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### Michael Wing Meridian UAS CEO 940 SE Bell Av. Corvallis, OR 97333 Telephone: 541.738.2772 Email: michaelwing01@gmail.com



### October 22, 2015 U.S. Department ofTransportation Docket Management System West Building Ground Floor Room w12-140 1200 NewJersey Avenue, SE Washington DC 20590

· RE: Exemption RequestSection 333 ofthe FAA Reform Act



### Dear Sir or Madam: 

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### We respectfully request exemption under Section 333 ofthe FAA Reform ACT and Part 11 of the Federal Aviation Regulations. Petitioner: Michael Wing Meridian UAS CEO 940 SE Bell Av. Corvallis, OR 97333 Telephone: 541.738.2772 Email: michaelwing01@gmail.com 

### Meridian UAS is a LLC. Meridian UAS intends to incorporate the use of sUASs for a variety of projects which may include but not be limited to project and construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects, wildlife · and

.forestry monitoring projects; aerial filmmaking, photographyand real estate purposes; search and rescue, etc. Proposed Operations Meridian UAS proposesto use thefollowing platforms in seeking an Exemption Pursuantto Section 333: Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2Vision, DJI Phantom 3, and 3DR Solo.Previous FAA Exemptions Each ofthe platforms proposed in this Exemption request have been granted previous Exemptions Pursuant to Section 333 by the FAA based on the platform weight, speed, and operational characteristics: AerialtronicsAltura Zenith ATX8, STR8: Exemption 12655 toJonathan Adams DJI Phantom 2Vision+: Exemption No. 11228to Steven Zeets DJI Phantom 3: Exemption No. 13203 to Matthew D. Gambill 3DR Solo: Exemption No. 11935to Patricia A. Lines In grantingthese previous Exemptions, the FAA has found that each ofthese platforms shared the following characteristics: • Weight is less than 55 pounds including payload. • The ability ofthe UAS to operate safely afterexperiencing in-flight contingencies orfailures, and the presence ofan auto-pilotto maintain flight stability and control. The UAS is also ableto respond toa loss ofGPS ora lost-link event with a pre-coordinated, predictable, automated flight maneuver. These safetyfeatures provide an equivalent level ofsafety compared to a manned aircraft performing asimilaroperation and mitigatethe risk ofcommand and control linkfailures. • Communication and control radio frequencies comply with the Federal Communications Commission (FCC) and otherappropriate government oversight agency requirements. • The maximum speed ofthe platforms is 87 knots or less. Public Benefit Meridian UAS conducts research in avariety ofdisciplines. Public benefit ofthe UAS operations

. proposed in this Exemption request lncludes thefollowing societal benefits: • Workersafety is emphasized as UAS operations can reduce oreliminate field measurements. There are significant risks to workers in the construction and structural inspection industries that can be alleviated by UAS. • Manned flights pose risks to pilots. • Greater image resolution can be obtained from UAS mounted sensors in comparison to manned aircraft as UAS are able tofly slowerand closertothe ground. Increased image resolution allows for more robust analysis which can lead to increases in agricultural.and forest productivity. • Search and rescue operations can be conducted in areas that might be ordinarily be inaccessible. • UAS are more cost effectivethan manned aerial platforms.

Reasons whythe exemption would not adversely affect safety or howthe exemption would provide a level ofsafetyat leastequal tothe existing rules. 

### 1. The UAS platforms weigh less than 20 pounds, including payload; 2. Flights will be operated within the visual line ofsight ofthe pilot; 3. Maximum total flight time for each operational flight will be (45) minutes. Flight

### times may be less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the ground station with at least 10% battery power reserved; 4. Flights will be operated at an altitude not greater than 400 feet AGL; 5. Minimum crew foreach operation will consist ofthe UAS pilot and aVisual Observer; 6. A briefing will be conducted daily by all personnel working with said UAS; 7. Written and/or oral permission from relative property owners will be obtained prior to operatingthe UAS; 8. All permits, permissions, etc. will be obtained from local government offices as required; 9. The UAS will operate at speeds less than 8 7 knots, hover and simultaneously move verticallyand horizontally; 

### 10. The UAS will have the capability to return and land at the pre-determined location with the Security Perimeter should the UAS lose communication or GPS signal during any operations; 

### 11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

### 12. Operations will not be conducted over densely populated areas or heavily traffic highways; and 

### 13. Operationswill not be conducted withinfive (5) NM ofan airportorheliport without permission ofthe airportor heliport. Exemptions Sought from CFRs Meridian UAS requests Exemptions from thefollowing CFRs: 1. 91.9(b)(2), 91.203(a) and (b): Carrying Aircraft Flight Manual, Certification and Registration in the Aircraft Given the small size ofthe proposed UAS platforms, OSU requests thatthese materials be kept inthe vicinity ofthe ground control station duringflight. 2. 91.7(a): Civil Aircraft Airworthiness Meridian UAS requests that no Airworthiness Certificate be required. 3. 91.9(c), 45.23(b), and 45.27(a): Aircraft Marking and Identification Requirements Meridian UAS requests that proposed platforms bear registration numbers that are as large as practical in accordance with platform size. 4. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport Pilot Medical Certificate, Privileges and Limitations Meridian UAS seeks an exemption from these CFRs as they prevent private, recreational or sportpilotcertificateholders from receiving pay for piloting duties. The UAS platforms in this petitionwill not carry passengers orcargo, and the FAA has previously ruled (Exemption No. 11062) that aCommercial Pilot Certificate is not required for UAS operations outside ofcontrolled airspace. 5. 91.405{a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417{a) and {b): Maintenance Inspections Meridian UAS seeks exemptions tothese CFRs as theyare intended foraircraftthat have an airworthiness certificate. Meridian UAS will ensure that all UAS platforms and components have an adequate maintenance and inspection schedule

.. 6. 91.121: AltimeterSettings Meridian UAS seeks an exemption from the requirementthat a pilot maintains aflight level through reference to an altimeter.The FAA has previously stated that equivalent functionality can be achieved when flights occur at orbelow 400feetAGL and when GPS elevation data can be transmitted in real timeto aground control station, given that a PIC establishes GPS elevation accuracy on-the-ground prior to everyflight. 7. 91.151(a): Fuel Requirements for Flight in VFR Conditions Meridian UAS seeks an exemption from the requirementthatfuel reserves duringVFR requirethat no less than 30 minutes offuel be maintained duringthe day and 45 minutes duringthe night. Given that the platforms in this petition generally have a30 minute or less flighttime, no meaningfulflights would occur under 91.151(a). Exemption No. 11213 determined that an equivalent level ofsafety is evident in UAS flights where the operationalflighttime can be achieved with an additionalfive minutes offlight

· time being available in fuel reserves.



### Please feel free to contact our office should you have any additional questions or comments. Thank you foryour cooperation with this matter. Sincerely, Michael Wing