December 31,2015 U.S
. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition ofClass A Roofing Consultants for an Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012
Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (" Reform Act") and 14 C.F.R. Part II, Class A Roofing Consultants ( "Class A") hereby applies for an exemption from !he Federal Aviation Regulations ("FARs") identified below to atlO\\ commercial operation of small unmanned aerial vehicles (i.e., "smaU unmanned aircraft" or "liAS") for !he purpose of conducting aerial photography. vidcography, mapping, imaging and infrastructure inspections for the roofing and construction industries. This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Class A documents: I. PIC Flight Operations Manual and: 2. Operations Manuals (Co llectively 2 and 3 are referred to as ··Documents 

### & Manuals") 

### J. User Guide and; 4. Flight Manual' (Collectively 3 and 4 arc referred to as "Manufacturer's Manuals") Class A submits these supporting materials as confidential documents pursuant to 14 C.F.R. 

### § 11.35(b). as the materials contain confidential commercial and/or proprietary information that Class A has not and will not share with other requesting parties. Additionally, these documents conta in operating conditions and procedures that are not generally available to !he public and are protected from release under !he Freedom ofInformation Act. 

### 5 U.S.C. 

### § 552 eL. 

### seq. NOTE: ALLAITA C HMENTS S ET FORTH IN SUPPORT OFTHIS L E TTER OF PETITION ARE C ONFIDENTIAL 

### A. 

### 'ID SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN A UT HORIZATION F ROM THE PETITIONER. For your convenience, this Petition is organized as follo"s:

1 • The term "Manufacturel's Manual" also includes all relevant manufacturer publications. including, but not limited to: operations and night manuals. user guides. component maintenance manuals, pilot training manuals, ser\ icc information letters and, safety / service bulletins.

### U.S Department ofTransportation December 31, 2015 Page2 I. 

### Description of Pet iti o ner II
. Desc riptio n of Proposed Operations A. 

### Aerial Photography. Videography, Mapping. Imaging and Infrastructure Inspection Ill
. Relevant Statuto ry Authority IV
. Class A's Propo sed UAS Opera tio ns Meet the Requirements of Sec tion 333 of the Reform Ac t A. Approval is Warranted Based on the UAS's Size, WeighL Speed. and Operational Capability B. Appro\'al is 

### Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals V. Regulations From Whi ch Exemption i s Requested A. 14 C.F.R. Part 21. Subpart H- Airworthiness Certificates and 14 C.F.R. § 

### 91.203(a)(l) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c). 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. 

### § 91.405(a). 91.407(a)(!). 91.409(a)(l) and (2): 91.417(a) and (b): 

### Maintenance Inspections E. 14 C.F.R. Part 61. 14 C.F.R. 

### § 61.3. 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): Chit Aircraft Airworthiness G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration H. 14 C.F
. R. 

### § 91.103: Preflight Action I. 

### 14 C.F.R. 

### § 91.1 09(a): Flight Instruction 

### J. 14 C.F.R. 

### § 91. 11 9(c): Minimum Safe Altitudes K. 14 C.F.R. 

### § 91.121: Ahimeter Senings L. 

### 14 C.F.R. 

### § 9!.151 (a): Fuel Requirements for Flight in VFR Conditions V 1
. Drug and Alcohol Program VII. Public Interest VIII. Pri, ·acy IX
. Federal Register S ummar y X. Co nclusion I. 

### DESCRIPTIO N OF PETITIO NE R 

### Class A is based in Portland , OR working aerial photography, videography, mapping. imaging and infrastructure inspection for the roofing and construction industries. The Company

### U.S Department ofTransponation December 31.2015 Page3 specializes in, and 

### will continue to focus on the photography
. videography, mapping and infrastructure inspection for the roofing and construction industry. The Company's Principal and ChiefPilot Jeremy Tunney has been flying UAV Quadcop t ers as a hobby for more than one year without incident, logg i ng hundreds ofh ours nyi n g. Upon lhe grant oflhe 333 Exemption the Company"s business 

### will

**spcciali.~:e** 

### in photography. 'ideography, mapping. imaging and infrastructure inspection of roofing systems. Class A's staffare well trained and experienced in providing suppon as visual observers (
..VO
..) for the pilot in command (
.. PIC
.. ) in addition to any olher needed on site assistance. A11 oft he equipment owned by Class A i s of lhe h ighest quality gear and has been ab le t o provi d e these services safel y and wit hout any claims or i n

cident. Class A's goal is to a d

vise t he perspective client that Class A is following all the applicable state and federa l rules to ensure the safety ofthe public while providing the client \\ith 

### a competitive and cost effective product. Class A seeks an exemption to allow for photography. videography. 3d mapping and 

### other related media products. The contact information for Petitioner is as follows: Jeremy Tunney Class A Roofing Consultants 6020 SE 34th 

### Ave. Ponland, OR 97202 Phone: 503.896.7727: Email :

**jeremytunney gmail.com**  II
. 

### DES CRIPTIO O F PROPOSED OPERATIO N 

### Class A seek s an exemption pursuant to Section 333 of the R eform Act to operate the 

# on Phantom 3; and 

# on Phantom 2 (referred to ClassA-UAS ) (under 55lbs) for the proposed operatio ns discussed herein below. All 

### UAS operations will occur under tightly controlled conditions on private propeny or approved location where Class A has received verifiable permission to operate from the lando'"ner. controller or authorized representative. The proposed U

AS operations 

### will be conducted in accordance wilh the conditions and limitations of !his 

### Petition for Exemption and Class A"s Operations Manuals. As 

### detailed in Class A's Operations Manuals, all 

### UAS operations will 

### be limited to da)lime VFR conditions.

**~ithin** 

### visual line-ofsight ( "VLOS ") ofthe operator, in uncontrolled airspace, and will occur at least 5 

### nm away from an airpon reference point. Moreover, Class A's Operations Manuals incorporate redundant safeguar ds to assure the aircraft does not trave l out side the contr olled area of UAS operations. including GPS "geo-fencing" technologies. A
. A erial 

### V ideography, Photography , 3d 

### Ma pping and Infrastructure Inspect io n Class A seeks to use small ClassA

- UAS for lhe purpose ofconducting aerial photography, videography, mapping, imagery and infrastructure inspection fo r lhe roofmg and construction industr i es . Class A has purposefully tailo r ed its 

### opera t ions to meet the requirements established

### U.S Department ofTransponation December 31, 2015 Page4 by the FAA in prior grants ofexemption authoriz.ng commercial usc ofUA in the related industries, including:
• Trudeau. Realtor® (Exemp ti on No. 11 138) • Alon Sicherman (Exemption o. 11728) • Sokoler Medly (Exemption No. 11341) • Raven Executive (Exempt ion

