply with all guidelines for documentation of aircraft maintenance in
accordance with the SOP

 Must meet all training requirements of the assigned responsibility in accordance with
the SOP.

Training

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operato r Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP.27

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Operations

Maintenance

Avion will perform all maintenance activ ities, to include inspections, preventive maintenance,
and condition based maintenance in accordance with the manufacturer’s manuals. When the manufacturer documentation does not identify specific maintenance procedures, best maintenance practices will be utilized and recorded in the aircraft logbook. All maintenance
activities will be recorde d in the aircraft logbook and will include the following items:

 Date of work performed

 A ircraft total time in service

 Description of the work accomplished

 Signature of the individual who performed the work

 Certificate number and type being exercised

A squawk sheet will be available for aircraft Operator s to denote faults identified during pre

and post

- flight inspections. The squawk sheet may be inserted into the air craft logbook, or entries may be transposed directly into the logbook by the original entry maker. The Squawk
sheet is identified in the Avion SOP.

Functional test flights will be performed following maintenance/modifications that affect flight

charact eristics, and/or the replacement of flight critical components. Functional test flights
will be conducted in accordance with the Avion SOP and will be annotated in the aircraft logbook.

When modifications to an aircraft are made for research and development, or when mission equipment is i nstalled/removed, an entry will be made in the aircraft logbook. In addition to a logbook entry and a functional test flight, the performing activity will complete an aircraft
b asic weight and configuration form in order to ensure aircraft maximum operating weight compliance. This form is identified in the Avion SOP.

The most current firmware available from the manufacturer will be installed and verified in
the aircraft, GCS and any additional equipment as required, prior to flight. Avion will adhere to any safety or flight critical related bulletins for the aircraft being operated.28

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Training

Training will be conducted for all personnel involved in the pre

- flight, mi ssion, and post

- flight
activities associated with commercial UAS operations. Training will be conducted in
accordance with the Avion SOP by assigned responsibility . All training will be conducted in a sterile training environment. Training flights will be conducted during dedicated sessions only,
and will include a Visual Observer at all times.

Training requirements and standards for each key personnel is outlined above and in the

Avion SOP . Key personnel include Operator s , Visual Observer s /P ayload Operator s and

M aintainer s

. Each of these key personnel will maintain proficiency in their respective areas by adhering to the Avion SOP currency/training requirements. Training and currency will be logged in individual logbooks and will be available for review. Training reviews will be conducted annually to ensure that the most recent and effective training procedures/standards are being utilized.



### Flight

No flight operations will be conducted with less than the Avion SOP approved minimum personnel, which includes an aircraft Operator and a Visual Observer

. All missions will be
briefed in accordance with the Avion Air Mission Brief prior to flight. The pr operty owner will
be brief ed on the operation and a Risk A ssessment will be performed prior to flight. Safety procedures are addressed in the Avion SOP. The aircraft Operator will perform all of the required preflight inspections and document as necessar y.

All operations will include a VO, and the VO may be used to satisfy the Visual Line of Sight (VLOS) requirement. The VO and aircraft Operator must maintain positive communication and have the ability to monitor Common Traffic Advisory Frequency (CTAF ) frequencies to ensure
manned aircraft avoidance.

At no time will the Visual Observer perform VO duties for more than one aircraft at a time.

At no time will the Operator of an Avion UAS manipulate an aircraft from a moving vehicle.
The UAS shall n ot be flown at a ground speed exceeding 30 mph.

All flights will be documented on the Flight Log and all flight time will be accounted for on the Flight Log, including the reason for the flight (purpose of the mission).

All flight operations will be co nducted at least 500 feet from nonparticipating personnel, unless blockades or physical barriers are present, providing a protective layer between operations and bystanders. If at any time nonparticipating persons encroach on the 500 foot safety zone, fli ght operations will be aborted immediately.29

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Operations of a n Avion UAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such p ermiss ion, and the Operator makes a safety assessment of the risk from operations and determines that it does not present an undue hazard to persons or
property . Personnel participating in flight training, or required for operations during flight are permitted within the 500 foot safety zone. These required personnel are to maintain a safe distance from both critical flight crew personnel and the UAS to ensure an appropriate level of safety at all times.

At no time will Avion operate a UAS above 400 FT above ground level (AGL). All operations will be conducted under Visual Meteorological Conditions (VMC) . Avion UAS will not be operated less than 500 feet below, or 2000 feet horizontally from a cloud, or if visibility is less than the identified 3 statute mile requirement.

UAS flights will not be operated in Class A, B, C, or D airspace but may be operated in class E and G airspace, provided the UASs Operator /Observer maintains visual line of sight with the
UASs and safe se paration from actual certificated aircraft in the airspace.

