1



# U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
DOCKET MANAGEMENT SYSTEM West Building Ground Floor, Room w 12140 1200 New Jersey Ave., SE Washington, DC 20590

In the matter of Petition for exception of : AERO DRONE RESOURCES LLC.

con cerning commercial operation s of unmanned

aircraft systems2



## Table of Contents

SUMMARY FOR SEEKING EXEMPTION

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

COMPANY BACKGROUND

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

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS

................................ ............................... 5

GROUND CONTROL STATION

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

BASIS FOR PETITION FOR EXEMPTION

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

NAME AND ADDRESS OF PETITIONER

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

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERO DRONE RES OURCES LLC, SEEKS
EXEMPTIONS AND THE E XTENT OF RELIEF

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

REASONS WHY THE EXEM PTION WOULD NOT ADVE RSELY AFFECT PUBLIC SAFETY AND
HOW THE EXEMPTION WO ULD PROVIDE A LEVEL OF SAFETY AT LEAST E QUAL TO THE
EXISTING RULE

................................ ................................ ................................ .................. 18

THE EXEMPTION IS IN THE PUBLIC INTEREST

................................ ................................ ... 20

A SUMMARY TO BE PUBL ISHED IN THE FEDERAL REGISTRAR

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

SUPPORT FOR THE REQU EST FOR AN EXEMPTION

............... E RROR ! B OOKMARK NOT DEFINED

.
NO PRIVACY ISSUES ARISE AT THE GRANT OF THE EXEMPTION

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

CONCLUSION

................................ ................................ ................................ ..................... 22

GLOSSARY /ABBREVIATIONS

................................ ................................ ............................. 223



## SUMMARY FOR SEEKING EXEMPTION

AERO DRONE RESOURCES LLC , seeks an exemption pursuant t o Section 333 of the Reform Act, to use a number of different UAS platforms for training and aerial data
collection from the requirements of Title 14 of the Code of Federal Regulations in particular an exemption from the following sections:

Part 21

14 C. F.R. §45.23(b)
14 C.F.R. §45.27(a)
14 C.F.R. §61.113 (a) and (b)
14 C.F.R. §91.7(a)
14 C.F.R. §91.9(b) (2)

14 C.F.R. §91.103

14 C.F.R. §91.105
14 C.F.R. §91.109(a)
14 C.F.R. §91.119(b)

14 C.F.R. §91.121
14 C.F.R. §91.151(a) (1)
14 C.F.R. §91.203( a) and (b)
14 C.F.R. §91.405(a)
14 C.F.R. §91.407(a) (1)
14 C.F.R. §91.409(a) (2 )
14 C.F.R. §91.417(a) and (b)

AERO DRONE RESOURCES LLC.
, seeks to commercially fly an Unmanned Aircraft System (UAS) within the United States

. The propose d UAS are less t han 55 lbs. max gross and
will be flown below 400 feet above gro und level (“AGL ”) outside the 5 miles radius of an

FAA airport unless a letter of agreement with that airport’s management is obtained
and NOTAM filed

. The exemption will have a positive impa ct on the public interest by providing services that are not available to the general public but are in high in demand
in both private and municipal sectors

. The exemption in particular will allow AERO
DRONE RESOURCES LLC , to offer wide spectrum of servic es using the UAS including and4

not limited to community training workshops on the proper use and operation of UASs

to :

1. E nsure safe operation by hobbyists and commercial users

2. Provide economically beneficial options for building /site inspections.

3. Provide first responders an alternative by using the UAS to investigate danger
situations which otherwise would risk human lives and/or property.

4. Land survey and data gath ering for agricultural planning and Forest Inventory

. The Petitioner is dedicated to followin g the conditions and limitations as imposed by the FAA regarding the flight of the UAS and including but not limited to avoid ing and yield ing right

- of

- way to all manned operations, file necessary notices an d flight plans as well as adhering to city and sta te imposed regulations to ensure the utmost safety for the general public and the operators.



## COMPANY BACKGROUND

AERO DRONE RESOURCES LLC
, is a n Oregon Corporation wit h a primary place of Business in Albany OR

. It is f ounded by t wo entrepreneurs with av iation background and a strong interest and desire to bring innovative services and safety to the public using the UAS vehicle as a more practical, econo mical and useful alternative

. Both founders have a strong background in aviation

. One is Private Pilot

, Aircraft owner
and FBO owner an d the other is an ATP/CFI/Gold S eal flight instructor with over two
thou sand hours of instruction given in a Tittle14 CFR part141 environment and over twenty years of RC unmanned aircraft building and flying.
The company wi ll be engaged in performing Research, Development , Data gathering and Training for a unique platform of services to be utilized commercially by a variety of professionals.

