TR4 

November 20, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe 

Federal Aviation Regulations from: 14 CFR 61.113 (a) and (b); 91. 7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and 

(b). 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the 

"Reform Act") and 14 C.P.R. Part 11, R4, Inc. ("R4"), seeks an exemption from Federal 

Aviation Regulations ("PARs") to allow the commercial use of its UAS's for the purpose 

of: 

Research & Development (R&D) 

R4 seeks the following exemptions to conduct research and development at R4 

facilities and properties, as well as properties owned by third parties where R4 has 

obtained express written consent for the operation. The primary focus ofR4's R&D 

efforts is to evaluate how to best incorporate UASs into R4's remote-sensing (data 

collection) research, modeling, simulation and integration business operations. 

Training 

R4 will conduct initial flight & sensor training, currency training, and 

maintenance test flights at these areas. These flights form a key part of R4's safety 

strategy to ensure the highest level of flight crew competency as well as establishing 

the airworthiness of the UAS after any repair or overhaul. 

Demonstrations 

In addition, R4's request for exemption focuses on the commercial demonstration 

& application of its sensors on unmanned aircraft to First Responders and emergency 

service customers. 

On or about January 31, 2015 the FAA granted Exemption No. 11158 to Team 5, 

LLC which uses the same UAS as R4, the DJI S 1000 (S 1 000) although for different 

purposes. The S 1000 is a stable lightweight battery operated octocopter. 

R4Incorporated 
'R4 

By approving these exemptions, the FAA will allow a safe and risk adverse way to 

collect data without sending persons into potentially high-risk areas to collect 

measurements and/or using a manned aircraft which carries a much larger risk of injury 

and damage to persons and structures. 

We are prepared to modify or amend any part of this request to satisfy the need 

for an equivalent level of safety. We look forward to working with your office. Please 

contact us at ( 41 0) 670-9339 or via email pryan@r4-inc.com at any time if you require 

additional information or clarification. 

Thank you, 

Is/ Patrick Ryan 

Patrick Ryan 

Director of Operations 

R4 Incorporated 

2204 Lakeside Blvd- Unit A 

Edgewood, MD 21 040 

Direct Phone: (202) 4 70-6086 

Main Phone: ( 41 0) 670-9339 

Email: pryan@r4-inc.com 

R4 Incorporated 
BASIS FOR PETITION 

I. Unmanned Aircraft System (UAS) 

The S 1000 has already been approved by the FAA to be used in aerial photography in 

exemption No. 11158. R4 intends to use multiple S1000s in a similar manner, but for different 

purposes. 

The S 1000 is an octocopter with retractable landing gear. The aircraft is designed to be 

stable even with the loss of a rotor. The S 1000 has a maximum thrust of 2.5kg. It weighs 

approximately 9.7 pounds and has a maximum takeoff weight is approximately 24 lbs. The 

S 1 000 uses a 6S LiPo battery that allows flight times in excess of 25 minutes. The S I 000 has a 

maximum speed of 45 mph. It can hover and simultaneously move vertically and horizontally. 

The S 1000 can operate in temperatures between -10 C to plus 40 C. The propeller is made out of 

high strength performance engineered plastics and is approximately 15 X5.2 inches. The S1000 

is not water-proof and is prohibited from flying in the rain and snow. 

Further, the S 1000 is programmed to return to its launch site in the event of either 

communications failure, loss ofthe Global Positioning System (GPS), or low battery. 

II. Crew Qualifications 

Each operation will be crewed with a minimum of a PIC and Observer. Required training 

and qualifications are outlined in R4's Flight Operations & Safety Manual (FOSM) and include: 

PIC: 
• The PIC will possess at least a private airman certificate and at least a third class 

medical certificate. 

• The PIC will be proficient in flying the S 1000 and have a minimum 15 hours flying a 

UAS, ofwhich at least 5 hours will be in the S1000 flying in a manner consistent with 

how the S 1 000 will be operated under this exemption. 

Observer: 

• The Observer is required to complete training as outlined in the FOSM. 