**~o.** 

### 12639) • Dobbs Administrations (Exemption No. 13279) • Thomas Johann Walter (Exemption No. 12719) • Joseph Roofing (Exemption 1

### o. 13518) All UAS photography , videography, mapping, imagery and infrast ructure inspection operations will occur on private propeny or approved location in a controlled area away from spectators and persons not involved in the recording process. In 

### addition, the filming will be conducted between da\vn and dusk to ensure maximum safety 

### for the public and those involved in the manipulation and operation of the UAS; VFR conditions. at altitudes beiO\\ 400' 

### above ground level ("AGL"). As set forth below. Class A's operations provide an equivalent level of safety which is superior to performing the same \\Ork using com·entional fixed-wing aircraft or helicopters. Small UAS video production is also safer than traditional manned aircraft performing the same function. Videographer-inspectors also frequently need to climb roof tops, trees, ladders or otherwise perform elevated work. which exposes them to the risk ofdangerous falls
. electrocution or other work related injuries. In addition, depending on the nature ofthe video needed and inspection. proximity to equipment. and other mechanical hrur.ards associated

**''~th** 

### industrial sites and construction facilities often involves a risk 

### ofexposure to hazardous conditions. The 

### use ofCiassA-UAS mitigates these hazards and is ultimate)) a much safer and cost efficient method ofperforming these and most other types of inspections. Moreover, conventional operations using rotorcrafl and fixed-wing aircraft in low level operations present risks associated

**\~th** 

### vehicles weighing tens ofthousands of pounds (including payload) and carrying large amounts of fuel which inherently presents significant frre hazards as well as exposure to other chemical contaminates. It 

### is imponant to note the use of small UAS in this area \\ill not only be 

### safer and more cost effective to the perspective user or purchaser ofthe service. but the quality and expanse ofacquired information 

# ''ill be far more robust given the lo\v cost associated \\ith its acquisition and other potential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection. di ssemination, and storage ofvisual and other sensory data

**\~th** 

### greater precision and duration at a very low cost. Small UASs \\ill also be capable ofaccessing and inspecting areas that would

**othen~se** 

### be inaccessible or highI) dangerous using convemi onal aircraft or other inspection methods. Ill
. RELEVANT ST ATtrrO RY Al i THORL TY 

### This Petition for Exemption is submined pursuant to Section 333(a) through (c) ofthe FAA Modernization and Reform Act of20 12 (" Reform Act"). Congress has directed the FAA

### U.S Deparuncnt ofTransportation December 31, 20 I 5 PageS "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 ofthe Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe to do so based on the following considerations:
• The UAS's size. weight. speed and operational capability: • Operation ofthe UAS in close proximity to airpons and populated areas: and • Operation ofthe UAS within the visual line of sight of the operator. Additionally. the FAA Administrator has 

### general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(1) (defining the authority ofthe Administra tor); 49 U.S.C. 

### § 44701(1) (permitting exemptions !Tom§§ 44701(a), (b) and §§ 44702-44716. et seq.). A party requesting an exemption must explain the reasons why the exemption: ( I) would benefit the public as a whole. and (2) \\Ould not adversely affect safety (or how it would pro\ide a level of safety at least equal to the existing rules). ec 14 C.F.R. § 11.81 (petitions for exemption). IV. CO RRfDOR FIELD 'S PROPO S ED CLASS A-UAS OPERATIO S MEET THE REQUIREMENTS OF SECTION 333 OF T HE REFO RM ACf The small ClassA-UAS operntions proposed by Class A as noted above in this Petition for Exemption qualifY for expedited approval pursuant to Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. A
. Appro\ a ! is Warranted Based o n the UA S 's Size, W eig ht, Speed, and Opera ti onal Capability A Grant of Exemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.
• The ClassA-UAS utilized by Class A has been approved for use in prior Section 333 Grants of Exemption from the FAA. 2


### • The ClassA-UAS weighs less than 

### 55 pounds. including pa)load
• The ClassA-UAS will not be flown at a ground speed in excess of 50 knots. The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction
. 

## •

l

**~e.g.,** Grant ofCxemption to Trudeau, Realtor® (Cxemption No. It 138): Grant ofE\emption to Alon Sic herman (Exempcion No. 11728); Grant ofExemption to Sokoler Mcdly (Exemption 1\o. 11341 ).U.S Department of Transportation December 31. 20 15 Page6

• Altitude information "ill be generated b) equipment onboard the UAS as specified using GPS triangulation. digitally encoded barometric altimeter. radio altimeter. or any combination thereof. This information will be transmined to the pilot ,;a telemetric data feed.

• The ClassA

-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. I f connection to the remote control or ground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land wit h out i njury or damage.
• The radio frequencies used for operations and control of the ClassA-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequent) for the ClassAUAS is 2.-t GHz frequency bands. Ifthe same operations were conducted using a he 1 icopter
. the aircraft's take-off weight would likely exceed 6,000 pounds depending on payload. The difference in weight between the ClassAUA and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Res trictions S e t F orth in Class A's Operations Manuals Class A's Operations Manuals and the Manufacturer's Manual for the selected ClassA-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified 

### in this Petition for Exemption. To assist the FAA in making a safety assessment ofClass A·s proposed operations. below is a summary ofoperational limitations and conditions that Class A will adhere to, and \\hich will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: I. The ClassA-UAS "eighs less than 55 pounds, with pa) load. 2. All operations shall 

### be conducted over private or controlled

- access property wi th verifiable permission from the land owner / contro ller or authorized r epresentative. Pemlission from land owner /controller or authorized representative will be obtained for each scheduled flight prior to operation. 3. All UASs operated under the Grant ofExemption \\ill be identified by serial number. registered in accordance with 14 CFR part 47. and have identification (N- , umber) markings in accordance "ith 14 CFR part 45. Subpart 

### C. Markings '"ill be as large as practicable. 4. Minimum crew for each flight operation \\ill consist of a pilot. who 

### will be Pilot

- in Command ("PIC") ofthe ClassA-UAS, and one or more Visual Obseners ("Observer") as necessary to safely conduct the mission.

