APRIL 15, 2015

US Department of Transportation Docket Management System

1200 New Jersey Avenue SE Washington, DC 20590

RE: 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

, Unmanned Vehicle Technologies, LLC (UVT) requests exemption from several provis ions of the Federal Aviation Regulations (FAR) in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. UVT seeks exemption in order to commercially operate small unmanned aerial vehicles (UAVs) / small unmanned aerial systems (UAS) weighing less than 55lbs for the purpo ses of:

 Aerial photography

 Aerial videography

 Inspection

A ll of UVT ’ s Pilots in Command (PICs) hold active sport pilot certifications or higher and all either carry a Third Class Medical Certificate or possess a valid driver ’ s license. All of UVT ’ s PICs and Visual Observers (VOs ) undergo rigorous training and continued education for the specific aircraft which they pilot/operate /observe. Following UVT policy, all PICs and VOs must maintain detailed flight logs, which are submi tted to UVT Senior Management monthly for review, approval and filing.

The name and address of the petitioner is :

Unm anned Vehicle Technologies, LLC
Attn: Christopher D. Fink / President
151 N Maitland Avenue
No. 948595 Maitland, FL 32751 (407) 218

- 6355 Unmanned Vehicle Technologies, LLC
151 N Maitland Avenue No. 948595 Maitland, FL 32751
407.218.6355 Info@uvt.email

www.uvt.usPage 2 Description of Flight Operations

To preserve the safety of manned aircraft operations, the NAS, and property, UVT will maintain the following limitations and conditions during all operations:

1. All UAVs operated by UVT under the requested Section 333 exemption will weigh less than 55 pounds.

a. In most cases, the UAVs will weigh less than four (4) pounds.
2. All UAVs operated by UVT under the requested Section 333 exemption will have on

- board GPS system s, preprogrammed with an altitude ceiling of 400 f ee t; additionally, a maximum lateral distance of 500 feet will be programmed into each aircr aft ’ s flight controller.
3. All flights will be conduct ed with in visual line of sigh t by the Pilot in Command and Visual Observer

. 4. All flights will be conducted with a limitation on the minimum voltage allowed in the primar y flight battery.

a. Preprogrammed voltage limitations are built

- in to each aircraft, allowing first for a visual warning to the PIC and VO, and seco nd for the autonomous descent and landing of the aircraft.
5. At all times during the flight, the active PIC and VO will be able to communicate verbally

. 6. All flights will be conducted in visual flight rules (VFR) conditions

. 7. All flights will be conducted in daylight; UVT has a strict “ No Night Flight ” policy for all aircraft.

UVT requests the following exemptions under Section 333:

Part 21 Subpart H Airworthiness certification
14 C.F.R. § 45.23 (b) Markings
14 C.F.R. § 61.113(a) a nd (b) Private pilot privileges
14 C.F.R. § 61.133( a) Commercial pilot privileges
14 C.F.R. § 91.7(a) and ( b) Civil aircraft airworthiness
14 C.F.R. § 91.119 Minimum safe altitudes
14 C.F.R. § 91.121 Altimeter settings
14 C.F.R. § 91.151 (a) Fuel requiremen ts for flight in VFR conditions
14 C.F.R. § 91.203 (a)( 1 ) and( 2 ) Civil aircraft certifications
14 C.F.R. § 91.405; 407; 409; 417 Maintenance ins pections

Part 21 Subpart H : Airworthiness certification

Part 21 Subpart H prescribes procedural requirements for the issue of airworthines s certificates. UVT requests exemption from this subpart to operate small UAVs (less than 55lbs) without the requirement for an airworthiness certificate. Based on the proposed small UAVs being limited in size, weight, speed, operating capabilities, and operating within visual line of sight,
UVT believes that an airworthiness certificate is not necessary to ensure an equivalent level of safety to manned aircraft operations.

14 C.F.R. § 45.23(b): Display of marks; general

As th e proposed small UAVs do not have any en trances to the cockpit or cabin, UVT requests that in order to identify the aircraft as an experimental type

, the word “EXPE RIMENTAL” will be displayed in two (2) inch lettering on the fuselage of each
aircraft.