AERO DRONE RESOURCES LLC.
, is dedicated to offering innovative and customized
servic es to consumers using the UAS to better serve the community and the public interest by providing a safer alternative to current practices of buildi ng inspection and
other aviation services as well as by providing trainin g workshops for other UAS
operators and commercial entities to ensure safer operations in the National Airspace System (“NAS”).5



## UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS

AERO DRONE RESOURCES LLC intends to use the following vehicles that meet the requirements of Section 333 of the Reform Act due to their weight, speed and operational capabilities:

 SenseFly EBee

 DJI Inspire 1

 DJI Phantom 3

 3DR Solo

 Draganflyer X4

- ES

 Latitude HQ

- 40A

 Mikrokopter Rotorcraft

 Delta Drone Delta Y

 MicroDrone md4

- 200

The FAA is familiar with and has a lready determined that the commercial off

- the

- shelf vehicles selected meet the requirements of Section 333 of the Reform Act due to their weight, speed and operational capabilities:

 SenseFly eBee: Exemption No. 11673 to Aerial Scout Ag Ops Support, LLC; Exemption No. 11646 to BioSensing Systems, LLC; Exemption No. 11263 to SenseFly LTD.

 DJI Inspire 1 : Exemption No. 11254 to Upward Aerial; Exemption No. 11659 to

Fovea Aero Systems ; Exemption No. 116 68 to Sky

- Forge Robotics LLC.

 DJI Phantom 3 : Exemption No. 12734: Docket FAA

- 2015

- 1964

 Draganflyer X4

- ES : Exemption No. 11557 to HAZON Solutions LLC; Exemption No. 11424 to AgScan, Inc.; Exemption No. 11281 to Draganfly Innovations, Inc.

 3DR Solo : Exemp tion No. 11935: Docket FAA

- 2015

- 1356

 Draganflyer X4

- ES : Exemption No. 12040: Docket FAA

- 2015

- 1248

 Latitude HQ

- 40A : Exemption No. 12205A: Docket FAA

- 2015

- 1873

 Mikrokopter Rotorcraft : Exemption No. 11891: Docket FAA

- 2015

- 07786

 Delta Drone Delta Y MicroDro ne md4

- 200: Exemption No. 12791: Docket FAA

2015

- 2070

 Trimble UX5 and Trimble UX5hp : Exemption No. 14445 Docket FAA

- 2015

- 5189



## GROUND CONTROL STATION

The ground control (“GCS”) station is the primary takeoff and landing point of the UAS
and includes a s etup, consisting of people and equipment, to promote th e utmost safety for all persons involved in the operation including the operators, general public, and any objects or persons that may come into contact with the zone of operation (“Zone”).

Specificall y the ground station includes:

a. Pilot in Command: A designated pilot with a minimum of a sport pilot’s license ground training or equivalent and current FAA airman medical certificate or a
valid U.S. driver’s licens e and a deep knowledge with thorough unde rstanding of the UAS and its operation al capabilities as well as numerous hours of experience in operating the aircraft

. PIC will operate the UAS within visual line of sight (VLOS) at all times using human vision unaided by any device other than
correctiv e lenses.

b. Flight Coordinator / Visual Observer (FC or VO ): A second person, other than the PIC, with in visual range of the UAS at all times with the ability and knowledgeable to assist the PIC as needed including verbal as well as p hysical
command of the c ontrols will be required when operating with in 5 miles of the center of the Albany Airport. The FC will have access to a VH F 2 way radio and
will monitor the Unicom frequency for airport traffic. The UAS will always be
within the VLOS of the FC. The PIC a nd the FC will have the ability to communicate verbally at all times.

c. Equipment:

a. A 100mW, 2.4GHz radio transmitter/controller operated by the PIC.

b. A portable receiver receiving transmitted live video and flight data from the UAS onboard camera and comput er. This data is projected onto the controller used by the PIC to assist during flight.

c. A functional handheld 2 Way VHF radio only when operating with 5 miles of the center of the Albany Airport.

d. Fire Extinguisher

d. Zone : a designat ed area cordoned off by orange colored cones and/or ribbons to put the surrounding public on notice of the operation. One sandwich board with7 the name of the company, contact information, and description of the operation in order to alert the general public of t he event taking place and allowing anyone
interested to contact AERO DRONE RESOURCES LLC
,

e. Paperwork : The ground station will also include a designated area for the Operator’s Manual (Appendix A ) as amended with conditions or limitations scripted by the FA A, copy of the granted exemption, pursuant to the grant of this exemption by the FAA, copy of the insurance certificate, business cards and any other relevant paper work for the specific event. (Copy of Plan of Activities and COA) Mission Checklist (Appen dix B)

f. Other : Anything else that is required in order to be in full compliance with the regulations of the City and State where the event is taking place.



