Name / Address of Petitioner:

Christopher DiBona

Brewster Ambulance Service

285 Hyde Park Avenue

Boston, MA 02130

Telephone Number of Petitioner: 617-983-1000

Email: Cdibona@brewsterambulance.com

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b)

14 C.F.R. § 91.109

14 CFR § 91.151 (a)

14 CFR § 409 (a) (2)

14 C.F.R. § 91.7 (a) 14 C.F.R. § 91.103 14 C.F. R. § 91.119 14 CFR § 91.203 (a) & (b)

14 CFR § 91.405 (a)

14 CFR § 417 (a) & (b) 3

14 CFR § 91.9 (b) (2)

14 CFR § 61.3 14 C.F.R. § 91.121

14 CFR § 91.205(b)

14 CFR § 407 (a) (1)

Appendix A describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption.This Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).

If the Administrator determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

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The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 4470244716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).

Petitioner Background:

The Petitioner has served proudly as a Flight Paramedic for Boston MedFlight for 10 years and has been involved in the Emergency medical field for the past 22 years. Boston MedFlight operates several EC145, Sikorsky S76 C++ helicopters and a Cessna Citation jet. As a Flight Medic, the Petitioner routinely functions as a clinician and as an aid to the PIC with radio communications, GPS navigation and see and avoid operations. After completing 2,500 missions of emergency rotor and fixed wing missions in the NAS, his respect for aviation safety and the need for careful, regulated sUAS integration into the NAS is unmatched.

Currently Mr DiBona is the Director of Clinical Performance at Brewster Ambulance Service involved in the medical and operational oversight of close to 700 clinicians within the Commonwealth of Massachusetts. Mr DiBona oversees clinical development, quality assurance, education and research associated with pre-hospital medicine. He has over twenty years of pre-hospital care and clinical experience and was part of the original Brewster Ambulance team. After moving to Denver, Colorado, to deepen hisexperience with a career in EMS, he returned to Massachusetts and worked for multiple non-transport, hospital-based advanced life support services along the south shore.

Mr DiBona also worked for ten years with Boston MedFlight as a flight paramedic and was previously the Tactical Medical Element Leader for the Metropolitan Law Enforcement Council, Quincy Police Marine Unit, and the FBI Boston SWAT Advanced Life Support Division. Chris is a graduate of Northeastern University and has extensive training in Advanced Trauma Life Support and Fundamentals of Critical Care Support for adult and pediatric patients. In addition the need for aerial imaging is imperative for rescue personnel in now the five 911 municipalities we serve in the commonwealth. Those cities and towns include Quincy, Braintree, Brockton, Middleboro and Plymouth

After a 22 year career in EMS / SAR / Aeromedical operations in New England, the Petitioner is in a unique position to not only safely utilize sUAS technology in the NAS, but to serve as a leader to other sUAS operators. If permission is granted, the Petitioner will serve numerous Local, State and Federal entities. The professional relationships he’s cultivated with the Massachusetts State Police, USCG and endless Fire and Police departments would serve as a conduit to safe sUAS implementation into the local airspace. His significant on scene emergency aeromedical experience with full scale helicopters will serve as the backbone for safe, efficient sUAS operations in numerous roles. Our deployment model in place would include but is not limited to EMS / Fire emergency support, Police operation support and missing persons support.

At no time will he operate outside the clearly outlined sUAS guidelines published by the FAA. For example, never >400’AGL, within five miles of an airport or beyond VLOS.

Petitioner also notes and has read the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits that can result from widespread deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act and the FARs to undertake the aforementioned activities for commercial purposes. If the Petition is granted, Petitioner will be at a significant competitive advantage if it, as it prefers, complies with FAA policy.

Vehicle(s):

The Petitioner will fly one or more DJI Inspire1

These vehicles have the built in capability to limit the height they fly above the ground, to limit the radius of the distance they fly from the operator, and to exclude them from class B, C, and D airspace as well any TFR’s (Temporary Flight Restricted) areas. The vehicles also have the built in capability to return to the launching point if the wirelesscontrol link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace limitations programmed into them. The vehicle weighs about five pounds and has a maximum gross weight of approximately twenty pounds. It has a top speed of about 30 knots. It has four fixed pitch rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer smart battery.