### U.S Department ofTransporta tion December 31, 2015 Page7 5. PICs shall possess either a private. recreational. or spon pilot certificate. The PIC must also 

### hold a current FAA airman medical certificate or a valid U.S. dri, ·er's license issued by a state, the District ofColumbia. Puerto Rico. a territor), a possession, or the Federal go,·ernment The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 6. The ClassA

- UAS shall be operated within VLOS ofth e PIC and Observer at all times. The PI C mus t use human vis ion unai d ed by an y device ot her than corrective lenses
. as spec ified on the PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate "erbally at all times. 8. Electronic messaging or texting ,,;11 not be permined during flight operations. 9. The additional requirements identified in the Grant ofExemption shall be added to the Class As Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. I f a discrepancy exists between the conditions and limitations in the Grant of Exemption and Class A"s Operat ions Manuals, the condi t ions and limitations in th e Grant of Exemption shall take pr

ecedence an d must be followed. Other wise, Class A shall follow the procedures outlined in t hei r Operations Manuals. I0. Class A may update or revise its Operations .\1anuals. R evisions will be tracked and a revised copy ofthe Manual will be provided to the Administrator upon request. Class A will also 

### present an updated and revised Operations .\1anuals if it petitions for extension or amendment to its Grant ofExemption. If

### an update or revis
. ion would affect the basis upon w 

### hicb the fAA grants the exemption, Class A 

# ,,;u seek an amendment tO its Grant of E: "emption. Class A will contact the FAA's UAS Integration Office (AFS

-80) ifquestions arise regarding updates or revisions to the operating documents. II. Class A O perations Manuals and its Gr ant of Exempt ion will be avai lable to the PIC at t he ground control station anytime th e C lassA

- UAS i s operating. 12. The PIC is prohibited from beginning 

### a ClassA

-UAS flight unless (considering wind and forecast weather conditions) there is enough power to fly to the fiCSt intended point of landing. and assuming normal cruising speed, to fly after that for at least I0 minutes. 13. Maximum total flight time for each operational flight using the ClassA-UAS will be limited to 

### 40 minutes or the amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%, whichever occurs first. I4. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable controlled airspace 'vithout ti mely prior v.Titten authorization and approval from the FAA. ln the event th e st ructure being inspected exceeds 400 feetU.S Department ofTrans portation December 3 1, 2015 PageS AGL. the UAS \\ill not be operated more than I00 feet above the highest point on the structure. and no more than 50 feet horizontally from the structure. IS. Flight operations must be conducted at least 500 feet from all nonparticipating persons. ( persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons f rom the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises

**'~here** nonparticipating persons leave such protection and are within 500 feet of the UA
. flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures

**'~here** the O\\nerlcontroller of such , ·essel s. vehicles or structures has granted permission and the PIC has made a safety lSsessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 16. The ClassA

- UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 17. The ClassA-UAS may not operate within 

### 5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless a lcner of agreement with that airport's management is obtained, and the operation 

### is conducted in accordance with a ' OTAM as required b)' the FAA. The lener of agreement \\ith the airport management \\ill be made a'ai l able to the Administrator upon request. 18. Prior to each flight the PIC shall inspect the ClassA-UAS to confinn that it is in a condition safe for flight. The pre-flight inspection will account for aU discrepancies, e.g. inoperable components. items. or equipment, not already covered in the relevant sections ofthe operating documents as well as equ ipment updates. The PIC shall not operate any ClassA-UAS if the inspection reveals a condition th at affects the safe operation ofthe ClassA-UAS until the necessary maintenance has been performed and the ClassA-UAS is found to be in a condition for safe flight. The ground control station shaU be included 

### in the preflight inspection. All maintenance and alternations must be properly documented in the UAS's records as 

### required by Class A's Operations Manuals. 19. Class A 

# ,,;u timely Cart) out its maintenance. inspections. and record keeping requirements 

### in accordance with the Operations

**~annals.** Maintenance, inspection, and alterations will be full) noted in the ClassA-UAS records, including total time 

### in service. description ofwork accomplished. date completed and the signatune ofthe authorized person returning the ClassA-UAS to service.

### U.S Depanment ofTransportation December 31, 20 15 Page9 20. Any ClassA-UAS that bas undergone maintenance or alterations that affect the UAS operation or flight characteristics

**e.g~** 

### replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Class A's Operations Manuals. The PIC "ho conducts the functional test flight must make an entry in the UAS aircraft r eco r ds ofthe flight. The requirements and procedures for a functional test flight and ClassA

-UAS record entry shall be includ ed in the Class A's Opera tions Manuals
. 2 1
. The ClassA

- UAS will be operated and maintained acco rding to t he Manufactur er's Manuals and any required manufacturer Safety / Service Bulletins and produc t updates. 22. Prior to the operation. a Mission Packet 

# ,,;u be created in accordance "'ith the requirements on Class A's Operations Manuals. 23
. Class A 

# '"ill obtain an Air Traffic Organiau:ion ("ATO ") 

### issued Certificate of\Vai\er or Authorization. othel'\\ise known as a COA, prior to conducting any operations under this Grant ofExemption. A O T

AM will be 

### issued as required b) the COA. All operations \\ill 

### be conducted in accordance with airspace requirements in 

### the ATO issued COA including class ofairspace, altitude level and potential transponder requirements
. 24. All requ ired pe rmi ssions and permits w ill be obtained from territorial. state, county or cityjurisdictions
. including local law enfo r cement, fire or other appropriate governmental agencies. 25. Ifthe ClassA-UAS loses communication with the PIC
. it \\ill 

### have the capability to safely rerum to a pre-determined location within the operational area and land safely. 26. Contingenc) plans will be in place to safely t. erminate flight ifthere is a loss of communication between the PIC and the Observer. 27. The ClassA-UAS 

# '"ill ha\e the capability to safely abort flight in the ease of unpredicted obstacles or emergencies. 28. P!Cs and Observer s will have at least a current Class III Medical Certificat e or u val id and current state driver's license issued wi t hi n the United States
. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in 

### a manner consistent with 14 CFR 

### § 61.51 (b)
. a minimum of200 flight cycles and 25 hours total time as a U AS rotorcraft pilot and at 

### least I 0 hours logged as a UAS pilot \\ith a similar ClassA

-UAS type 

### platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming, the PIC '"ill 

### ha' e accumulated and logged
. in a manner consistent with 14 CFR 

### § 61.51 (b)
. a minimum ofhours pursuant to 54 CFR § 

### 61.51(b) as UAS pilot operating the make and model ofC1assA-UAS to be utilized for operations under the exemption and three take-offs and three landing in the preceding 90 days .U.S Department ofT ransportation December 31.2015 Page 10

31. Operation s shall occur during daytime VFR Meteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The ClassA-UAS shall remain clear and yield the right ofway to all other manned operations and acti\ ities at 

### all times (including, but not limited to. ultralight vehicles. parachute acti\·ities, parasailing acth ities, hang gliders. etc.). 33. ClassA- UAS Operations under Instrument Flight Rules, at night. or beyond VLOS 

### are prohibited. 34. The UAS will not be operated from an elevated platform unless designed and engineered specifically for such purposes and be in compliance with the general restrictions imposed b) the applicable regulations. Additionally no PIC \\ill provide any film-flight operat ions while in m01ion from atop any elevated platform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control of the ClassA-UAS wi ll comply with the Federa l Communications Commission (FCC) or other appropriate govenunent oversight agency requirements . 