## BASIS FOR PETITION FOR EXEMPTION

Pursuant to the authority granted to the FAA under Federal Aviatio n Regulations, 14 C.F.R. § 11.61(b) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, XKYVIEW Inc. respectfully requests to grant its petition for an exemption from the requirements of 14 C. F.R Part 21; 14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2); 14 C.F.R. §91.103; 14 C.F.R. §91.109; 14 C.F.R. §91.119; 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. §91.203(a) and (b); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a )(1); 14 C.F.R. §91.409(a)(2); and 14 C.F.R. §91.417(a) and (b).



## NAME AND ADDRESS OF PETITIONER

AERO DRONE RESOURCES LLC.
Attn: Jose Gutierrez/Tony Hann 525 Aviation Way Albany, OR. 97322



## SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERO
DRONE RESOURCES LLC , SEEKS EXEMPTIONS A ND THE
EXTENT OF RELIEF

1. AERO DRONE RESOURCES LLC seeks an exemption from 14. C.F.R. Part 21

14 C.F.R. Part 21

- Airworthiness Certificate8

14 C.F.R. Part 21 along with 14 C.F.R. §91.203(a) (1) establishes the necessary procedures in ord er to obtain an airworthiness certificate for a manned aircraft. The general purpose of an airworthiness certificate for an aircraft is to ensure the aircraft’s safe functionality, good working order and to ensure the safety of those
onboard as well as an yone in proximity to the aircraft at any time. The Federal Aviation Act, 49 U.S.C. §44701(f) and Section 333 of the Reform Act statutorily authorize the FAA to issue an exemption from the airworthiness requirements upon
consideration of the aircraft’s siz e, weight, speed and operational capability. Such considerations should be applied to Petitioner’s UAS in determining that AERO
DRONE RESOURCES LLC.
, should be exempt from the airworthiness requirement for
its UAS.
The UAS to be operated by AERO DRONE RE SOURCES LLC are less than 55 lbs. max
gross (inclusive of additional equipment such as GPS tracker, camera, etc.) and does not carry a pilot or passengers. Furthermore, the UAS does not contain explosives, fuel or any other flammable materials. The opera tion of the UAS will be strictly confined to a designated area and under full control of the PIC and FC.
Safety Standard: The UAS s are equipped with several safety features, which will further serve as a reason to exempt it from an airworthiness certifica te. The UAS is equipped with a “Fail

- Safe Feature which allows it to self

- correct a failure that is beyond control of the PIC. Once a “Failure” is detected the UAS’s automatic safety feature is triggered which prompts it to retu rn to its GPS point of ori gin

.
AERO DRONE RESOURCES LLC. would like to refer to Exemptions No.11062 and 11067 in which the FAA previously determined that based on the [Petitioner’s] UAS “limited size, weight, operating conditions, design safety features and the imposed
conditions and limitations the [Petitioner] has demonstrated that the operations would not adversely affect safety compared to similar operations conducted with aircraft that have been issued an airworthiness certificate under 14 C.F.R. Part 21, Subpart H”.

In the a lternative Petitioner respectfully requests that the Administrator finds that the exemption from 14 C.F.R. Part 21 is not necessary because the regulation is not applicable to the UAS to be used by the Petitioner.

2. AERO DRONE RESOURCES LLC seeks an exemptio n from 14 C.F.R. §45. 23(b)
14 C. F. R. §45.23(b)

- Display of Marks; General
(b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisi onally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in9 letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “expe rimental,” or “provisional,” as applicable.

Provided that the exemption from Part 21 is granted and the UAS will not need an airworthiness certificate, Petitioner seeks an exemption from the requirem ent that the word “limited,” “restricted,” “light

- sport, ” “experimental,” or “provisional,” as be displayed on the UAV near each entrance to the cabin, cockpit or pilot station
since UAVs do not have a cabin, cockpit, pilot station or any other type of entrance. Also, except in some fixed wing UAVs, the size d oes not permit any markings to be above one inch (1”) in height and be longer than eight inches (8”).