Flight profiles:

The petitioner will program the Inspire 1 so that they will not fly more than 400 feet above ground level, or more than line of site from its operator. The PIC (Person in Control) will carefully preflight the vehicle before each mission to assure that its compass and GPS system are properly calibrated and that the return-to-home feature, altitude, and radius limitations work.

They will not operate in controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL where the Petitioner is operating its Inspire 1 , the operator will keep both the vehicle and manned aircraft in sight and avoid the manned aircraft.

More particularly, the Petitioner will fly the Inspire 1 only over the hazard areas that are in control of an on scene Incident Commander, most likely being a Fire Chief, SAR rep or Police rep, etc.

The Petitioner will not conduct flight operations of any kind without a minimum of three dedicated personal. A PIC, SIC and observer will be present and functioning as a cohesive flight team for each mission.

Airframe

DJI Inspire 1

Product profile The inspire 1 is a quadracopter capable of capturing 4k video and transmitting a HD video signal to multiple devices. Equipped with retractable landing gear, an unobstructed 360 degree view from the camera is made possible by moving the landing gear out of sight. The built in camera has been integrated with a gimbal to minimize space and maximize weight efficiency. Optical flow enhances the hovering precision when GPS is not available.

Aircraft Model- T600Weight (Battery Included)- 2935 g Hovering Accuracy (Gps 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° to 40° C Diagonal Distance- 559 to 581 mm Dimensions- 438x451x301 mm

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- 4000x3000 Iso Range- 100~3200 Fov (Field Of View)- 94° Cmos- Sony EXMOR 1/2.3” Lens f/2.8 (20 mm equivalent) 9 Elements in 9 groups Aspherical lens element Anti-distortion filter UV filter Still Photography Modes Single shoot Burst shooting (BURST: 3/5/7 frames
, AEB: 3 or 5 bracketed frames at 0.7EV Bias) Time lapse Hd Video Recording Modes UHD (4K): 4096x2160p24/25
, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 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 SD/SDHC/SDXC Micro SD Max capacity: 64 GB. Speed: Class 10 or higher Operating Temperature Range 0° to 40° CRemote Controller Name- C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.728~5.850 GHz 2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed)- 2 km Eirp- 10dBm@900m
, 13dBm@5.8G
, 20dBm@2.4G Video Output Port USB, mini-HDMI Power Supply Built-in battery Charging DJI charger Dual User Capability- Host-and-Slave connection Mobile Device Holder- Tablet or Phone Max Mobile Device Width 170mm Output Power 9 W Operating Temperature Range -10° 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 TypeLiPo 6S High voltage battery Energy 99.9 Wh Net Weight 570 g Operating Temperature Range -10° to 40° C Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W

Battery (Optional) Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery Type LiPo 6S Energy 129.96 Wh Net Weight 670 g Operating Temperature Range -10° 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° to 40° C Max Charging Power 180 W

Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5-500 cmOperating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0-250 cm

UAV Crew

Personnel qualifications Pilot in Command (PIC)

The PIC shall be the individual with responsibility for all other personnel involved with the operation. For clarification, this section will include both the Pilot in Command and the Pilot at the Controls although they may both be interchangeable in most circumstances. The PIC shall have the minimum qualifications;

1. Knowledge of general aviation practices and FARs ( optional private rating) 2. National Incident Management System Certification 100, 300, & 700 level 3. 20/20 corrected vision 4. Familiarity and operations of DJI inspire 1 aircraft to include;

a. At least three events utilizing the inspire 1

b. At least three take offs and landings within 90 days with the inspire

c. Familiar with the latest revision of ground control software

d. Emergency recovery procedures in failed link situations

5. Familiar with the qualification requirements of all other personnel

6. Familiar with communications protocols in an NIMS/ICS environment

7. Familiar with mission planning and preflight procedures 7. Versed in emergency procedures and contingency operations

8. Familiar with acceptable field repair and maintenance procedures

Pilot at controls (PAC)

1. Knowledge of general aviation practices and FARs ( optional private rating)

2. 2. National Incident Management System Certification 100, 300, & 700 level3. 20/20 corrected vision

4. Familiarity and operations of inspire 1 aircraft to include;

a. At least three events utilizing the inspire 1

b. b. At least three take offs and landings within 90 days with type

c. Familiar with the latest revision of ground control software

d. Emergency recovery procedures in failed link situations

5. Familiar with mission planning and preflight procedures 6. Versed in emergency procedures and contingency operations 7. Familiar with acceptable field repair and maintenance procedures

