# T R4

November 20, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 

### Re:ExemptionRequest Under Section 333 oftheFAAReformActandPart 11 ofthe FederalAviationRegulations 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), and91.417(a) and (b). Dear Sir orMadam: 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 allowthe commercial use ofits 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 & sensortraining, currency training, and maintenance test flights atthese areas. These flights form a key part ofR4's safety strategy to ensure the highest level offlight crew competency as well as establishing the airworthiness ofthe UAS after any repair oroverhaul. 

### Demonstrations In addition, R4's request for exemption focuses on the commercial demonstration & application ofits sensors on unmanned aircraft to First Responders and emergency service customers. On or about January 31, 2015 the FAA granted ExemptionNo. 11158 to Team 5, LLC which uses the same UAS as R4, the DJI S1000 (S 1 000) although for different purposes. The S1000 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 datawithout sendingpersons into potentially high-risk areas to collect measurements and/or using a manned aircraft which carries a much larger risk ofinjury and damage to persons and structures. We are prepared to modify oramend any part ofthis request to satisfy the need for an equivalent level ofsafety. We look forward to working with your office. Please contactus at (410) 670-9339 orvia email pryan@r4-inc.com at any time ifyou require additional information or clarification. Thank you, Is/PatrickRyan Patrick Ryan Director ofOperations R4 Incorporated 2204 Lakeside Blvd- Unit A Edgewood, MD 21040 Direct Phone: (202) 470-6086 Main Phone: (410) 670-9339 Email: pryan@r4-inc.com

R4 Incorporated

### BASIS FORPETITION

I. Unmanned AircraftSystem (UAS) The S1000 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 S1000 is an octocopter with retractable landing gear. The aircraft is designed to be stable even with the loss ofa rotor. The S1000 has a maximum thrust of2.5kg. It weighs approximately 9.7 pounds and has a maximum takeoffweight is approximately 24 lbs. The S1 000 uses a 6S LiPo battery that allows flight times in excess of25 minutes. The SI000 has a maximum speed of45 mph. It can hover and simultaneously move vertically and horizontally. The S1000 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-proofand is prohibited from flying in the rain and snow. Further, the S1000 is programmed to return to its launch site in the event ofeither communications failure, loss ofthe Global Positioning System (GPS), or low battery.



### II. Crew Qualifications Each operation will be crewed with a minimum ofa PIC and Observer. Required training and qualifications are outlined in R4's Flight Operations & SafetyManual (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 S1000 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 howthe S 1 000 will be operated underthis exemption. Observer:

• The Observer is required to completetraining as outlined in the FOSM. III. Operations oftheUnmannedAircraft (UA) R4 has both a Flight Operations & Safety Manual (FOSM) and an internal S1000 Operations Handbookwhich is intended to provide an equivalent orhigher level ofsafety for flight operations for the FAR'swhich R4 seeks exemption. R4 will provide a hard orelectronic copy to each Pilot and Observer. The Pilot in Command ("PIC") will ensure that each flight is in compliance with the FOSM, R4 S1000 Operations Handbook, and the DJI S1000 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 orlimitations specified in grant ofExemption. As set forth in the FOSM, some requirements, limitations and conditions include:
• Minimum crewfor each operation will consist ofa PIC and the Observer. The PIC may deem other crew essential to the safe operation ofthe aircraft to include: a sensor operator, instructor, trainee, orotherpersons necessary for the safe operation ofthe flight.
• The PIC and Observer will be able to communicate verbally at all times.
• Flights will onlybe conducted during daylighthours.
• Visibility will be adequate to ensure thatthe PIC and/or Observer can maintain visual contactwith the aircraft at all times and ensure thatthe aircraft will remain clear of obstructions and people.
• The aircraft will remain clear ofclouds at all times.
• Flights will be operated within the line ofsight ofthe PIC and/or Observer.
•Flights will not go beyond % statute miles from point ofintended landing.
• Flights will be terminated at orbefore 25%batterypowerreserve.
•Flights will notbe conducted at speeds greaterthan 25 mph.• Flights will operate at an altitude ofno more than 400 feet AGL.
• Flights will remain in Class G airspace.
• Flights will not operate within 5nautical miles ofan airport orheliport unless a letter of agreement with the airport's management is obtained.
• Flights thatfly overprivate orcontrolled-access property will be conducted with landowner'sf controller'spermission.
• Flights will notbe operated over denselypopulated areas.
• The PIC will ensure that an adequate preflight inspection ofthe aircraft has been completed in accordance with the Operations Manual and the FOSM.
•ThePIC will conduct a briefingbefore each flight with the Observer and any otheressential 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 offlight. IV. 