Safety Standard: In order to achieve an equivalent level of safety and to most closely comply with the FAA regulations, AERO DRONE RESOURCES LLC propose s to display a Registration Number on top of the UAS with the dimensions of the signage in compliance with 14 F.C.R. §45.29 (f)). This type of signage will allow the PIC, FC and others in close proximity to see the designation of the UAS and will comply w ith
the new registration requirements.
AERO DRONE RESOURCES LLC will display markings as large as practicable on the top of the UAS in the interest of safety and compliance. See also Exemptions Nos. 10700, 8738, 10167, and 10167A.

3. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §61.113(a) and (b)

14 C.F.R. §61.113

- Private pilot privileges and limitations: Pilot in command
(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an
aircraft.
(b) A private pilot may, for compensation or hire, act as pilot in comm and of an aircraft in connection with any business or employment if:

1. The flight is only incidental to that business or employment; and

2. The aircraft does not carry passengers or property for compensation
or hire.

AERO DRONE RESOURCES LLC.
, seeks an exemp tion from the restriction outlined in parts (a) and (b) of the regulation prohibiting a holder of a private pilot’s certificate to act as a pilot for an aircraft carrying property for compensation or hire. The UAS to be used by

, will be used for commerci al operation for compensation or for hire, however, will not be carrying any passengers or cargo allowing AERO DRONE10

RESOURCES LLC
, to achieve the same level of safety of current operations by requiring the PIC to obtain a private pilot’s license instead o f a commercial pilot
license.
Safety Standard: Pursuant to obtaining a grant of the exemption to operate the UAS for compensation, AERO DRONE RESOURCES LLC
, will ensure that the PIC has a significant number of flying hours and follows the instructions as set forth in the
Manual for the UAS. Since there are no persons on board and the UAS will be operated within the safety procedures outlined by the FAA regulations, the operation of the UAS by remote control by the PIC will exceed the present level of
saf ety meant to be achieved by the requirements of 14 C.F.R. §61.113 (a) and (b).

As the FAA Administrator previously outlined in Exemption Nos. 11062 and 11067 “[a] another consideration supporting the certificate requirement is that pilots holding a private pilot certificate are subject to security screening by the Department of Homeland Security” and this type of screening should overrule “security concerns over the UAS operations” that would be granted under this exemption. Granting the exemption based on the safety outlines and requirements outlined by the FAA and the experience and expertise of the PIC, would not adversely affect the safety of the NAS.

4. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.7(a)
14 C.F.R. §91.7(a)

- Civil aircraf t airworthiness
(a) No person may operate a civil aircraft unless i t is in an airworthy condition.

AERO DRONE RESOURCES LLC
, requests an exemption from the regulation, pursuant

to petitioner obtaining of an exemption to 14 C.F.R. Part 21, there will be no
air worthiness certificate issued for the UAS and consequently a standard for airworthiness is not applicable.
Safety Standard: AERO DRONE RESOURCES LLC , compliance with an established pre

flight safety checklist, standard of operation as described in the Man ual and outlined in the maintenance requirements prior to each flight ensures that an equivalent level of safety will be provided during all times of operation. The PIC will be in compliance with the requirements of 14 C.F.R. §91.7(b) when determining whe ther the aircraft is in a condition for safe flight.
As the FAA determined in Exemption Nos. 11062 and 11067 that a requirement of
airworthiness does not need to be met if a certificate of airworthiness is not required, the FAA should determine similarly in favor of AERO DRONE RESOURCES
LLC
, that if they are granted the exemption from a certificate of airworthiness, the provision of 14 C.F.R. §91.7(a) and (b) is not necessary.11

5. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.9(b ) ( 2)

14 C.F.R. §91.9(b) (2)

- Civil Aircraft Manual Requirements

No person may operate a U.S.

- registered civil aircraft

— (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a curre nt approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

AERO DRONE RESOURCES LLC . seeks an exemption from maintaining a flight manual
aboard the UAS.
Safety Standard : Given the size a nd design of the UAS it is not possible to carry the manual onboard during operation. To ensure full compliance with safety requirements the Aircraft operation manual will be available at the ground station and immediately accessible by the PIC and FC at all times during operation.
Petitioner would like to refer to Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700 and 11067 where the Administrator issued a similar exemption as requested here. In the alternative, Petitioner requests that the Administrator finds that the exemption is not necessary based on the FAA Memorandum subject “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station” dated August 8, 20 14.

6. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.103

14 .F.R. §91.103

- Preflight Action
Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in
command h as been advised by ATC;
(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:
(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing di stance data is required, the takeoff and landing distance data contained therein; and12

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performan ce under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

AERO DRONE RESOURCES LLC
, seeks an exemption from the Preflight Action requirements as prescribed in 14 C.F.R. §91.103 which requires the PIC to take certain actions before flights to ensure safety.

AERO DRONE RESOURCES LLC , Safety Standard

s : The PIC will be familiar with all of the manual requirements and recommendations as well as perform an “ Ops
Checklist “ (Appendix B) a customized pre

- fligh t check list of actions to be performed prior to operation of the UAS. Combined, the PIC will take actions such as inspection of the UAS, the weather elements, and physical inspection of the area of operation and aircraft performance data prior to the ini tiation of every single flight. A copy of
the Operator’s Manual and Operational limitations (Appendix A) will be kept at the ground station within reach of the PIC at all times

. The pre

- flight procedures will allow an equivalent if not higher level of saf ety to be reached. The PIC will also take into account visibility and distance from clouds interpolating ASOS/ATIS from the nearest airports, local observations to estimate the ability to see other traffic when conducting the pre

- flight inspections.

In t he alternative Petitioner requests the Administrator to find that the exemption is not necessary, as the FAA administrator found in Exemption Nos. 11062 and 11067, that with conditions and limitations the exemption is not necessary

.
7. AERO DRONE RESOURCES LL C, seeks an exemption from 14 C.F.R. §91.105

14 C .F.R. §91.105 Flight crewmembers at stations.
(a) During takeoff and landing, and while en route, each required flight crewmember
shall

— (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and

... Petitioner requests an exemption from the regulation because the UAS and other remotely piloted aircraft, by design, do n ot have “stations” wi th shoulder harness. Flight control of the UAS is accomplished by the PIC at the GCS ( Ground Control
Station ) using a control box which communicates with the aircraft via radio signal
communication

. Safety Standard: AERO DRONE RESOURCES LLC, will achieve the level of safety this rule intends to accomplish by having a PIC and VO at the present at control station whenever an operation is in progress. The mission checklist addresses this point in Appendix B13

8. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.109(a)
14 C.F.R. §91.109(a)

- Flight Instruction
(a) 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...

Petitioner requests a n exemption from the regulation because the UAS and other remotely piloted aircraft, by design, do not have functional dual controls. Flight control of the UAS is accomplished by the PIC’s use of a control box which
communicates with the aircraft via radi o signal communication.
Safety Standard: Since the UAS is not carrying a pilot or passengers the equivalent level of safety will be achieved with the remote control of the UAS and without dual
controls. The PIC is in full control of the UAS at all times. B ecause the flight will be performed in a cordoned off area, any trouble that the UAS might experience will be rectified in a safe manner by the PIC and the FC without any interference or danger to the public.
Petitioner would like to refer Exemption Nos. 11062 and 11067 where the Administrator found that UAS may be operated without dual controls. See also
5778K and 9862A.
In the alternative the Petitioner would like to request the Administrator to determine that the 14 C.F.R. §91.109(a) regulation is not applicable to XKYVIEW Inc,
since AERO DRONE RESOURCES LLC
, does not plan to use the UAS in an environment where dual controls are necessary such as instrument flight instruction and the PIC will be the only controller in operation of the UAS at all times.

9. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.119(b)
14 C.F.R. §91.119(b)

- Minimum Safe Altitudes: General
Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:
(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the
aircraft.

AERO DRONE RESOURCES LLC seeks an exem ption from the requirement of a subsection (b) and relies on subsection (d) for an exemption. Subsection (d) permits the operation of a helicopter at less than the prescribed minimums, given that the14

operator is in compliance with any route or altitudes pr escribed for helicopters by
the FAA.

AERO DRONE RESOURCES LLC , r equests an exemption to operate the UAS at below
400 feet AGL . Except for the limited conditions stated in the Manual ( Appendix A ) the UAS will not operate above 400 feet AGL. The equivale nt level of safety will be achieved provided the size, weight and speed of the UAS.
Safety Standard: AERO DRONE RESOURCES LLC. operation will provide at least an

e quivalent or better level of safety at or below 400 feet AGL to those in relation to
the mini mum safe altitudes as outlined in regulation 91.119. Most civil airplanes operate at 500 feet AGL or above therefore the operation of the UAS by petitioner
will not be in direct interference with manned aircraft in the NAS.