14 C.F.R. § 61.113(a) and (b): Private pilot privileges and limitations: Pilot in command

UVT requests exemption from 14 C.F.R. § 61.113(a) and (b) to allow UVT to commercially operate small UAVs with operators holding private pilot certificates. Sections 6 1.113(a) and (b) limit private pilots to non

- commercial operations. However, provided in recent documentation, it has been deter mined that private pilot and commercial pilot certifications meet the same
basic kno wledge of airspace through ground school and not flight training (See Regulatory Docket No. FAA

- 2014

- 0352, pages
16

- 17). A commercial pilot ’ s certification ensure s th at a pilot is abl e to safely commercially operate a manned aircraft, not aPage 3 small UAV

. Applying manned commercial pilot certification requirements do es not significantly add to the safety of UAS operations. UVT ’ s operating procedures will ensure our Pilots in Command and VOs are trained to conduct operations with a n equiv alent level of safety to the training advantages obtained by a commercial pilot certification for manned aircraft.

14 C.F.R. § 91.7(a) and (b): Civil aircraft airworthiness

Th e regulation requires that no person may opera te a civil aircraft unless it is in airworthy condit ion. As there will be no
airworthiness certificate s issued fo r small UAVs , should this exemption be granted, no FAA regulatory standard will exist for
airworth iness. Given the small size of our aircraft (weighing less than 55 pounds) and t he aforementioned description of flight operations, an equivalent le vel of safety will be provided.

14 C.F.R. § 91.119: Minimum safe altitudes

UVT requests exemption from the minimum safe alt itude requirements of 14 C.F.R. § 91.119 that prescribes the minimum safe
altitudes under which aircraft may operate:

 Over any congest ed area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000
feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

 Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas . In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or

structure.

To provide the intended operation s, our small UAVs will be operated below 400 feet. Additionally, the small UAVs will maintain

a maximum lateral distance of 500 feet from inhabited structures, buildings and vehicles, and will remain within visual line of
si ght of the PIC and VO at all times.

14 C.F.R. § 91.121: Altimeter se ttings

This regulation requires that each person operating an aircraft shall maintain the cruising altitude or flight level of that
air craft, as the c ase may be, by reference to “ the current reported altimeter settings of a station along the route within 100
nautical miles of the aircraft

. ”

UVT requests exemption from this section because our small UAVs do not have barometric altimeters on

- board, but rather GPS

ba sed altitude readout s . All aircraft will be programmed to remain below 400 feet regardless of the input of the PIC, thus ensuring operation at safe altitudes.

14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions

UVT requests an exemption from 14 C.F.R. § 91.151(a) ’ s fuel requirements for flight in VFR conditions. Section 91.151 states:

 No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

–

o During the day, to fly after that for at least 25 minutes;

o At night, to fly after that for at least 45 minutes.

The batteries powering our small UAVs provide approximately 10

- 18 minutes of flight time. All fl ight operations will be limited to a minimum voltage to ensure appropriate reserve battery to maintain an equivalent level of safet y at all times. Should the PIC fail to land the aircraft prior to the minimum voltage warning, the aircraft will autonomously re turn to its home point and
land.

14 C.F.R. § 91.203(a)(1) and (2): Civil aircraft: Certifications required

U nder the requested exemption, UVT would not be operating aircraft with an airworthiness certificate as requested under the

exem ption for Part 21 Subpart H. T h e exemption for this section is required as UVT would not be able to display the
airworthiness certificate in accordance with 14 C .F.R. § 91.203 (a)( 1 ) and ( 2 ).Page 4 14 C.F.R. § 91.405; 91.407; 91.409; 91.417: Maintenance/Operations/Inspections/Records

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. 14 C.F.R. 91.405(a) (stating that each owner or operator of an aircraft “ shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections

... have discrepancies repaired as prescribed in part 43 of this chapter ” ).

UVT requests exemption from these sections as these sections require the aircraft be inspected in accordance with Part 43 and is needed as these sections apply only to ai rcraft with an airworthiness certificate. An equivalent level of safety will be achieved by the PIC followi ng standard maintenan ce procedures, per the aircraft manufactur er ’ s User Manual and all maintenance and repairs are logged for each aircraft, with those logs being submitted to UVT Senior Management following each maintenance and repair

. Additionally, the PIC will ensure the aircraft is in working order prior to each flight

. Why is this exemption request in the public ’ s best interest?

By granting this exemption request, UVT wil l be able to safely commercially operate our small UAVs in the NAS allowing for
aeria l photography

, aerial videography and perhaps most importantly, inspection

. The safe and responsible u tilization of this technology allows us to minimize the risk placed on the human life, not only poten tially saving a life, but freeing up valuable
human resources to be used to further innovate and create.

UVT feels these exemptions play an integra l part of the early adoption of small UAS in to the NAS. It is review processes like these that allow those of us operating resp onsibly and saf ely to use this technology to protect our people, protect our property and help improve countless industries and lives , worldwide.