III. Operations of the Unmanned Aircraft (UA) 

R4 has both a Flight Operations & Safety Manual (FOSM) and an internal S 1000 

Operations Handbook which is intended to provide an equivalent or higher level of safety for 

flight operations for the FAR's which R4 seeks exemption. R4 will provide a hard or electronic 

copy to each Pilot and Observer. The Pilot in Command ("PIC") will ensure that each flight is in 

compliance with the FOSM, R4 S 1000 Operations Handbook, and the DJI S 1000 Operations 

Manual ("Operations Manual", which is electronically available at 

http://www.dji.com/product/spreading-wings-s1000-plus/download), applicable FAR's and any 

conditions or limitations specified in grant of Exemption. 

As set forth in the FOSM, some requirements, limitations and conditions include: 

• Minimum crew for each operation will consist of a PIC and the Observer. The PIC may 

deem other crew essential to the safe operation of the aircraft to include: a sensor operator, 

instructor, trainee, or other persons necessary for the safe operation of the flight. 

• The PIC and Observer will be able to communicate verbally at all times. 

• Flights will only be conducted during daylight hours. 

• Visibility will be adequate to ensure that the PIC and/or Observer can maintain visual 

contact with the aircraft at all times and ensure that the aircraft will remain clear of 

obstructions and people. 

• The aircraft will remain clear of clouds at all times. 

• Flights will be operated within the line of sight of the PIC and/or Observer. 

• Flights will not go beyond % statute miles from point of intended landing. 

• Flights will be terminated at or before 25% battery power reserve. 

• Flights will not be conducted at speeds greater than 25 mph. 
• Flights will operate at an altitude of no more than 400 feet AGL. 

• Flights will remain in Class G airspace. 

• Flights will not operate within 5 nautical miles of an airport or heliport unless a letter of 

agreement with the airport's management is obtained. 

• Flights that fly over private or controlled-access property will be conducted with 

landowner' sf controller's permission. 

• Flights will not be operated over densely populated areas. 

• The PIC will ensure that an adequate preflight inspection of the aircraft has been completed 

in accordance with the Operations Manual and the FOSM. 

• The PIC will conduct a briefing before each flight with the Observer and any other essential 

crew as to the plan for the flight including: flight area, weather, potential obstacles and 

hazards, flight time, battery time and any other information affecting the safety of flight. 

IV. FAR Relief Requested and Equivalent Level of Safety 

61.113 (a) & (b) Private pilot privileges and limitations 

91 .7 (a) Civil aircraft airworthiness 

91 .119 (c) Minimum safe altitudes 

91.121 Altimeter settings 

91.151 (a)(l) Fuel requirements for flight in VFR conditions 

91.405 (a) Maintenance required 

91.407 (a)(l)Operation after maintenance, preventive maintenance, rebuilding, or alteration 

91.409 (a)(l) and (2) Inspections 

91.417 (a) and (b) Maintenance records 

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command 

Sections 61.113 (a) and (b) limits private pilots to non-commercial operations. 

Because the aircraft will not carry pilots or passengers and is limited in the type of 

operation and the area of operation, a private pilot can achieve the equivalent level of safety for 

the proposed operations as a commercial pilot. First, unlike a conventional manned aircraft, the 

aircraft is remotely controlled by a ground-based pilot operator in a controlled and restricted 
area. Second, the aircraft is much smaller than a manned aircraft that the level of risk associated 

with its' operation is diminished from the level of risk associated with commercial operations 

contemplated by part 61. 

Therefore, allowing aircraft use by a private pilot as the PIC meets or exceeds the present 

level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. §91.7(a) Civil Aircraft Airworthiness 

Section 91.7(a) requires a civil aircraft to be in an airworthy condition for operation, 

which accordingly includes an airworthiness certificate in accordance with 14 CFR part 21, 

Subpart H. 

To maintain an equivalent level of safety, the PIC will ensure that the aircraft is in 

compliance with the Operating Manual and FOSM prior to each flight. Additionally, the Pilot 

will still comply with 91.7(b) and ensure that the aircraft is in condition for a safe flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 (c) establishes safe altitudes for operation of civil aircraft over other than 

congested areas. 

R4 requests authority to operate at altitudes only up to 400 AGL over uncongested areas. 

The aircraft will operate in a limited area within pre-defined boundaries with the consent of the 

landowner/controller and require that all non-essential persons remain clear of the flight area 

during operations. The PIC will make a safety assessment of the risk of operating the aircraft and 

ensure no undue hazard is present for persons or property. Compared to flight operations for 

manned aircraft and the lack of flammable fuel , any risk associated with the proposed aircraft 

operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the 

low-altitude operations of the aircraft will ensure separation with conventional aircraft. 