 The ground control station ar ea of operation of the UAS will be in a cordoned
off area with securit y perimeters set up by the PIC.

 All property owners and abutters who may be affected will receive advanced notice of the operation and the propose d flight operations as set fo rth in the
Manual.

 AERO DRONE RESOURCES LLC will ensure a “safe cone zone” around the area of PIC operation as large as is allowable in an urban setting.

 At all times anyone interested in the operation criteria of the UAS can
contact Petitioner to obtain the necessar y information.
The UAS is equipped with an automatic system that detects “trouble” such as low battery or connection loss and automatically triggers the UAS to land safely back at its point of lift off based on the GPS coordinates of the take off.

Compar ed to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed to be used by AERO DRONE RESOURCES LLC
, and lack of flammable fuel and a pilot or passengers on board any risk associated with these operations is far less as compa red manned aircraft operated in accord with the minimum altitude requirements as outline in the regulation.

10. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.121(a)

14 C.F.R. §91.121

- Altimeter Settings
(a) Each person operating an aircraft shal l maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— ...15

AERO DRONE RESOURCES LLC, requests an exemption from the Altimeter Settings requirement because the UAS does not have a barometric altimeter, but is instead equipped with a GPS altitude reading device.
Safety Standard: With an exemption from the regulation, an equivalent level of safety will be achieved by the operator, pursuant to the Manual and pre

- flight chec k lists and by confirming the altitude of the launch site as shown on the GPS altitude indicator before flight. To ensure that the exemption from the regulation does not adversely affect safety the petitioner proposes to operate the UAS at or below 400
fe et AGL , provide altitude information to the PIC via a digitally encoded telemetric data feed, which downlinks from the ground

- base on

- screen display. Prior to each flight, a zero altitude initiation point will be established a nd confirmed for accuracy
b y the UAS PIC and the altitude information will be generated by equipment installed onboard the aircraft, as specified using GPS triangulation.
Petitioner would like to refer to Exemption Nos. 11062 and 11067 where the Administrator found that UAS is permit ted to be operated with a digitally encoded
telemetric data feed instead of an onboard barometric altimeter. See also Exemption Nos. 5778K and 9862A.

11. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.151(a ) ( 1)
14 C.F.R. §91.151 (a)

- Fuel requirements for flight in VFR conditions
(a) 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 cr uising speed

—
AERO DRONE RESOURCES LLC, seeks an exemption from the fuel requirement

. Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restricti on would be mo re than adequate to return the UAV to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through 11067, 11080 and 11110.

11. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.203(a) and (b)
14 C.F.R. §91.203(a) and (b)

- Civil Aircraft: Certifications Required
(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following:16 (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications
iss ued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must hav e on it the 15 registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to
the aircra ft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district
office.
(2) An effective U.S. registration certifica te issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign country.
(b) No person may operate a c ivil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

AERO DRONE RESOU RCES LLC
, requests an exemption from sections (a) and (b) of the regulation because the Administrator grants the earlier requested exemption from Chapter 14 Part 21 the UAS will not be required to obtain an airworthiness
certificate. Additionally the UAS is less than 55 lbs. when max gross and does not contain an onboard pilot therefore there is no ability or place to carry the certification and registration documents as prescribed.
Safety Standard: AERO DRONE RESOURCES LLC, proposes to achieve the equival ent level of safety that is premised by the regulation by keeping the necessary and required documents at the ground control station within immediate reach by the PIC
at all times and will be made available to the Administrator and law enforcement
immediat ely upon request.
For similar exemptions to this regulation granted by the FAA see Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11062 and 11067.
In the alternative, Petitioner requests that the Administrator finds that the exemption is not necessary based on the FAA Memorandum subject “Interpretation17

regarding whether certain required documents may be kept at an unmanned aircraft’s control station” dated August 8, 2014.