### V
. REGULAT I O NS 

### FROM WHICH EXEMPTIO N IS REQ UESTED The Federal Aviation Act expressly grants the FAA the authority to issue exempti ons. This statutory authority. b) its terms, includes exempting civil aircraft, 

### as the term is defined under 

### § 40101 ofthe AcL including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 3 Class A seeks an exemption from several interrelated provisions ofTitle 14 of the Code of Federal Regulations ("14 C.F.R") Pans 21 , 45.61 and 91 for purposes ofconducting the requested operations using ClassA

- UAS platforms noted above. Listed below 

### arc: (I) the specific sections of 14 C.F.R for \\hich exemption is soughL and (2) the operating procedures and safeguards that Petitioner has established whi ch will ensure a level of safety bener than or equal to the rules from which exemption is sought.• UNMANI'I 'EO A IRC R AFT 

### SYSTEM A. 14 C.F.R. Part 21, Subpart H -Airwort hiness Certificates and 1 4 C.F.R. §91.203(a)( I)
J 49 U.S.C. § 4470 I(f) (authoriling lhe g,ant ofe.xemptiOO$ from requirements of regulations presaibed pursuant to Seetions 44701(a) and (b) and Sections 44702

- 44716)
. • 14 C.F.R § 11.81(e), "hich requires a petition for exemption 10 include: The reasons wb) granting lhe e,,emption \\OUid not adversely affect safel). or ho" the exemption would provide a le,el ofsafety at least equal to that provided by the rule from "hich )OU seek exemption.U.S Department ofT ranspOrtation December 31, 20 15 Page II
The FAA has Stated that no exemption is needed from this section 

### ifa finding is made under the Reform Act that the UAS selected provides an equivalent Je,el of safety when compared to ain:raft normally used for the same application. These criteria are met and in pOint of fact exceeded, and therefore no exemption is needed. s If, howe ver . t

h e FAA de t ermines that there are some characteristics ofthe chosen UAS that fail t o meet the requirements ofthe Reform Act. an exemption is requested
. Eq uivt1 lent Level of Sa

fety Class A's use ofthe ClassA

-UAS is safe \\hen taking into account i ts size
. weight. speed, and operational capability. As set forth in the description ofproposed operations in Section IV(A) , the ClassA-UAS weighs less than 55 pounds, including payload and ...,;11 not be flov.n at a ground speed in excess of 50 knots. The ClassA-UAS is also equipped with safe!) features which will allow Petitioner to operate the ClassA- UAS safely after experiencing certain in-flight contingencies or failures as noted belo\\
. 6 1 Additionally. the ClassA

- UAS carries neither pilots nor passeng ers . carries no explosi'e materials or flammable liquid fuels. or other elements identified by Homeland Security as being prohibitive and operate exclusively within the pa rameters stat ed in Class A's Operations M anuals. Operations conducted un der th i s exempt i on will 

### be closely controlled and monitored by t he PIC operator and will 

### be conducted in compliance 

### with local public safety requirements, to provide security for the area ofoperation. Class A will also provide the FAA with advance notice of all

' See Grant o f Exemption No
. 11062 to Aslraeus Aerial (F AA-2014.{1352 81 pgs. 13-14, 22 )
. • See e.g. . Grant ofE.,emption No. II IS4t o Lo" Counll) RC, Corp
. (FAA

-2014.{1803 81 pg. 3 ): "The [DJI SIOOO] has the capability to operate safe!} after experiencing cenain in

- flight contingencies or failures and uses an autopilot system to maintain U AS stabilil) and control. The UAS is also able to respond to a loss ofglobal positioning S}>tem (GPS ) or a lost

- link evem witb a pre-coordinaled , predictable , automated flight maneu,er. and manual flight oontrol functionality as a baclmp
. These safety

**featu~** provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation
.• 7 Sec e.g., Grant ofExemption No. 111 8 4to VDOS Global, LLC. (FAA-2014.{13 82 atpgs. 4-5) : "The ClassA-UAS can be operated entire l y by a touch-screen. map-based in terface. This means tbe operator only needs to command the system where to go, and the system does alltbe nying for t he operator. The ClassA

- UAS can be opernted in botb semi and fully autonomous night mode s , with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, tbe operator can create no ny zones or ma.ximum flight ranges and altitudes so the S >

S tem cannot enrer areas deemed unsafe or unnecessary tony over. The petitioner states further thai the UAS has built-in intelligent fault handling which allows tbe ClassA-UAS to detect a system fault wbile in the air and automalicall) fly back to its takeofflocation and

**l:u~d**

**.** FaultS that can be detected include: loss ofcommunication ;

**ex~ing** pre-set "ind thresholds: and lo" banery le•els." All flight opera tions are global positioning S ) S

tem (G PS) controlled. making the system eas) to na"gatc
. At an) point ifthe operator is not CX'Jllicitly commanding the system to move, the system amomatically bolds its GPS pos i tion
. The flight comrol system employs not on I) GPS positioning but a variety 

### or sensors including sonar, barometric pressure, temperarure. wind speed and others to ensure stability so long as wind thresholds are not c'cecded. AI so a flight termination link -to prevent a •ny away' or other potentially dangerous situation is available to the opemtor.•U.S Department of Transportation December 31,2015 Page 12 operations \ia 'OTAMs as required by the applicable CO A. 

### In aU cases. operation ofthe ClassA-UAS under the proposed conditions will 

### be at least as safe as, or safer 

### than. comentional rotorcraft operating \\ith an airworthiness certificate. Lastly. the ClassA

-UASs do not need a means to communicate with other aircraft or ATC, because those capabilities will be solely possessed by the PIC and Observer. who 

### are not onboard the ClassA

-UAS. 1 ln addition. no sense-and-avoid techno logy is necessary for the ClassA-UASs because they will be opera ted at all times in VFR conditions and within VLOS oflhe P IC and Operator. 9 

### B. 14 

### C.F.R. Part 27 Airworthin ess S tandards: Normal Category Roto rcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for aimorthiness certification of nonnal category rotorcraft. To the extent that Class A's small ClassA

-UAS would othemise require certification under Part 27. Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. R. Pan 21. Subpart H. supra. C. 14 C.F .R. 

