Scott Eveld

Aerial Information Technologies

27543 Ethan Allen Way

Menifee,CA 92585
I am seeking relief from the following regulations:

Part 21 prescribes the procedural requirements for issuing and changing

design approvals,

productions approvals, airworthiness certificates, and airworthiness

approvals.

Section 45.23(b) prescribes that 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 provisionally certificated aircraft, the operator must also

display on that

aircraft near 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.

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a 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 command 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.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless

it is in an

airworthy condition.

Section 91.7(b) prescribes that the pilot in command of a civil aircraft is

responsible for

determining whether that aircraft is in condition for safe flight and that the

PIC shall

discontinue the flight when unairworthy mechanical, electrical, or

structural conditions occur.

Section 91.9(b)(2) prohibits operation of U.S.‐registered civil aircraft unless

there is available

in the aircraft a current approved Airplane or Rotorcraft Flight Manual,

approved manual

material, markings, and placards, or any combination thereof.

Section 91.103(b) prescribes that a pilot shall for any flight, become

familiar with runway

lengths at airports of intended use, and takeoff and landing distance

information.

Section 91.109(a) prescribes, in pertinent part, that no person may operate

a civil aircraft

(except a manned free balloon) that is being used for flight instruction

unless that aircraft has
fully functioning dual controls.

Section 91.119 prescribes that, except when necessary for takeoff or

landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency

landing without

undue hazard to persons or property on the surface.

(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.

(c) Over other than congested areas. 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.

(d) Helicopters, powered parachutes, and weight‐shift‐control aircraft. If

the operation is

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in

paragraph

(b) or (c) of this section, provided each person operating the helicopter

complies

with any routes or altitudes specifically prescribed for helicopters by the

FAA; and
(2) A powered parachute or weight‐shift‐control aircraft may be operated at

less than

the minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, each person operating an

aircraft to maintain

cruising altitude by reference to an altimeter that is set “...to the elevation

of the departure

airport or an appropriate altimeter setting available before departure.”

Section 91.151(a) prescribes that 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 cruising

speed, (1) during the

day, to fly after that for at least 30 minutes [emphasis added].

Section 91.203(a) prohibits, in pertinent part, any person from operating a

civil aircraft unless

it has within it (1) an appropriate and current airworthiness certificate; and

(2) an effective

U.S. registration certificate 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).

Section 91.203(b) prescribes, in pertinent part, that no person may operate

a civil aircraft

unless the airworthiness certificate 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.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or

owner shall have that

aircraft inspected as prescribed in subpart E of the same part and shall,

between required

inspections, except as provided in paragraph (c) of the same section, have

discrepancies

repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating

an aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration

unless it has been

approved for return to service by a person authorized under § 43.7 of the

same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may

operate an aircraft

unless, within the preceding 12 calendar months, it has had an inspection

for the issuance of

an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for

the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration

and
records of the 100‐hour, annual, progressive, and other required or

approved

inspections, as appropriate, for each aircraft (including the airframe) and

each

engine, propeller, rotor, and appliance of an aircraft. The records must

include—

(i) A description (or reference to data acceptable to the

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each

propeller, and each rotor.

(ii) The current status of life‐limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time

since the last inspection required by the inspection program under

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the AD

or safety directive number and revision date. If the AD or safety
directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after

the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under

§ 43.11 of this chapter shall be retained until the defects are repaired and

the

aircraft is approved for return to service.

My UAV is a SOLO by 3D robotics

Specs:

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for

HERO3+ and 4

Streaming video quality: 720p
Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self‐tightening (24 cm diameter 144

cm pitch); glass‐reinforced nylon

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor‐to‐motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later
*Flight time varies with payload, wind conditions, elevation,

temperature, humidity, flying style and pilot skill. Listed flight time

applies to elevations less than 2,000 ft above sea level.

**Depending on environmental conditions; controller is expandable,

allowing us or third parties to amp up the range in the future.

Solo Smart Battery:

Rechargeable lithium polymer (Li‐Po)

5200 mAh

14.8 Vdc

Weight: 1 lb. (.5 kg)

Solo Gimbal:

Three‐axis stabilization

Fully compatible with 3DR Solo and GoPro HERO3+ and HERO4; camera

charging and stabilization only with HERO3

HDMI video output

Wireless software upgrade through Solo

Controllable range: 0° to ‐90° pitch
I am wanting to use this UAV for the purpose of collecting data for mapping

and GIS applications, as well as remote sensing. The SOLO is fitted with a

gyro stabilized gimbal that will accept a gopro camera. Flight times are

limited to no longer than 20 minutes and at an altitude of no more than 400

feet. Because of the precision, of the maps, we hope to achieve, our flights

are usually less than 200 feet. We will never exceed 400 feet. There may

be times that we will need to be closer than the 5 mile radius of an airport,

if the need arises, we would first check with the airport, and apprise them

of our intent and accommodate them in anyway necessary.

I have more than 50 hours UAV flight time and 16 hours course study of

UAV safety, theory, and maintenance and I have been certified through UVU

(Unmanned Vehicle University). I realize that there is no officially

recognized training for UAV’s in the United States at this time, however, I

feel that the training that I received from UVU was invaluable. I have 25

years experience as a land survey professional, as well as an OSHA 30 Safety

certificate.

This UAV would be used to fly in areas that conventional aircraft cannot

fly. We use the information to turn out maps that have more, and better

information than is possible through traditional means. I would be the PIC

and always have a spotter with me that would also have the ability to

initiate the auto land or return to launch sequence(RTL). The Solo has a

standard flight mode, GPS assisted mode, and an autonomous flight mode.