Ground System Crew

1. National Incident Management System Certification 100, 300, & 700 level

2. 2. 20/20 corrected vision 4. Familiarity and operations of Spectra and Stryker aircraft to include;

a. Familiar with the construction and configuration of each UA

b. Familiar with GCU electronics and configuration

c. Familiar with field repair procedures for each UA

d. Familiar with the latest revision of ground control software

Observers

1. National Incident Management System Certification 100, 300, & 700 level

2. 20/20 corrected vision

3. Familiar with emergency recovery procedures in failed link situations

Mission Selection

RPSearch Services recognizes that each mission has its’ own unique circumstances that may affect the operation of the UA, safety factors, and personnel involved.Search and Rescue/Recovery

Search and Rescue operations range from small singly controlled units to multi agency units requiring coordination and close dissemination of information. The PIC will consider the following factors before authorizing any launch of either UA for the purpose of Search and Rescue;

1. Weather

When possible, the RPSS PIC shall contact the closest flight service station for

weather in the immediate area of operations. In lieu of that source, the local source of weather may be utilized through the internet, or may be observed on site. The PIC shall have final determination of risk due to weather and authority over launch of any RPSS aircraft

2. Hazards to the public

The RPSS PIC shall make every effort to ensure that flight operations will not pose any undue risk to the public not directly involved with the effort. The PIC shall have final determination of risk to the public and authority over launch of any RPSS aircraft

3. Hazards to property

The RPSS PIC shall make every effort to ensure that flight operations will not pose any undue risk to any property in the area involved with the effort. The PIC shall have final determination of risk to the property and authority over launch of any RPSS aircraft

4. Hazards to personnel

The RPSS PIC shall make every effort to ensure that flight operations will not pose any undue risk to the personnel directly involved with the effort. The PIC shall have final determination of risk to the public and authority over launch of any RPSS aircraft

5. Proximity to controlled airspace

The PIC shall ensure that all unreported operations take place at least three (3) miles from any controlled airspace. Operations inside any controlled airspace shall be performed with permission of, and in constant communication with, the controlling authority of the airspace. The PIC shall have final authority over launch after clearance has been granted by the controlling authority. The controlling authority maintains the right to abort any RPSS flight operation regardless of the stage that operation is in.

Law Enforcement Support

In addition to the above stated considerations for Search and Rescue, additional considerations for law enforcement support shall be:1. Covert operations affecting safety

The PIC shall have final authority of launches and flight operations involved in covert operations that could preclude any safety consideration to maintain the missions secrecy. No convert operations shall be conducted that subvert any stated safety consideration.

2. Evidence handling and security

RPSS personnel directly involved with evidence gathering shall not subvert any of the safety rules stated to perform flight operations.

Fire Support

RPSS fire support activities are confined generally to wildland fire control and post fire mop up. In the event that an Incident Command is established, the RPSS PIC shall report directly to the Incident Commander and defer resource authority to that position. Additional considerations for fire support include:

1. Safety of full size aircraft involved in support operations

Fire incidences typically involve the use of spotter aircraft and aircraft that deliver

fire retardants and water at altitudes operated in by RPSS aircraft. The PIC shall defer to any incoming aircraft reported by the Incident Command, Air Boss, or RPSS observers. All RPSS UA flight operations shall cease and aircraft will land until the full size aircraft are clear of the area.

2. Safety of RPSS personnel

At no time shall the PIC allow any RPSS personnel to place themselves or any RPSS resource in danger. The PIC shall defer to the Incident Commander in all situations when an ICS situation exists.

Disaster Recovery Support

Almost all Disaster Recovery Support operations shall be controlled by a NIMS Incident Command System. The RPSS PIC shall report to the Incident Commander with a list of all resources that can be made available for the situation. Regardless of authority, the RPSS PIC has final authority for all launches of RPSS UA.

Other agency missions

Other agencies could include NTSB, DOT, Dept. Agriculture, DEA, etc. and could pose additional safety considerations. The PIC shall have final authority over the execution or attempt of any flight operations by RPSS personnel and UA.Incident Command Interface

ICS accountability

If an Incident Command structure is implemented on any mission involving UAV personnel, the PIC shall report directly to the situation Incident Commander with a full disclosure of assets available. The PIC shall defer authority for flight clearance to the Incident Commander unless a safety situation that the Incident Commander may not be aware of arises. In that case, the PIC must halt flight operations and report immediately to the IC for further instructions. Regardless of authority, no UAV operators shall impinge, interfere, or hinder any full size aircraft entering into proximity of the operation.