### §§ 91.9( c), 45.23 ( b ) and 45.27 (a ) : Aircraft 

### Marking and I d e ntification Requi.rements Class A seeks an e x emption from the aircraft marking and identification requirements contained in 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a).
• 14 C.F.R. 

### § 9 1. 9(c) , Civi l Aircraft Flight Manual
. Yiarking and Placard requirements
. provides that:
o person may operate a U.S.-registered civil aircraft unless that aircraft 

### is identified 

### in accordance with Part 

### 45 of this chapter.
• 14 C.F.R. 

### § 45.23(b). Markings ofthe Aircraft. states: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, rest ri cted or light

- sport category aircraft or experimental or provisionally cert i ficated aircraft. the operator must also display on that aircraft nea r each entrance to the cabin. cockpit, or pilot station. in letters not less than 2 inches nor more than 

### 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional." as applicable.
• 14 C.F.R. 

### § 45.27(a)
. Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcrafi horizontally on both surfaces of

### the cabin, fuselage, boom. or tail the marks required by 

### § 45.23.

1 See Grant ofExemption No. 11062 to Astraeus Aerial (FAI\ -20t4-0352 at pg. 13)
. • . ldU.S Department ofT ransportati on December 31, 20 15 Page 1 3


### In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted p rovided that the aircraft "have i dentification (N-Nurnber) markings in accordance with 14 C.F. R P art 45, Subpart C ifthe markings are as la rge as practicable." 10 Equivalent Le vel o f S afet y All C lassA

- UAS flown by Class A wi ll bear N-numbe r markings that are as l arge as pract icable in accordance with 14 C.F.R
. Part 4 5 , Subpart C. 11 D. 14 C.F.R. § 91.405 (a ), 91.407 (a )(l ), 91.409 (a )( l ) and (2); 91.4l7(a ) and (b) : Maintenance Inspections Class A seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R
. 

### § 9 1 .40 5 (a), 91.407(a)( l ), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection stan dards in re f erence to 14 C.F
. R
. Part 43. See, e . g ., 14 C.F.R. 

### § 91
.405(a) ( stating that each owner or operator of an aircraft "(s)hal l have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections
... h ave discr epanc ie s repa ired as prescribed in part 43 ofthis chapter"). An exemptionfrom rhese regularion.s is needed because Part 43 and these secrions only apply to aircraft with an ainvonhiness certificate, which the UAS platforms robe operated under this gram of exemption will nor have. (Emphasis added) Equivalent L evel of Saf ety An equivalent level of safety will be achieved or exceeded because mai ntenance and inspections will 

### be timely per formed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Servi ce Bulletins. Further, as required by Class A's Operations Manuals, the P IC will conduct a pre - fl i ght inspection ofthe ClassA-UAS and all associated equipment t o account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation of the ClassA

-UASs and no fligh ts 

### will occur unless, and until, all flight cri tical components ofthe ClassA

-UAS have been found to be airworthy and in a condition safe for operat ion . A functional test flight will 

### be conducted following the replacement of any fl ight

-cri tical components. As required by Class A's O perations Manuals, t he PIC who conducts the functional test flight will make an entry in the ClassA

-UAS aircraft records ofthe fl i ght. Class A's Operations Manual also includes requirements to follow the manufacture r 's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limi t requirements for the following applicab le components : powertrain system (powerplant), propellers, avionics and control surfaces (includi ng aileronslelevons), structures 

### & airframe, camera system, electrical systems (includi ng batteries), ground control station, hazard accessories, an d spare parts. Further, Class A's Operations Manuals also incl ude procedures to document and maintain a record ofthe ClassA

-UAS's maintenance, preventative maintenance, al terat ions, status of replacement /overhaul component parts, and the total time in service ofthe C lassA

-UAS used un der th i s Grant ofExemption
. As a whole, the maintenance and inspection procedures r equi red 1

# ° FAA Docket No. FAA-2014

- 0352 ll See, e.g., FAA Docket No. FAA-2014-0352, at 14.

### U.S Department of Transportation December 31.2015 

### Page 14 in Class A"s Operations Manuals ensure that an equivalent or higher level of safety will be achieved
. PILOT

- IN-COMMAND OF T HE UAS 

### E. 14 C.F.R
. § 

### 61.113: Prh ·a te Pilot Prilileges 

### and Limitati ons 

### Class A seeks exemption from 14 

### CFR § 61.113. 

### which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose ofPart 61 

### is to ensure that the skill and competency ofany PIC matches the airspace 

### in which the 

### PIC "ill be operating, as 

### well as requiring certifications 

### ifthe private pilot is carrying passengers or cargo for hire. In 

### this 

### case. while the 

### ClassA-UAS will be operated as 

### parr of a commercial operatiOD, they CarT) 

### neither passengers nor cargo. In 

### the Grant ofExemption to Astraeus Aerial. the FAA 

### determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class ll 

### Medical Cenificate. 12 

### The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are imolved. Equivalent Level of Safety 

### The restrictio ns Class A has placed on its ClassA

-UAS operations meet or exceed lhe restrictions similar!)' imposed on Astraeus Aerial. Class A '"ill operate on private property away from persons and property not invohed in the operation. Class A ''ill also 

### obtain an ATO issued COA prior to conducting any operations under this Grant ofExemption. All 

### operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 1 

### 0TAM will also be issued as required by the applicable COA. In addition to these flight restrictions. Class A will further ensure safe operation by requiring that any PIC be thoroughly Yersed 

### not only in airspace and communication issues penaining to all aircraft operators but also in the unique aspects ofClassA- U AS flight. As set fonh in the Operations Manuals, pilots will have experience not only in ClassA

- UAS operations generally but have logged flight time in the speci fie ma k

e and model used for the operations before they are permitted to participate in commercial flights on behalfof Class A. The pilot qualification. training, and currency requirements in the Operations Manuals ensure that Class A pilots are competent and proficient in the ClassA-UAS they are operating. Class A's training and 

### qualification requirements are consistent wilh those contained in prior FAA 

### Section 333 

### Grants of Exemption. and will provide 

### a higher level ofcompetenc y and proficiency for its pilots and will ensure at least 

### an equivalent level of safety to the public. O P ERA T I NG PARAMETE R S OFTHE U AS 

### F. 14 C.F .R
. § 9L7( a): 

### Chi ! Aircraft Airworthiness
12 Exemplion No
. 11062 (FAA Dockel No. FAA-2014-0352).U.S Department of Transportation December 31. 2015 Page 15 Inasmuch as there 

# ''ill be no aimorthiness certificate issued for the UASs. Class A seeks an exemption from 14 C.F.R. 

### § 91.7(a). ''hicb requires that a ci,iJ aircraft be in aiJ"\\Orthy condition to be operated. The FAA bas stated that no exemption is required for 14 C.F.R. 