The aircraft documentation required by 14 CFR, § 91.9 and § 91.203 shall be available to the Operator a t the GCS of the UAS anytime the aircraft is operating. This documentation shall be
availabl e to the Administrator or any law enforcement official upon
request.

UAS Operator shall not begin an operation unless there is enough battery power for the aircraft, in a normal flight attitude, to land at the Home Point with at least 25% power

remainin g.

Aircraft Operator must abort the flight in the event the aircraft strikes an object, or an emergency is identified by any of the flight crew personnel. If the UAS loses positive control
link from the Operator , the aircraft must automatically return to the briefed Home Point.

All aircraft operations will be conducted in accordance with this exemption, the Avion SOP, and any additional guidelines provided by the FAA.

Avion Solutions will request a Notice to Airman (N OTAM) between 48 and 72 hours prior to
each mission.

UAS accidents, incidents or flights that transgress the boundaries of the operational area as defined by the applicable certificate of authorization (COA) shall be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 ho urs. Accidents shall be reported to the National Transportation Safety Board (NTSB) In accordance with the NTSB Web site: www.ntsb.gov.

UAS Operator shall remain clear of and yield right of way to all manned aircraft.30

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com UAs will be identified by N

- number, with markings as large as practicable.

Avion Solutions shall hold an Air Traffic Organization (ATO) issued COA before operating under this exemption request.

Unless otherwise specified by the Administrator, the PIC, and Operator must comply w ith all applicable parts of 14 C.F.R. including, but not limited to, parts 45, 47, 61, and 91.31

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Privacy

Respect for civil rights and civil liberties is a core tenet of our democracy. As with all data collection methods, UAS must be operated consistent wi th the U.S. Constitution. The Fourth Amendment protects individuals from unreasonable searches and seizures and generally requires law enforcement to seek a warrant in circumstances in which a person has a reasonable expectation of privacy. Despite the pro ven effectiveness of UAS technology

, concerns about privacy threaten to overshadow the benefits it pro mises to bring to public safety.

Avion 's proposed operations will create no privacy issues. The UAS will be operating in rural and populated areas withi n the vertical boundaries of the designated property. When possible, UAS will utilize Geofencing software to ensure airspace compliance and restrict operations in areas that may affect the privacy of adjacent landowners. All operations will be
conducted with the property owner’s written consent provided on the Avion Solutions UAS Operations Release Form; this form is available for reference in the Avion SOP. Avion
Solutions Inc. will also obtain any permits or authorizations from local authorities, facil ity managers, or event managers when necessary, and the approval of any/all parties participating in the aerial data collection/training operation.

Documentation related to aerial data collection operations will be available to local authorities

on site and at Avion Headquarters. Mission related data will be kept on file for a minimum of one year and will then be destroyed IAW Avion Privacy Policy. All missions will be evaluated to ensure that data that is unrelated to the specified use will be minimized

.

Avion will not infringe on any individual or landowner privacy rights. If a non

- participating individual poses a safety risk prior to or during an operation, the mission commander will
abort the mission and re

- evaluate the mission scenario.

Avion wi ll take steps to protect against unauthorized disclosure of any information or data through the use of encrypted video downlink signals, positive control of removable media, and proper destruction of data that is not required or relevant to the operation.

Avion personnel will be trained to understand and abide by all relevant federal legal privacy standards applicable to the use of UAS, and to seek advice from legal counsel as necessary.

Avion will make every attempt to avoid use of UAS in a manner that co uld be considered intrusive relative to individuals' privacy and civil liberties.

Prior to using UAS, Avion will assess the relative intrusiveness of the proposed use of UAS, and balance it against the particular need. This is both a logical process and a n exercise in judgment, but the overall principle remains: in deciding whether to use UAS, Avion personnel must consider and, if reasonable based on the facts and circumstances of the mission, use the least intrusive means to accomplish an operational need

.32

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Avion will only collect, use and disseminate information obtained from UAS for an authorized purpose. Data collected by UAS that is retained must be safeguarded in accordance with applicable Federal laws, Executive Orders, directives, policies, regulatio ns, standards, and guidance. These authorities ensure that Avion personnel with access to such data follow practices that are consistent with the protection of privacy and civil liberties.

