Long Range RC

19733 State Route 278 S.W. Nelsonville, Ohio 45764 740

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- 2610 Jason@longrangerc.com www.longrangerc.com August 7, 2015 US Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590 RE: Exemption Request under Section 333 of the FAA Modernization and reform Act of 2012 and C.F.R. Part 11 Dear Sir or Madam, Long Range RC, (LRRC) requests exemption from several prov isions of the Federal Aviation Regulations (FAR) in accordance with section 333 of the FAA Modernization and Reform Act of 2012. LRRC seeks and is asking for exemption in order to commercially operate small unmanned aerial vehicles (UAVs) / small unmanned aerial systems (UAS) weighing less than 55lbs for the purpose of: . Search and rescue . Aerial photography . Aerial videography . Inspections All of Long Range RC’s Pilots in Command (PICs) will have attended a sport pilot course or higher and all carry a Third Class Medical Certificate or possess a valid driver’s license. All of LRRC’s PIC’s and Visual Observers ( VO’s) undergo rigorous training and continued education for the specific aircraft for which they will pilot/ operate/ or observe. Following LRRC policy, all PIC’s must maintain a detailed flight log and that flight log information will be on file with LRRC. All Information record ed by the PIC will be filed with Senior Management weekly for approval filing. Any incidents out of normal operation wil l also be immediately filed before the end of the day on which the incident took place. The name and address of this petitioner is: Long Range RC Attn: Jason A. Gadrim 19733 State Route 278 S.W. Nelsonville, Ohio 45764To preserve the safety of all man ned aircraft operations, the NAS, and property, LRRC will maintain

the following limitations and conditions during all flight operations : 1. All UAVs operated by LRRC under the requested Section 333 exemption will weigh less than 55 pounds. 2. All UAVs operated by LRRC under the requested Section 333 exemption will have an on

- board GPS positioning system, preprogrammed with an altitude ceiling of 385 feet and a maximum lateral distance of 2,600 feet and these parameters will be programed into each units flight co mputer prior to flight. 3. All flights will be conducted within visual line of sight by the pilot in command and the VO. 4. All flights will be conducted with a limitation on the minimum voltage allowed in the primary flight battery. a. Preprogrammed voltage limita tions are built into each aircraft, allowing first for a visual warning to the PIC and VO, and a second for the autonomous landing of the aircraft. b. If the aircraft is autonomously traveling home at its’ return home altitude and a hazard appears the PIC can flip a switch and avoid such hazard and land the aircraft without incident. 5. At all times during the flight, the active PIC and VO will be able to communicate verbally. 6. All flights will be conducted in visual flight rules (VFR) conditions. 7. All flights will be conducted in daylight; LRRC has a strict “No Night Flight” policy for all aircraft. LRRC requests the following exemptions under Section 333: Part 21 Subpart H Airworthiness Certification 14 C.F.R. /45.23(b) Markings 14 C.F.R. /61.113(a) and (b) P rivate Pilot Privileges 14 C.F.R. /61.133(a) Commercial Pilot Privileges 14 C.F.R /91.7(a) and (b) Civil Aircraft Airworthiness 14 C.F.R. /91.119 Minimum Safe Altitudes 14 C.F.R. /91.121 Altimeter Settings 14 C.F.R. /91.151(a) Fuel Requirements fo r Flights in VFR conditions 14 C.F.R. /91.203(a)(1) and (2) Civil Aircraft Certifications 14 C.F.R. /91.405; 407; 409; 417 Maintenance Inspections Part 21 Subpart H: Airworthiness Certification Part 21 Subpart H prescribes procedural requirements for th e issue of airworthiness certificates. LRRC requests exemption from this Subpart to operate small UAVs (less than 55 pounds) without the requirement for an airworthiness certificate. Based on the proposed small UAVs being limited in size, weight, speed, op erating capabilities, and operating within visual line of sight, LRRC believes that an airworthiness certificate is not necessary to ensure an equivalent level of safety to manned aircraft operations.14 C.F.R. / 45.23(b): Display of marks; general

