I 

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 of Transportation Docket Management System 

West Building Ground Floor 

Room w12-140 1200 New Jersey Avenue, SE 

Washington DC 20590 

· RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

. . .~ 

..._ j.} • 

We respectfully request exemption under Section 333 of the 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, photography and real estate purposes; 

search and rescue, etc. 

Proposed Operations 

Meridian UAS proposes to use the following platforms in seeking an Exemption Pursuant to Section 333: 

Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2 Vision, 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: 

Aerialtronics Altura Zenith ATX8, STR8: Exemption 12655 to Jonathan Adams 

DJI Phantom 2 Vision+: Exemption No. 11228 to Steven Zeets 

DJI Phantom 3: Exemption No. 13203 to Matthew D. Gambill 

3DR Solo: Exemption No. 11935 to Patricia A. Lines 

In granting these previous Exemptions, the FAA has found that each of these platforms shared the 

following characteristics: 

• Weight is less than 55 pounds including payload. 

• The ability of the UAS to operate safely after experiencing in-flight contingencies or failures, and 

the presence of an auto-pilot to maintain flight stability and control. The UAS is also able to 

respond to a loss of GPS or a lost-link event with a pre-coordinated, predictable, automated 

flight maneuver. These safety features provide an equivalent level of safety compared to a 

manned aircraft performing a similar operation and mitigate the risk of command and control 

link failures. 

• Communication and control radio frequencies comply with the Federal Communications 

Commission (FCC) and other appropriate government oversight agency requirements. 

• The maximum speed of the platforms is 87 knots or less. 

Public Benefit 

Meridian UAS conducts research in a variety of disciplines. Public benefit of the UAS operations 

. proposed in this Exemption request lncludes the following societal benefits: 

• Worker safety is emphasized as UAS operations can reduce or eliminate 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 to fly slower and closer to the 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 effective than manned aerial platforms. 

Reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to the existing rules. 

1. The UAS platforms weigh less than 20 pounds, including payload; 

2. Flights will be operated within the visual line of sight of the 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 for each operation will consist of the UAS pilot and a Visual 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 operating the 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 vertically and 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. Operations will not be conducted within five (5) NM of an airport or heliport 

without permission of the airport or heliport. 

Exemptions Sought from CFRs 

Meridian UAS requests Exemptions from the following 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 of the proposed UAS platforms, OSU requests that these materials be kept in the 

vicinity of the ground control station during flight. 

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 sport pilot 
certificate holders from receiving pay for piloting duties. The UAS platforms in this petition will not carry 

passengers or cargo, and the FAA has previously ruled (Exemption No. 11062) that a Commercial Pilot 

Certificate is not required for UAS operations outside of controlled 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 to these CFRs as they are intended for aircraft that have an 

airworthiness certificate. Meridian UAS will ensure that all UAS platforms and components have an 

adequate maintenance and inspection schedule .. 

6. 91.121: Altimeter Settings 

Meridian UAS seeks an exemption from the requirement that a pilot maintains a flight level through 

reference to an altimeter. The FAA has previously stated that equivalent functionality can be achieved 

when flights occur at or below 400 feet AGL and when GPS elevation data can be transmitted in real 

time to a ground control station, given that a PIC establishes GPS elevation accuracy on-the-ground prior 

to every flight. 

7. 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Meridian UAS seeks an exemption from the requirement that fuel reserves during VFR require that no 

less than 30 minutes of fuel be maintained during the day and 45 minutes during the night. Given that 

the platforms in this petition generally have a 30 minute or less flight time, no meaningful flights would 

occur under 91.151(a). Exemption No. 11213 determined that an equivalent level of safety is evident in 

UAS flights where the operational flight time can be achieved with an additional five minutes of flight 

· time being available in fuel reserves. 

Please feel free to contact our office should you have any additional questions or 

comments. Thank you for your cooperation with this matter. 

Sincerely, 

Michael Wing