Considering the size, weight and speed of the aircraft, these protections will ensure the 

equivalent level of safety of minimum safe altitudes. 

14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 requires 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." 

The S 1000 does not have a barometric altimeter, but instead uses GPS altitude data. 

R4 establishes an equivalent level of safety by requiring the Pilot to confirm that the GPS 

altitude is set to zero before every flight. 
14 C.F.R. §91.151(a)(1): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a)(1) requires all day VFR flights to operate with enough fuel to fly to 

first point of intended landing and then for at least an additional thirty minutes. 

The battery powering R4's aircraft provides approximately 25 minutes of powered flight 

and therefore is unable to meet this requirement. However, in accordance with the FOSM, flights 

will not go beyond % mile of the intended landing point and will remain in line of sight at all 

times. The S 1 000 has a low battery function that automatically sends the aircraft back to its 

departure point and a critical battery function which automatically lands the aircraft. 

An equivalent level of safety can be achieved by flight planning all flights to return to 

intended landing site with a minimum of 25% reserve power in accordance with the FOSM. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a)(1) & (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner shall "have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to R4 operations. Maintenance will be accomplished by 

R4 in accordance with the Operations Manual and FOSM. The PIC will ensure that the aircraft is 

in working order prior to flight and will perform so maintenance and inspection of the aircraft 

and "be authorized to approve the aircraft for return to service." Additionally, the PIC will 

conduct detailed inspections of the aircraft after every 10 hours of flight. Maintenance performed 

by the PIC is limited to repairing small cracks, replacing propeller, and updating software and 

firmware. All other maintenance will be performed by the manufacturer. R4 will keep a log of 

maintenance performed. Moreover, R4 and the PIC are most familiar with the aircraft and best 

suited to maintain it in an airworthy condition. 

An equivalent level of safety will be achieved because the S 1000 is limited in size, will 

carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise, the aircraft can land immediately and will be operating from no higher 

than 400 feet AGL. 

IV. Privacy 

There is little concern that the proposed flights will cause invasions of privacy because 

flights will occur over private or controlled access property with the land owner's prior consent 

and knowledge. In addition, as the overflight areas will be rural, there is little to no chance that 

there will be inhabited houses in the visual area or other people who have not consented to being 

filmed or otherwise agreed to be in the area where filming will take place. 
V. Public Interest 

Use ofthe SIOOO aircraft is in the public interest because it is safer for people and 

structures. First, risk to the flight crew is virtually eliminated by using an unmanned aircraft. 

Second, by flying a small aircraft weighing less than 25lbs and carrying no fuel, risk to the 

persons and structures on the ground is greatly reduced. Finally, use ofthe S1000 benefits the 

public because it is better for the environment through reduction in noise and environmental 

pollution. 

VI. Summary for Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register: 

R4, Inc. seeks an exemption from the following rules: CFR 61.113 (a) and (b); 91.7(a), 

91.9, 91.109, 91.119(c), 91.121, 91.151(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 

91.417(a) to commercially operate a small unmanned vehicle for aerial mapping and quantitative 

volume analysis. 

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations of UASs for aerial remote sensing will enhance safety by reducing risk. 

Conventional data-collecting and quantitative volume analysis using manned aircraft present 

avoidable risks to flight crew and persons and structures on the ground because the aircraft is 

flying at low altitudes with large amounts of fuel. In contrast, a UAS weighing less than 25 lbs 

and powered by batteries eliminates virtually all of that risk given the small size and lack of 

combustible fuel. Environmental risks are also eliminated by using an aircraft that does not have 

emissions. Therefore, by using a UAS for the purposes outlined by R4, the risk to persons and 

structures will be significantly reduced. 

VII. Conclusion 

R4 requests a grant of exemption from the aforementioned FAR's. The exemption is in 

the public interest because it will increase safety for persons and structures and R4 will provide 

an equivalent or greater level of safety as provided for in the FAR's. If the exemption is granted, 

R4 can competently operate the aircraft in a safe manner. 

VIII. Attachments 

The following attachments are proprietary and commercial information. In support of this 

petition and in-accordance with filing instructions, the following documents were sent to 

333exemptions@faa.gov): 

Attachment A: R4 Aviation Operations & Safety Manual 

Attachment B: R4 DJI SlOOO Operations Manual