Avion will conduct annual privacy reviews of the organization’s u se of UAS to ensure compliance with existing laws, regulations, and company policy, and to identify potential privacy risks. Avion will also, where appropriate, make recommendations to ensure that UAS
will continue to be used in a manner consistent with th e U.S. Constitution and all applicable laws, regulations, and policies, including those protecting privacy and civil liberties.33

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Aircraft

DJI Innovations Phantom 2

Figure 1 Aircraft Specifications:

Aircraft Operating Environment Temperature

- 10° C to 50°C Power Consumption 5.6 W Supported Battery DJI Intelligent Battery Weight(including the Battery) 1000g

Take

- off Weight ≤1300g Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Hor izontal: 2.5m Max Yaw Angular Velocity 200°/s Max Tilt Angle 35° Max Ascent/Descent Speed Ascent: 6m/s; Descent: 2m/s Max flight speed 15m/s (Not Recommended)

Wheelbase 350 mm

2.4GHz Remote Controller Operating Frequency 2.4 GHz ISM Communication Distance (open Areas) 1000m Receiver Sensitivity (1%PER)

- 97dBm Working Current/Voltage 120 mA@3.7V

Built

- in LiPo Battery Working 3.7V, 2000mAh34

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Current/Capacity

DJI Intelligent Battery
Type 3S LiPo Battery Capacity 5200mAh, 11.1V Charging Environment Range 0°C to 40°C Discharging Environment Range

- 20°C to 50°C

Previous FAA approvals for commercial operation of the Phantom 2 aircraft: Exemption Nos. 11442, 11388, 1135135

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### DJI Innovations Phantom 3

Figure 2

Aircraft Specifications:

Aircraft Weight (Battery and Propellers included) 1280 g Max. Ascent Speed 5 m/s Max. Descent Speed 3m/s Max. Speed 16 m/s (ATTI mode, no wind) Max. Flight Altitude 6000 m Max Flight time Approximately 23 Minutes Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

Gimbal Controllable Range Pitch:

- 90° to +30°

Vison Positioning System Velocity range < 8 m/s (2 m above ground) Altitude range 30 cm

- 300 cm Operating range 30 cm

- 300 cm Operating environment Brightly lit (Lux > 15) patterned surfaces

Camera

Sensor Sony EXMOR 1/2.3” Effective Pixels 12.4M36

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com (Total Pixels: 12.76M)

Lens FOV 94° 20mm(35mm format equivalent) f/2.8
ISO Range 100

- 3200(video) 100

- 1600(photo) Electronic shutter speed 8s

– 1/8000s
Image Max. size 4000 x 3000 Still photography modes Single shot Burst shooting:3/5/7 frames Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7 EV bias

Time

- lapse Supported SD card types Micro SD Max Capacity: 64 GB.
Class 10 or UHS

- 1 Rating Required Video recording modes UHD: 4096 x 2160p 24/25, 3840 x 2160p 24/25/30 FHD: 1920 x 1080p 24/25/30/48/50/60 HD: 1280 x 720p 24/25/30/48/50/60

Max. Bitrate of video
storage 60 Mbps

Supported file formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264)
Operating temperature

range 0°C to 40°C

Remote Controller Operating Frequency 2.4 GHz

– 2.483 GHz Communication Distance (Open Areas) 2000 m (Outdoor and Unobstructed) Video Output Port USB Operating Temperature Range 0°C to 40°C
Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and Smartphone Transmitter Power(EIRP) FCC: 20 dbm; CE: 16 dbm Working Voltage 1.2 A @ 7.4 V

Charger Voltage 17.4 V

Rated Power 100 W

Intelligent Flight Battery (PH3

- 4480 mAh

– 15.2 V) Capacity 4480 mAh Voltage 15.2 V
Battery Type LiPo 4S37

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Energy 68 Wh Net Weight 365 g Operating Temperature

- 10°C to

- 40°C Max. Charging Power 100 W

App / Live View Mobile App DJI Pilot

EIRP 100 mW Live View Working Frequency 2.4 GHz ISM Liew View Quality 720P @ 30fps (Depending on conditions
and mobile device) Mobile Device System Requirements iOS 7.1 or later; Android version 4.1.2 or
later Supported Mobile Devices iPhone 6 Plus, iPhone 6, iPhone 5S, iPad Air2, iPad mini 3, iPad Air, iPad Mini2, iPad , Samsung Note 3, Samsung S5, Sony Z3 EXPERI A. Note: It is recommended that you use a tablet for the best experience.