### FARReliefRequested and EquivalentLevel ofSafety 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): PrivatePilotPrivileges and Limitations: Pilot in Command Sections 61.113 (a) and (b) limits privatepilots to non-commercial operations. Because the aircraft will not carry pilots or passengers and is limited in the type of operation and the area ofoperation, aprivatepilot can achieve the equivalent level ofsafety 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 restrictedarea. Second, the aircraft is much smallerthan a manned aircraft that the level ofrisk associated with its' operation is diminished from the level ofrisk associated with commercial operations contemplated by part 61. Therefore, allowing aircraftuse by a private pilot as the PIC meets or exceeds the present level ofsafety sought by 14 C.F.R. §61.113 (a) and (b). 

### 14 C.F.R. §91.7(a) Civil AircraftAirworthiness 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 CFRpart 21, Subpart H. To maintain an equivalent level ofsafety, the PIC will ensure that the aircraft is in compliance with the OperatingManual and FOSM priorto 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 SafeAltitudes Section 91.119 (c) establishes safe altitudes for operation ofcivil 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 areawithin pre-defined boundaries with the consent ofthe landowner/controller and require that all non-essential persons remain clear ofthe flight area during operations. The PIC will make a safety assessment ofthe risk ofoperatingthe aircraft and ensure no undue hazard is present for persons orproperty. Compared to flight operations for manned aircraft and the lack offlammable fuel, any risk associated with the proposed aircraft operations is far less than conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations ofthe aircraft will ensure separation with conventional aircraft. Consideringthe size, weight and speed ofthe aircraft, these protections will ensure the equivalent level ofsafety ofminimum safe altitudes. 

### 14 C.F.R. §91.121 Altimeter Settings Section 91.121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "to the elevation ofthe departure airport oran appropriate altimeter setting available before departure." The S1000 does not have a barometric altimeter, but instead uses GPS altitude data. R4 establishes an equivalent level ofsafety by requiringthe Pilot to confirm that the GPS altitude is setto zero before every flight.14 

### C.F.R. §91.151(a)(1): Fuel Requirements for Flightin VFRConditions Section 91.151(a)(1) requires all day VFR flights to operate with enough fuel to fly to first point ofintended landing and then for at least an additional thirty minutes. The batterypowering R4's aircraft provides approximately 25 minutes ofpowered flight and therefore is unable to meetthis requirement. However, in accordance with the FOSM, flights will not go beyond % mile ofthe intended landing point and will remain in line ofsight at all times. The S 1 000 has a lowbattery function thatautomatically sends the aircraft backto its departure point and a critical battery function which automatically lands the aircraft. An equivalent level ofsafety can be achieved by flight planning all flights to return to intended landing site with a minimum of25% reserve power in accordance with the FOSM. 14 

### C.F.R. §91.405 (a); 407 (a) (1); 409 (a)(1) & 

### (2); 417(a) & 

### (b): MaintenanceInspections These regulations require that an aircraft operator or owner shall "havethat aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 of this chapter
...," and others shall inspect ormaintain the aircraft in compliance with Part43. 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 ensurethatthe aircraft is in working orderpriorto flight and will perform so maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." Additionally, the PIC will conduct detailed inspections ofthe aircraft after every 10 hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacingpropeller, 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 ofsafety will be achieved because the S1000 is limited in size, will carry a small payload and operate only in restricted areas for limited periods oftime. 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 ofprivacy because flights will occur overprivate or controlled access property with the land owner'spriorconsent 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 otherpeople who have not consented to being filmed or otherwise agreed to be in the areawhere filming will take place.V. Public Interest Use ofthe SIOOO aircraft is in thepublic interest because it is safer for people and structures. First, riskto 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 environmentthrough reduction in noise and environmental pollution. VI. Summary for Publication Pursuantto 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 ofUASs 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 becausethe aircraft is flying at low altitudes with large amounts offuel. In contrast, a UAS weighing less than 25 lbs and powered by batteries eliminates virtually all ofthatrisk 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 riskto persons and structures will be significantly reduced. VII. Conclusion R4 requests a grant ofexemption 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 ofsafety as provided for in the FAR's. Ifthe exemption is granted, R4 can competently operatethe aircraft in a safe manner. VIII. Attachments The following attachments are proprietary and commercial information. In support ofthis petition and in-accordance with filing instructions, the following documents were sentto 333exemptions@faa.gov): Attachment A: R4 Aviation Operations & SafetyManual Attachment B: R4 DJI SlOOO Operations Manual