During autonomous flight, corrections can be given directly to the UAV for

course change (altitude or directional) as well as loiter, auto land and RTL.

All flights for the collection of data will be done through the autonomous

mode. If communication is lost with the UAV it will stop and loiter in

position for one minute while trying to reacquire communication. If it is

unable to establish communication it will RTL and land. GPS is also required

for autonomous flight, if the gps signal is lost , the UAV will loiter in position

and try to establish a GPS signal. If a GPS signal can not be acquired, it will

land at that position. If the GPS signal is lost the UAV can also be controlled

safely through the RC controller.
The SOLO is powered by a 5200MaH battery, there would be no chance of

fuel spillage, and reduces the chance of igniting fires.

All safety and maintenance is always strictly adhered to following

guidelines that will be included in this application.

Copter Safety

Copters can be hazardous if operated incorrectly. We always make safety

our first priority, and always follow these best practices.
Handling

Spinning propellers can cause serious injury. Become familiar with your

copter’s arming procedure, and always disarm before handling the

propellers. On 3DR RTF and other Pixhawk‐powered vehicles, the safety

button provides an additional safety measure by blocking power to the

motors while the button is disabled (blinking red), allowing you to handle

the copter safely.

When flying, always make sure to keep a safe distance between yourself

and the copter. Don’t take off with the copter facing towards you or fly

directly over your head. It is your job to ensure

the safety of the people around you; make sure that spectators maintain a

safe distance from your copter at all times.
Visual line of sight

Maintaining visual contact with your aircraft is the best assurance of a safe

flight. Don’t let the copter get too far away from you; keep it where you

can easily see its orientation from the ground. This is called your visual line

of sight and prevents a situation where you cannot recover the copter

safely.

Flying within visual line of sight is also a good way to ensure that your radio

signals (from the RC and telemetry radio systems) aren’t blocked by

buildings or other obstructions. If you can’t see through it, it’s likely that

your radio signal can’t either.
Under 400 feet

Keep your copter flying below 400 feet (120 meters) altitude to avoid

conflict with full‐scale, manned aircraft and maintain visual line of sight. To

give you an idea of how high that is, the Statue of Liberty is 300 feet (93

meters) tall.

At least 100 feet from people, vehicles, and property
Always maintain at least 100 feet (30 meters) between your copter and

people, vehicles, and buildings. This rule is important for flying near

crowds, buildings, and roads due to potential hazards from unplanned

landings.

At least 5 miles from airports

To prevent conflict between your copter and manned aircraft, always fly at

least five miles (eight kilometers) away from all airports and other locations

where manned aircraft are in use. Research your area to find all areas of

restricted airspace near you.

Failsafes
A failsafe is a pre‐programmed behavior designed to prevent a crash in the

event of an unsafe situation. All ArduCopter vehicles include a GPS failsafe

activated by default. 3DR RTF copters are also pre‐set with radio control

(RC) and low battery failsafe behaviors.

Loss of GPS signal

If the copter loses GPS signal in a flight mode that requires GPS (loiter,

auto, return‐to‐launch, guided), it will land automatically, indicated by a

blinking blue and yellow status LED and a high‐high‐high‐low tone. Always

fly outside in an open area to improve GPS signal strength.

Loss of RC signal

If the copter looses contact with the RC transmitter, it will land

automatically, indicated by a blinking yellow status LED. If it looses RC

signal during a mission, it will return to the launch point before landing.
Low battery

If the battery reaches 25% charge, the copter will land automatically,

indicated by a blinking yellow status LED and a quick repeating tone. If the

battery runs low during a mission, the copter will return to the launch point

before landing.

Common sense

Your common sense is the best failsafe. Always be ready to regain manual

control of the copter in the event of an unsafe situation. Before you fly,

determine the boundaries of your safe flying area. If the copter moves

outside the designated area or exhibits instability in flight, switch to

stabilize mode and land the copter manually. Remember that, despite

specific regulations, flying recklessly or creating an unsafe situation for the

public is always illegal. As the operator, you take responsibility for the

behavior of your drone at all times.

Personnel Safety
a. Capital assets, such as quarries, dams, pipelines, and bridges often times

span over areas where terrain is unstable, vertical, or simply too dangerous

for foot travel. Field inspections leave employees vulnerable to

environmental hazards such as stream crossing, seasonal water runoff, risk

of falls and blocked paths; biological hazards, such as snakes, and natural

predators; and extreme temperature changes which may cause altitude

sickness, or heat stroke. The utilization of our UAV will ensure access to

these areas while minimizing risk of serious injury or issue to personnel

assigned to conduct these surveys.

2. Access to remote or impassable areas

a. Segments of quarries, dams, pipelines, and bridges may currently be or

become unreachable, partially obscured, or impracticable for inspection by

conventional means, such as physically walking the line, or utilizing airplane

or helicopters for inspections. Access to assets can also be partially or

completely blocked by environmental singularities, such as storm events,

felled trees, or vegetation growth, or blocked by mechanical means such as

vehicle accidents, new construction, or road maintenance. The use of our

UAV will ensure access to remote or impassable areas on an as‐needed basis

as well as during or after uncontrolled singular events.

3. Protection of natural resources
The use of UAV’s along with NIR (near infrared) photography make it

possible to quickly and efficiently monitor the use and possible loss of water

to crops due to oversaturation, thereby increasing efficiency of water use as

well as increasing crop yield.

Thank you for your consideration,

Scott Eveld

Aerial Information Technologies

27534 Ethan Allen Way

Menifee,CA