ICS communications

All communications in a IC structure shall be the prescribed method of the incident which may two radio, cell phone, or face to face. Irregardless of method, communication between the PIC, ground crews, and incident command shall be conducted in plain English. All personnel should reduce the amount of codes and jargon to an absolute minimum to ensure clarity of information transmitted. UAV flight personnel shall not disclose any information to parties outside the responding agency concerning the mission or the payload unless it has been approved by the ICS Public Information Officer (PIO)

Permissions

In order of hierarchy, flight authorizations will come from the following:

1. Area Command – in a multi-agency oriented incident

2. Situation Incident Command – in a local incident

3. Pilot in Command – in an independent operation.Public interest Granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of sUAS into the National Airspace System advances the public interest. The Committee Report leading the House to adopt H.R. 658 said: "The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support more than 23,000 high paying jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a barrier to such job creation . . . ."1 Granting the Petition represents a step toward such integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in Emergency Response activities, one in which the responders themselves have a tool to safely, quickly and remotely assess a situation without placing lives in harm’s way. In comparison, the EOD robots have saved countless lives since their inception, a feat that will become common place for aerial assessments.

3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating new safety techniques and tactics with new aeronautical technology, thereby improving the efficiency of Emergency Responders around the world and making for a safer society. The rules from which Petitioner seeks exemption artificially and irrationally limit the effective use of new technologies to expand Emergency Response safety and improve the efficiency of markets, thereby subverting the public interest.

______________________________________ 1. H. R. Rep. 11229 on H.R. 658, 112th Cong., 1st Sess. at 116. The HouseSenate Conference Committee on the FAA Modernization and Reform Act of 2012 recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. Conference Report to Accompany H.R. 658, H.R. Rep. 112381, 112th Cong., 2d Sess., at p. 1 (Feb. 1, 2012).

4. Granting this Petition will enable the Petitioner to help demonstrate that the FAAs sUAS FARs are indeed a safe and effective means in which to govern the NAS. He will serve as an advocate for the practice of lawful sUAS operations.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging and developing civil aeronautics, including new aviation technology."2 Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the UnitedStates because of the rapid pace of innovation in aeronautical and associated technologies, followed by their commercialization and their introduction into the marketplace. The drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from using this in air commerce subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the availability of these technologies in the National Airspace System, thereby representing a congressional determination that the public interest is served by making these technologies more widely available at the earliest practicable date. The Petition represents a way for the

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FAA to move incrementally, while still satisfying its congressional mandate and meeting its obligation to enhance the public interest by making new technologies available by allowing the use of sUAS technologies in a manner that protects the public and the rest of the aviation community from significant risk.

The commercial activities by Petitioner proposed in the Petition represent contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act.

7. Granting the Petition will enhance aviation safety, thereby advancing the public interest. The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the National Airspace System and to persons and property on the ground. Many others are flying sUAS without regard to these hazards. Granting the Petition will offer the Petitioner up as an example of how the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS operations.

Users of the National Airspace System are confronted by mushrooming threats from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying the hazards to manned aircraft and to persons and property on the ground.

Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs.

Thank you very kindly for exemption consideration. Sincerely

Christopher DiBonaAPPENDIX AFAR SUBJECT Justification
14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft; not suitable for off the shelf sUAS
14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS operator 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable for off the shelf sUAS
14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual 14 CFR § 91.103(b) Requirement for crew members to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate controls

14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes 14 CFR § 91.121 Altimeter settings No one aboard to read altimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel
14 CFR § 91.203 (a) & (b) Requirement for registration and airworthiness certificates to be onboard No one aboard to read certificates

14 CFR § 91.205(b) Cockpit instruments No one to read
14 CFR § 91.417 Maintenance records not applicable FAR14 CFR § 91.409 Inspections designed for manned aircraft
14 CFR § 91.407 operation after maintenance designed for manned aircraft
14 CFR § 91.405 Maintenance required normal UAS maintenance will be followed SUBJECT Justification FAR