### § 91.7(a) to the extent that the requirements of Pan 21 are waived or found inapplicable. n Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with Section V(A), supra. G. 14 C.F.R. § 9 1.9 (b)( 2) : C ivil Airc raf t F lig ht Manual in the Airc raf t a n d 14 C
. F
.R
. 

### § 91.203 (a ) and (b) : Car r y ing C ivil A ircraf t C e rtificati o n a nd R eg istrati on Title 14 C.F.R. 

### § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry aim ·orthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.f.R. 

### § 91.9(b) (2): (b) o person may operate a U.S.-registered civil aircraft- (2) For which an Airplane or Rotorcraft Flight Manual is required b) 

### § 21.5 ofthis chapter, unless there is a,·ailable in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings. and placards. or any combination thereof. Pursuant to 14 C.F.R. 

### § 91.203(a) and (b): (a) Except as provided in 

### § 91.715, no person may operate a civil aircraft unless it has within it the following: (I) An appropriate and current

**am~orthiness** certificate
... (b) No person may operate a civil aircraft unless the amvorthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under 

### § 91.715 is displa) ed at the cabin or cockpit entrance so that it is legible to passengers or crew. Given the small size and configuration ofthe ClassA -UAS. it would be impossible to keep aimorthiness documents and other aircraft manuals on board the ClassA-UAS because there is simply no room and the ClassA-UAS has no cabin or cockpit. As a way to comply with the code Class A will maintain the documents with the PIC and make them available for inspection. 

### Equivalent Level of Safety In an FAA Office ofChiefCounsel's Opinion dated AugustS. 2014. and prepared b) Dean E. Griffith, Anomey. AGC-220. it was ackno,,ledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met 

### ifthe pilot ofthe unmanned aircraft bas access to the UAS night manual. registration certificate. and other required documents from the ground control station from "hich he or she is operating the aircraft.'' As this FAA Office ofChiefCounsel Opinion
IJ See ld. a1 13

- 14, 22. "Memorandum from Marlt Bury. FAA Assistanl ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014·0352 at 16-18.U.S Depanmem ofTransportation December 31, 2015 Page 16 clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has access tO the documents at the ground control station from wh ich he or she is piloting the UAS
. H. 

### 14 C
. F .R. 

### § 91.103: Pr eflight Action Class A seeks an exemption from 14 C.F.R. § 91.103, which requ ires a PIC to become familiar w ith specific information before each flight, including infom1ation contained in the FAA

approved Flight Manual on board the aircraft. Whjle the PIC will be farlliliar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAAapproved Fligh t Manual is reqwred
. 

### Equivalent L evel of S afety An equivalent level of safety will be provided by following the Class A's Operations Manuals and the Manufacturer's Manual
. The PIC will perform a series ofchecklists designed to identi fy my defects or inoperable components in accordance with the Class A's Operations Manuals, including checkJjsts covering Pre

- Flight, Launch, Lmdillg, md Post-Flight procedures. The PIC will also be required to review weathe r , flight requirements, battery charge, landing and takeoff distailce, UA performance data, and contingency l mding areas-before injtiation of fl i ght. Class A's Operations Mmuals and the Manufacturer's Manual will be kept at the ground cont ro l station and will be accessible to the PIC at all times while operating the UAS. 

### I. 14 C.F.R. 

### § 91.109 (a) : F light Inst ruction Class A seeks an exemption from 14 C.F.R
. 

### § 91.1 09(a), which provides in pertinent part that "LnJo person may operate a civil aircraft (except a marmed free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual cont'rols." UASs md remotely piloted aircraft, by their design, do not have functional dual controls.**In~-tead,** flight control is accompl ished through the use of a device that conunullicates with the aircraft via radio communications
. Accordingly, m exemption will be required for the !light instruction requir ements of 14 C .F. R
. 

### § 91.109(a).



### Equivalent Le vel of Safety Given the size and speed ofthe UASs that Class A intends to use, m equivalent level of safe training can sti II be performed without dual contro ls because no pilot or passengers are aboard the UAS, and as required by the Class A's Operat ions Marmals, all persons will be a safe distance away in the event that the UAS experiences my difficulties during flight instruction. Moreover, as reqwred by the Class A's Operations Mmuals, all ilight training will be conducted in controlled and sterile enviroument. As a whole, the safery procedures provi ded for in Class A's Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level of safety than that pro vided by the flight instruction regulations.U.S Department ofTransportation December 31. 2015 Page 17 

### J. 14 C.P.R. § 91.119( c) : Minimum Safe Altitudes Class A requests an exemption from the minimum safe altitude requirements of 14 C
. F
. R. § 91.119(c). u Section 91.119 prescribes the minimum safe altitudes unde r which aircraft ma) not operate. including 500 feet above the surface and away from any person. vessel. \ 'Chicle, or structure in non - congested areas . See 14 C.F.R. § 91. 1 19(c). Section 91.1 1 9(d) allows for a helicopter to operat e at le ss than those minimum altitudes when it can be operat ed "without h azard t o persons or property on the surface." provided t h at "each person o perating the helicopter complies with any routes or alt itudes specifically presc ribe d for he licopters by the FAA." An exemption is r equired because the proposed ClassA-UAS operation 

### will normally need to occur below 400 feet AGL. In circumstances where the ClassA

- UAS is used to inspect a structure

**'~hose** height exceeds 400 feet AGL. the ClassA

- UAS 

### "ill not be operated more than I00 feet above the higheSt point on the structure, and \Vi thin 50 feet horizontally of the strucrure. Additionally. due the nature ofthe proposed operations. the Pilot and/or Observers(s) may need to be less than 500 feet away from the ClassA-UAS. 