Previous FAA approvals for commercial operation of the Phantom 3 aircraft: Exemption Nos. 11872, 11802, 1180138

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### DJI Innovations Inspire

Figure 3

Aircraft Specifications:

Aircraft

Model T600 Weight (Battery include) 2935 g Hovering Accuracy(P mode) Vertical: 0.5 m
Horizontal: 2.5 m Max. Angular velocity Pitch: 300°/s Yaw: 150°/s Max. Tilt Angle 35° Max. Ascent Speed 5 m/s Max. Descent Speed 4 m/s Max. Speed 22 m/s (ATTI mode, no wind) Max. Flight Altitude 4500 m Max. Wind Speed Resistance 10 m/s Max Flight time Approximately 18 Minutes

Motor Model DJI 3510 Propeller Model DJI 1345 Indoor hovering Enabled by Default Operating Temperature Range - 10°C to 40°C

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm39

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Gimbal

Model ZENMUSE X3 Output Power (With Camera) Static: 9 W; In Motion: 11 W Operating Current Station: 750 mA; Motion: 900 mA Angular Vibration range ± 0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30°
Pan: ± 320° Mechanical Range Pitch:

- 125° to +45°
Pan: ± 330° Max. Controllable Speed Pitch: 120°/s Pan: 180°/s

Camera

Name X3

Model FC350

Total Pixels 12.76M
Effective Pixels 12.4M Image Max. Size 4000 x 3000 ISO Range 100

- 3200(video) 100

- 1600(photo) FOV (Field of View) 94°

CMOS Sony EXMOR 1/2.3”

Lens 20mm (35mm format equivalent) f/2.8 focus at ∞ 9 elements in 9 groups

Anti

- distortion Still photography modes Single shot Burst shooting:3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 Bracketed

Frames at 0.7 EV bias

Time

- lapse Video recording modes UHD (4K): 4096 x 2160p 24/25, 3840 x 2160p 24/25/30 FHD: 1920 x 1080p 24/25/30/48/50/60 HD: 1280 x 720p 24/25/30/48/50/60 Max. Bitrate of video storage 60 Mbps Supported file formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD card types Micro SD Max Capacity: 64 GB.
Class 10 or UHS

- 1 Rating Required40

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Operating temperature

range 0°C to 40°C

Remote Controller

Model C1 Operating Frequency 5.725 ≈ 5.825 GHz: 2.400 ≈ 2.483 GHz Transmitting Distance 2 km (Outdoor and Unobstructed)

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB Power Supply Built

- in Battery Charging DJI Charger Dual User Capability Host

- and

- Slave Connection

Mobile Device Holder Tablets and Smartphone Operating Temperature Range 0°C to 40°C

Storage Temperature Range Less than 3 months:

- 20° to 45°C
More than 3 months: 22° to 28°C Charging Temperature Range 0

– 40°C
Battery 6000 mAh LiPo 2S

Charger

Model A14

– 100P1A Voltage 26.3 V

Rated Power 100 W

Battery (Standard)

Name Intelligent Flight Battery

Model TB47 Capacity 4500 mAh Voltage 22.2 V
Battery Type LiPo 6S High Voltage Battery
Energy 99.9 Wh Net Weight 570 g Operating Temperature

- 10°C to 40°C Storage Temperature Range Less than 3 months:

- 20° to 45°C
More than 3 months: 22° to 28°C Charging Temperature Range 0

– 40°C Max. Charging Power 180 W

Battery (Optional)

Name Intelligent Flight Battery41

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Model TB48 Capacity 5700 mAh Voltage 22.8 V
Battery Type LiPo 6S High Voltage Battery
Energy 129.96 Wh Net Weight 670 g Operating Temperature

- 10°C to 40°C Storage Temperature Range Less than 3 months:

- 20° to 45°C
More than 3 months: 22° to 28°C Charging Temperature Range 0

– 40°C Max. Charging Power 180 W

Vison Positioning System Velocity range Below 8 m/s (2 m above ground) Altitude range 5

– 500 cm Operating environment Brightly lit (Lux > 15) patterned surfaces Operating range 0

– 250 cm

DJI Pilot App Mobile Device System Requirements iOS 7.1 or later; Android version 4.1.2 or later

Supported Mobile Devices iPhone 6 Plus, iPhone 6, iPhone 5S, iPad Air2, iPad mini 3, iPad Air, iPad Mini2, iPad , Samsung Note 3, Samsung S5, Sony Z3 EXPERIA. Note: It is recommended that you use a tablet for the best experience.