12. AERO DRONE RESOURCES LLC , seeks an exemption from 14 C.F.R. §91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 2) and 91.417(a) and (b)
14 C.F.R. §91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b)

- Maintenance Exceptions

AERO DRONE RESOURCES LLC
, seeks an exemption from the above outlined regulations gover ning the maintenance requirements, because these section along with Part 43 apply only to aircraft with an airworthiness certificate, which if the petition is granted by the Administrator, will not apply to the Petitioner
Safety Standard: With the grant o f the exemption, an equivalent or higher level of safety will be achieved during the operation of the UAS. The Petitioner will inspect the UAS regularly and address all mechanical issues immediately. The PIC will
ensure that the UAS is in proper working order prior to every flight, perform required maintenance and keep a record log of any maintenance issues and their respective resolutions. In the instance that the UAS is dormant for a prolonged period of time, the operator will inspect the UAS bi

- weekly to ensure its working
order. All maintenance and inspections will be performed in accordance with the
Aircraft Operator’s Manual and flights will not be conducted until the Mission Checklist (Appendix B) list is performed prior to each flight

.18



## REASONS WHY THE EXEMPTION WO ULD NOT ADVERSELY
AFFECT PUBLIC SAFETY AND HOW THE EXEMPTIO N WOULD PROVIDE A LEVE L OF SAFETY AT LEAST EQUAL TO
THE EXISTING RULE

Taking into consideration the safety standards outlined above granting AERO DRONE
RESOURCES LLC
, an exempt ion to permit commercial operation of the UAS will not adversely affect public safety and would provide a level of safety at least equal to the existing rule and in several cases provide a higher level of safety. The UAS is a battery operated unmanned air craft with no flammable fuel, pilot or passengers on board and operated by an operator with at least a private pilot’s license. The UAS will in several instances replace a manned aircraft hired to perform the same task or serve as an alternative to using persons climbing to high elevations and eliminating the risk of incident of injury or fall.
The UAS will be operated by an experienced PIC who will be in full control of the UAS at all times with a FC who will provide another visual and keep the UAS in a VLOS at all
times. . PIC will have access to all necessary up to date equipment, machinery and mechanicals necessary for the proper and airworthy operation of the UAS. Furthermore, AERO DRONE RESOURCES LLC will carry liability insurance for the operation of the UAS in excess of $ 1 Million a nd provide the insurance certificates upon
request. AERO DRONE RESOURCES LLC proposes to operate the UAS with the utmost diligence, care and responsibility as outlined in the exemptions, regulations and
additional rest rictions and guidelines as proposed by the FAA.
With following the safety provisions as outlined in the Manual and being in strict compliance with FAA regulations, restrictions and conditions the operation of the UAS will not adversely affect public safet y and the exemption will provide a level of safety at a level greater than the existing rule by providing alternative ways to inspect areas of high elevation instead of using physical man power to do so, thus preventing injuries
and other hazards.19



## OPERAT IONS AT ALBANY AIRPORT

AERO DRONE RESOURCES LLC main place of business is located at the Albany Airport in Oregon. During training operations conducted under the supervision of an FAA certified Instructor (CFI) AERO DRO NE RESOURCES LLC proposes to operate the UA under the following conditions;

1. W ith a letter of agreement w ith that airport’s management

2. I n conjunction with a NOTAM and

3. W i th a Visual traffic spotter with a two way radio tuned to the airport Unicom frequency

. The letter of agreement with the airport management must be made available to the Administrator upon request

.20



## THE EXEMPTION IS IN THE PUBLIC INTEREST

Granting AERO DRONE RESOURCES LLC, request for a petition for the exemption from the regulations out lined above will further the public interest by allowing AERO DRONE
RESOURCES LLC
, to provide commercial services and thus expanding the stream of

commerce.
Providing such services to the public holds many benefits because these optio ns are much more eco nomical, safer than current available options, and create safe options for first responders to use in emergency situations.

AERO DRONE RESOURCES LLC
, proposes to use the UAS system to perform citywide, mandatory building and structure inspections providin g a more economical and safe alternative than the current inspection method in place. These inspections are applicable to buildings as well as all apartment building parts. Currently the inspections are performed by a visual evaluation through a telescop e on the ground or a physical escalation of the building itself. AERO DRONE RESOURCES LLC, will provide a service to inspect the buildings using the UAS operated by a licensed PIC adhering to all applicable FAA regulations as outlined by the Administrator as well as the recommendations set
forth in the Manual. Use of the UAS will ensure a higher level of safety for the public and provide more accurate reporting including areas of the building such as overhangs and awnings which are not easily accessible. AERO DRONE RESOURCES LLC, will also provide services to Insurance Companies needing surveys.
These exemptions will also further the public interest by providing the option of having

access to ae rial photography and video in disasters areas at first respond er’s request

. The use of the UAS will provide government and private reporting agencies, real estate and development firms as well as architects the option to use a UAS to obtain aeri al views, replacing the use of the more costly manned aircraft. Use of the UAS is both more economical and safer and decreases congestion of the NAS. The use of the UAS versus a manned aircraft will also create a reduction in noise and air pollution, an increase in safety and a better economic alternative for the public.