### Equiv al

e nt Le vel o f Safety Compared t o nigh t operations with rotorcrafl \\Cighi ng far mo re than the maximum weigh ts proposed herein, and gi ven the lack of flammable fuel wi t h t he above noted UASs. any ri sk assoc iated with these operations is far less than those which pre sently exist with conventi onal aircraft. An equivalent le vel of safety will be achieved given the size
. weight
. and speed of the ClassA-UASs, as well as the controlled location where the operations will occur. In order to avoid any risk to manned aircraft. flight operations will be restricted to 400 feet AGL or belo\\. or when inspecting a U.S. structure whose height exceeds 400 feet AGL. within 100 feet above the highest point on that structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals. the Class..\

- UAS \\ill be operated in a restricted area, and all nights \\ill be operated at a lateral distance ofat least 500 feet from any nonpanicipating persons, unless that person 

### is in a position where he or she is shielded from the ClassA-UAS and an) possible debris resulting from its failure. As required by the Operations Manuals, flights ''ill be terminated 

### ifa nonparticipating person wi t hin 500 feet oft h e ClassA

-UAS lea,·es a shielded position. Further, its o perations will occur at least 500 feet away from vehicles or structures unless the property owner /controller time ly has gmnted permissi on and the PIC has made a safe t y assessment ofthe risk of operati ng closer to t hose objects and, operations ncar t he PIC or Observer will not p r esent an undue ha7.ard per§ 91. 1 19{a). Adherence to these restrictions in Class A's Operations Manuals will ensure operations can be conducted without compromising

" Relief from § 9t
. ll9(a) 

## ,.;n not be necessary because Pe!itioner will be able to perform ao emergency landing "ithoUI undue hazard to persons or propel1) on the ground in the e•ent ofa fuilure
. Petitioner's proposed U AS opcrntions will not

**oc~ur** over congested areas. and therefore an exemption from§ 9l. l t9(b) will nOt be necessary. See e .g. , Grant of Exemption No. 11157 to S1ugwettr, Inc
.. dba Like on a tree Aerial (FAA-2014-0534 at 15).U.S Depanment ofTransportation December 31. 2015 Page 18 public safet). 16 K
. 14 C .F.R
. § 

### 91.Ul: Altim ete r et tings Class A seeks an exemption from 14 C.F.R. 

### § 91.121, which requires a person operating an aircraft tO maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the depanure airpon or barometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out. 

### Equ ivalen t Level of Sa

fety The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (I) the UASs will be operated belo\\ 400 feet AGL or below". (2) \\ithin VLOS. (3) where GPS 

### based altitude information is relayed in real time to the operator at a ground-based on-screen displa) and. (4) where prior to each flight. a zero altitude initiation point is established for the PIC to confirm accuracy ofthe on board GPS. 11 The ClassA-UAS that Class A intends to use for the proposed operations will meet all these operational characteristics. Moreover. as required by Class A's Operations Manuals. the PIC 

### ,,;11 be required to calibrate the aircraft's G PS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption. the ClassA-UAS Class A intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level of safery or greater level will be achieved. and a Grant ofExemption to the requirements of§ 191.121 is therefore appropriate. 

### L. 14 C.F.R
. § 

### 91.15l (a): Fue l R equi re ments for Flight in VFR Conditi ons Class A requests an exemption from 14 C.F.R. 

### § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) 'o person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel tony to the first point of intended landing and, assuming normal cruising speed

-
t6 See e.g., Gmm ofExemp tion No. 11138 to Douglns Trudeau (FAA -2014-048 1 at 19): "if barriers or structures are present that can suOicieo tly protect nonpanicipating persons from the UA or debris in the event ofan accident, then the UA may operate closer than 500 feet to persons afforded suc h protection. The operator must also ensure that nonpanicipoting persons remain under such protection. If a situation arises where nonpanicipoting persons leave such protection and are within 500 feet of the UA. night opemtions must cease immroiately. When considering how to immediately cease operations. the primary concern is the safety of those nonpanicipatiog persons. In addition, the FAA finds that operations ma> be conductro closer than 500 feet to vessels
. •chicles aod suuctures \\hen the o"ner controller of &n)' such vessels, '"'bides or strUCtum gants pennission for the opmilion and the PIC males a safe!} assessment ofthe risk ofoperating closer to those objtcts and detrnnines that it does 001

**~nt** an undue hll1.llrd.• 17 Ifthe height of the structure being inspected e"ceeds 400 feet AGL, the UAS "ill 001 be operated more than 100 feet abo•e the highest point on the structure. tS See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-20 14-0352 at 21).U.S Department ofTransponation December 31, 20 I 5 Page 19 (I) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here. the technological limitations on UAS bauery power means that no meaningful flight operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of 14 C. F.R
. 

### § 91. 1 51 (a) is therefore requ ired
. Moreover, it is no t Class A's intention to fly t h e C lassA

- UASs a t night. 

### Equivalent Level of S af ety In the Grant ofExemption to VDOS (Exemption 'o. 11112). the FAA determined that an equivalent le\·el of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a ClassA-UAS flight unless (considering v.ind and forecast weather conditions) there was enough pQ\'-"Cr to fl) to the first intended point of landing and, assuming normal cruising speed. to fly after that for at least I 0 minutes. 

### In reaching this conclusion, the FAA considered that the UAS ba11eries for the ClassA

- UAS provide approximately SO minutes ofpowered flight (with payload) and provided battery level and battery time remaining in minutes and seconds to the PIC. 1 9 The FAA also considered the fact the ClassA-UAS operating manual sta tes: "stan every flight with a fully charged bauery in the aerial vehicle'', and that i n the even t that t he C lassA-UAS should run low on power, the PIC will be alencd and can safely land the

- ClassA

- UAS as soon as possible
. Like the VDOS Grant of Exemption, Class A's use ofthe ClassA-UAS, combined with the requirements of Petitioner's Operations Manuals. ensure that an equivalent level of safety can be achieved and in fact exceeded. Similarly. in the Grant of Exemption to Alan Purwin (Exemption

**~o.** 11161 ). the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a flight \vith the UA unless (considering wind and forecast weather conditions), there was enough po''er to safely fly at normal cruising speed tO the intended landing point and land the UA with 25% bauery power remaining. Class A will adhere to this limitation for it s ClassA-UAS flights. The ClassA

- UAS incl udes a low battery warn ing system and the amount of battery reserve power remaini ng is continuo usly transmitted to the PI C v ia te lem etric data feed, which downlinks from the C l assA

-UAS to a ground-based-on-screen d i splay. 20 As required by Class A's Operations Manuals, the PIC will promptly fly the ClassA

-UAS back to the home launch location or pre-determined abort location where it may safely land, while still maintaining a minimum of25% reserve battery power. Class A submits that the procedures requiring flights to be safely terminated once the batteries fall belov. 25% capacity, combined with the requirement that flights only be conducted "ithin a secure. isolated area. using a UAS weighing less than 55 19

. Gran1 oflxemption No. 1111210 VDOS Global, LLC (FAA-2014-0382 at 10). 2 0

. The ClassA-UAS ground eon1r0l swion displays, the UASs position. navigation route. Jail number. ahitude, heading. nonh -king arrow. range to

**~argets.** calculated 1arge1 posilion, datMime. and sensor heading and orientation relalive to 1he UAS.

### U.S Depanment ofTransportation December 31. 2015 Page 20 pounds, an d within VLOS ofthe PIC and ObserYer(s), ensure thai 

### the proposed operation will provide an equivalent or higher level of safety to the public to that provided by the regulations from which exemption is sought. VI
. DRUG AND AL C O HOL PROGRAM 

### Class A ,,;ll have policies in place 10 

### ensure that no person may participate in ClassA

- UASs flig)u operations ifthey are under the influence of alcohol or any drug. VII
. 