Previous FAA approvals for commercial operation of the Inspire 1 aircraft: Exemption Nos. 11416, 11384, 1142642

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### DJI Innovations Spreading Wings S1000

Figure 4 Aircraft Specifications :

Frame Diagonal Wheelbase 1045 mm Frame Arm Length 386 mm

Frame Arm Weight (with motor, ESC, Propeller) 325 g

Center Frame Diameter 337 mm Center Frame Weight (With Landing Gear Mounting Base, Servos) 1520 g

Landing Gear Size 460 mm (Length) x 511 mm (width) x 305 mm (Height)

Motor

Stator Size 41 x 14 mm

KV 400 rpm/V

Max Power 500 W Weight(with cooling fans) 158 g

ESC Working Current 40A Working V oltage 6S LiPo Signal Frequency 30 Hz ≈ 450 Hz43

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com Drive PWM Frequency 8 KHz Weight 13 g

Foldable Propeller (1552/1552R)

Material High Strength Performance Engineered Plastics

Size 15 x 5.2 Inch Weight 13 g

Flight Parameters Takeoff Weight 6.0 Kg ≈ 11.0 Kg Total Weight 4.4 Kg
Power Battery LiPo (6S, 1000mAh ≈ 20000 mAh, 15C(Min)) Max. Power Consumption 4000 W Hovering Time 15 min (@15000mAh & 9.5 Kg Takeoff Weight) Working Environment Temperature - 10°C to 40°C

Previous FAA approvals for commercial operation of the Spreading Wings S1000 aircraft: Exemption Nos. 11442, 11439, 1141644

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Summary That Can Be Publish ed In t he Federal Register

Department of Transportation
Federal Aviation Administration

Avion : Avion Solutions Inc.

Avion Solutions Inc. seeks exemption from the requirements of 14 CFR Title 14

– Aeronautics and Space : Subpart h, § 45.23 (b), § 45.27, § 45.29, § 61.101 (e) (4) and (5), § 61.113 (a) and (b)§ 61.315 (a) and (c), § 91.7 (a)

, § 91.9 (b) (2) and (c), § 91.103

, § 91.109 , § 91.119, § 91.121 (a) (1)

, § 91.151 (a) (1)

, § 91.203

, § 91.405 (a)

, § 91.407 (a) (1)

, § 91.409 (a) (1) and (2) , § 91.417 (a) (1) and (2).

Descrip tion of relief sought;

Avion Solutions Inc. seeks an exemption for commercial operation of small unmanned aircraft pursuant to 14 CFR § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012. Approval of said exemption will permit safe oper ation of the DJI Innovations Phantom 2, Phantom 3, Inspire 1, and Spreading Wings S1000

. These aircraft will be operated

c ommercially for the purpose of conducting of UAS flight training, research and development,
and aerial data collection . By granting this petition, the FAA will provide Avion Solutions with a means to provide safe, effective and efficient aerial data collection to consumers.45

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Conclusion

As discussed in detail above, Avion Solutions Inc. will operate the proposed UAS safely in the NAS, without creating a hazard to other users of the NAS, the public, or otherwise pose a threat to national security. Avion Solutions will comply with all federal aviation regulations that are applicable to its UAS operations. Additional r egulatory requirements imposed by the FAA through the approval of this exemption will be adhered to. All other mandates, state and local will be observed to ensure maximum safety during any data collection or training events.46

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### Appendices

A. Avion Solutio ns Inc. Unmanned Aircraft Systems (UAS) Standard Operating Procedures

Avion Solutions Inc. Unmanned Aircraft Systems (UAS) Standard Operating
Procedures47

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### B. DJI Phantom 2 Documentation

DJI Phantom 2 User Manual

DJI Phantom 2 Quick Start Guide

Zenmuse H4

- 3D Gimbal Quick Start Guide DJI Smart Flight Battery Safety Guidelines

DJI Phantom 2 FPV Hub Kit Instructions v1.0

DJI Naza

- M(v2) Quick Start Guide v1.22

DJI 2.4G Bluetooth Datalink and iPad Ground Station U ser Guide v1.12 DJI New Pilot Experience 2015

Avion Solutions Phantom 2 Checklist48

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### C. DJI Phantom 3 Documentation

DJI Phantom 3 Professional User Manual v1.0

DJI Phantom 3 Safety Guidelines and Disclaimer

DJI Phantom 3 Professional Quick Start Guide

DJI Phantom 3 Intelligent Flight Battery Safety Guidelines

Avion Solutions Phantom 3 Checklist49

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### D. DJI Inspire 1 Documentation

DJI Inspire 1 User Manual v1.2

DJI Inspire 1 Quick Start Guide

DJI Intelligent Flight Battery Safety Guidelines

DJI Inspire 1 Safety Guidelines

DJI Inspire 1 Maintenance Manual v1.0

DJI Disclaimer & Warning

DJI 1345s Quick Release Propellers for the Inspire 1 Quick Start
Guide

Avion Solutions Inspire 1 Checklist50

4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com 

### E. DJI Spreading Wings S1000 Documentation

DJI Spreading Wings S1000+ User Manual v1.2

Avion Solutions S1000 Checklist4905 Research Drive NW Huntsville, AL 35805 (256) 721

- 7006