As the proposed small UAVs do not have any entrances to a cockpit of cabin, LRRC requests that in order to identify the aircraft as an experimental type, the word “EXPERIMENTAL” will be displayed in 1⁄2 inch lettering on the fuselage of each aircraft. 14 C.F.R. / 61.113(a) and (b) : Private Pilot Privileges and Limitations: Pilot in Command LRRC requests exemption from 14 C.F.R. / 61.113(a) and (b) to allow LRRC to commercially operate small UAVs with operators holding a private pilot certificate. Section 61.113(a) and (b) limit private pilots to non - commercial operations . However, provided recent documentation, it has been determined that private pilot and commercial pilot certificates meet the same basic knowledge of airspace through ground school and not flight t raining (See Regulatory Docket No. FAA

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- 17). A commercial pilot’s certification ensures that a pilot is able to safely commercially operate a manned aircraft, not a small UAV. Applying manned commercial pilot certification requirements does not significantly add to the safety of UAS operations. LRRC’s operating procedures will ensure our Pilots and VOs are trained to conduct operations with an equivalent level of safety to the training advantages obtained by a commercial pilot certificat ion for manned aircraft. 14 C.F.R. / 91.7(a) and (b): Civil Aircraft Airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificates issued for small UAVs, should this exemption be granted, no FAA regulatory standard will exist for airworthiness. Given the small size of our aircraft (weighing less than 55 pounds) and the aforementioned description of flight operations, an equivalent level of safety will be provided. 14 C.F.R. / 91.119 : Minimum Safe Altitudes LRRC request exemption from the minimum safe altitude requirements of 14 C.F.R. / 91.119 that states the minimum safe altitudes under which aircraft may operate:
1. Over any congested area of a city, town , or settlement, or over any open air assembly of person s, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 2. Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. To provide the intended operations, our small UAVs will be operated below 385 feet. Additionally the small UAVs will maintain a maximum lateral distance of 150 feet from inhabited structures, buildings and vehicles, and will remain within visual line of site from the PIC and VO at all times. 14 C.F.R. / 91.121: Altimeter SettingsThis regulation requi res that each person operating an aircraft shall maintain the cruising or flight level

of that aircraft, as the case may be, by reference to “the current reported altimeter settings of a station along the route within 100 nautical miles of the aircraft.”
L RRC requests exemption from this section because our small UAVs do not have barometric altimeters on - board, but rather a GPS

- based altitude readout system. All aircraft will be programmed to remain below 385 feet regardless of the input of the PIC, thus en suring operation at safe altitudes. 14 C.F.R. / 91.203(a)(1) and (2): Civil aircraft: Certification Required Under the requested exemption, LRRC would not be operating aircraft with an airworthiness certificate as requested under the exemption for Part 21 Subpart H. The exemption for this section is required as LRRC would not be able to display the airworthiness certificate in accordance with 14 C.F.R. / 91.203(a)(1) and (2). 14 C.F.R. / 91.405; 91.407; 91.409; 91.417: Maintenance / Operation / Inspections / Records These regulations specify maintenance and inspections standards in reference to 14 C.F.R. Part 43. 14 C.F.R. 91.405(a) (stating that each owner or operator of an aircraft “shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections. Have discrepancies repaired as prescribed in Part 43 of this chapter”). LRRC requests exemption from these sections as these sections require the aircraft be inspected in accordance with Part 43 and is needed as thes e sections apply only to aircraft with an airworthiness certificate. An equivalent level of safety will be achieved by the PIC following standard maintenance procedures, per the aircraft manufacturers Guidelines and equipment manuals and all maintenance an d repair. Additionally, the PIC will ensure the aircraft is in working order prior to each flight. The PIC will use a check list prior to each flight session and range test the unit as per the control units owner’s manual to ensure safe link is established from the control unit to the UAV. If the UAS fails the Range Test the unit will be taken out of service and checked. Any repairs and observation as to the link failure will be logged in the PICs flight logged. Why is this exemption request in the public’s best interest? By granting this exemption request, LRRC will be able to safely commercially operate our small UAVs in the NAS allowing for aerial photography, aerial videography, inspections, and most importantly help to possible help find a lost person l ooking for help. The safe and utilization of this new technology allows us to minimize the risk placed on human life, not only potentially saving a life, but freeing up valuable time and human resources to be used to further help others. LRRC feels these e xemptions play a huge part of the early adoption of small UAS into the NAS. It is the review processes like these that allow those of us operating responsibly and safely to use this technology to protect people, protect property, and help to improve countl ess industries and lives.