### PUBLI C INTERES T The pu blic int e

rest will be served by granting Class A's P eti tion for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in contro lled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act-the FAA Administrator's assessment of\\hether certain UAS ma} operate safely in the

AS before completion ofthe statutorily required rule making. The proposed ClassA-UAS operations in this Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whom penuission was granted f or use by Petitioner and abutting properties. staff of P eti tioner, unsus pecting passersby, inspecting engineers from rel evant organizations and all those who may be in the loca l vicinity. Traditional methods ofinspect ing and monitoring potential locations and relevant sites and facilities requires location personnel to climb towers . trees. venture onto precarious roofs and other dangerous scenarios, perform elevated work for "hich the individual is neither trained nor equipped to perform, which exposes tbem to unnecessary risk ofserious ph:rsical injury from dangerous falls or other physical mishaps. Moreo' er, inspectors/surve:rors are often unnecessarily exposed to hazardous conditions
. unsafe environments, culturally tense situations and other hazards associat ed with identifYing specif i c locations for potential recording si t es to be used in the end product. The use of small UASs can el i minate these hazards and ultimately create a much safer method of performing these types of inspections creating a safer environment for the public as well as Class A employees. The use ofsmall UAS also enhances safety and 

### reduces risk to tbe surrounding public because. unlike manned aircraft \\eighing thousands ofpounds, CIUT)ing crew in addition to flammable fuel, the UAS carry no passengers. crew or explosive fuel. Furthermore. in the unlikely event of an accident, Class A's small bancry powered ClassA-UAS presents significantly less danger to persons on the ground when compared to operations by conventiona l manned a ircraft
. 21 

### As Petitioner's ClassA-UAS are battery powered
. the pub li c will also benefit from a r eduction in 21 See Grant ofExemption No
. tit 58 to Twn 5. LLC (FAA-2014.{)783 ru 12): "Manned helicopters conducting aerial filming can \\tigh 6.000 pounds or more and are operated b) an ooboard pilot. in addition 10 Olher onboard cre"members. as ntteSsat)
. The petilioner·s UAS \\ill "eigh less !han 55 pounds "ilh no onboard pilol or ere". The pil01 and.,_. will be remo1el) located from the aircraft. The limited weigh! signiJ'Jcanll) reduces llle potential for hann 10 participating and nonpaniciparing individuals or propen) in !be evem ofan incident or accidenL Risk to an onboard pilo1 and crew during an inc idem or accident is eliminated witllllle use of a UA for the aerial filming operation."U.S Depanment ofTransportation December 31. 2015 Page 21 hann f ul petroleum 

### based emissions associated \\ith conventional aircraft perfonning in the same functions proposed herein. 

### Air quality 

### will narurall) be improved \\ith the reduction of fuel powered vehicles. Lastly. as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UASs provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree of flexibility
. which supplements the current capabil ities offer ed by manned aircraft. 22 The quality of the finished product is enhanced and provides a greater fin ished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility of production: therefore. given the lower cost. owncr 'o perators and others in the relevant industry 

### ";11 be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's
. 

### VIII. PRI VA CY All ClassA-UAS operations 

### will be conducted in accordance \vith applicable federal. state, and local laws regarding privacy. 

### AIJ operations shall be conducted over pri vate or controlled-access property \vith permission from the land owner /controller or authorized representative. Pennission from land owner /controller or authorized representative will be obtained for each night to be conducted. 

### IX. FED E RAL R EGI STER SUMMA RY Pursuant to 14 C.F.R. Part II. the following summary is provided for publication in the FEDERAL REGISTER. should it 

### be determined that publication is needed: Petitioner seeks an exemption from the follo\\ing rules in Title 14 of the Code of Federal Regulati ons: Part 21. Subpart H; Part 27; 45.23(b): 45.27(a); 6 1. 113; 91.7(a): 91.9(b)(2): 91.9(c); 91.103; 91.109(a); 91.119(c); 9l.l21: 91.15l(a): 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(aXI) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards assoc iated with performing equiva lent film work and aerial video production \vith conventional fixed-wing aircraft. rotorcraft. or other methods. 

### X
. C O NCLUSION Class A's Peti tion for E.'<emption satisfies the criteria articulated in Section 

### 333 ofthe Refonn Act of2012 which includes weight: speed; operat: ng capabilities: proximity to airports and populated areas; operation \\ithin VLOS and national security. The proposed ClassA-UAS operations 

### will benefit the public as a whole by improving safety and reducing risk by alleviating 22 See e.g., Grant ofExemption No. 11178 to Picture Facto!)', Inc. (FAA -20 14-0794 at 18).U.S Depanmem ofTransportation December 31, 20IS Page22 human exposure to danger while lowering the anendant related costs thereby increasing the demand for the fmished product. In consideration of

### the foregoing. this Petition for Exemption pro,idcs the FAA \\ith more 

### than adequate justification for granting the requested exemptions aliO\\ing Class A 10 use small ClassA

- UAS sin the recorded production ofits product. We thank you for your prompt consideration ofour requested exemptions. Respectfully Submitted, 

# ,d /

# a:rCiass A Roofing Consultants 6020 SE 34111 A\e. Ponland. OR 97202 Phone: 503.896.7727: Email: jeremytunney @; gmail.com (The following anached items contain proprietary and commercial information exempt from disclosure under the Freedom of Information Act, 

### 5 U.S.C. 

### § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. 

### § J1.3S(b)). Auachmems: 

### I. General Operat ions Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Depaning Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist I0. Equipment Checklist II. UAS Manufacturer ' s Manuals a. User Manuals b. UAS Maintenance Manuals


### PETITIONER REQUESTS THAT GOOD C AUSE EXISTS TO EXE MPT ANY PART OF T HI S PETITION FROM BEING PUBLI SHED IN THE FEDERAL REGI STER PUBLI C FORUM BEC AU S E THE REQ UESTED

**EXE~ION** 

### WOULD NOT SET A PRECEDENT, AND ANY DELAY IN ACTI NG ON TIDS PETITIO N WO ULD BE DETRIMENTAL TO THE PETITIO N ER.