Fi nally, the public will benefit from the use of the UAS by AERO DRONE RESOURCES LLC,
because AERO DRONE RESOURCES LLC with thousands of hours of manned aviation experience will advocate safety throughout the community.
The enhanced safety achieved by using a UAS w ith a trained PIC and the added safety gear to be used strictly in compliance with the uses outlined above while carrying no passengers or crew is in the public interest to replace the use of a manned aircraft of21

significantly greater proportions , carrying crew and flammable fuel. This use provides an alternative use with more accuracy and a higher level of safety



## A SUMMARY TO BE PUBL ISHED IN THE FEDERAL
REGISTRAR

Applicant, AERO DRONE RESOURCES LLC seeks an exemption from the following regulation s Part 21; 14 C.F.R. §45.23(b); 14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2);14 C.F.R. §91.103; 14 C.F.R. §91.105

, 14 C.F.R. §91.109(a); 14 C.F.R. §91.119(b);14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.203(a) and ( b); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(2); 14 C.F.R. §91.417(a) and (b), as established by the FAA, in order to commercially operate an unmanned aerial system weigh ing less than 55 lbs. and operating at a maximum altitude o f 400 feet AGL for aerial imagery, research and development , training and other commercial uses including but not limited to building inspections. The grant of the exemption allowing for commercial operation will maintain an equivalent if not higher level of safety than the one proposed by the FAA regulations, benefit the public interest and create a positive impact on the stream of commerce.
The operation of the UAS conducted with strict accord of the FAA regulations and within
the conditions outlined a bove will provide an equivalent if not higher level of safety supporting the grant of the exemption request by AERO DRONE RESOURCES LLC
, including the exemption from the requirements of Part 21 and allowing commercial operations.



## NO PRIVACY ISSUES ARISE AT THE GRANT OF THE
EXEMPTION

If AERO DRONE RESOURCES LLC, is granted an exemption there are no privacy issues with regard to the operation of the UAS. Any privacy concerns, which might arise, can be alleviated by providing advanced notice to the possible affected persons.
The UAS will be operated at the request of a client. At the inception of the agreement
AERO DRONE RESOURCES LLC
, will provide the client a “ Notice of UAS operation” at least 3 days in advance outlining the operation which the client wil l need to distribute to foreseeable persons that might be affected

. This advanced notice will permit the client to field any concerns that might arise ahead of time and if necessary allow possible affected persons to vacate the area for the time of the fli ght operation.22

This type of action is no different than if a building inspection is done manually by an “inspector” positioning themselves on the fire escape with the same access to the window of a person’s apartment.
Once the UAS is ready for takeoff, t he ground station will be clearly marked with orange cones and a good sized sign noting the exact procedure in place and creating a chance for people to avoid the area if they do not wish to be caught on the film. This type of procedure can be equated wit h a movie production in a public area where people are notified in the same manner in order to have the option to avoid the area altogether.
When the UAS is rising up into its flight the main focus of the camera is the building itself, if there are faces of persons who did not provide consent to be filmed which are caught in the frame, following proper protocol AERO DRONE RESOURCES LLC, will use specifically designated software to blur out the faces before turning the finished product
over to the client wh ether it is an architect who will further use the video to generate an analysis report or submit it over to their respective client.



## CONCLUSION

For the reasons outlined above and with authority granted to the FAA by 14 C.F.R. §11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, AERO DRONE RESOURCES LLC, requests and Exemption to commercially operate the UAS, without an airworthiness certificate for experimental uses. The low

- risk UAS operations proposed by this Petitioner for Exemption fall squarely within the category of aerial data collection that has been subject to previous approval.
The grant of this exemption will advance the public inter est, promote safety practices to the public and allow AERO DRONE RESOURCES LLC, to develop new and innovative uses for UASs in a safe and compliant manner.



## GLOSSARY /ABBREVIATIONS

UAS

- Unmanned Aerial System

UAV Unmanned Aerial Vehicle

PIC

- Pilot in Command

FC

- Flight Coordinator

VO

- Visual O bserver

COA

- Certificate of Waiver or Authorization

FB O Fixed Based Operator23

CFI Certified Flight Instructor

GCS Ground Control Station

GPS

- Global Positioning System

VLOS

- Visual Line of Sight