R&M Aerial Imagery Page 1

**March 16, 2015**

**U. S. Department of Transportation Docket Management System**  **1200 New Jersey Ave., SE Washington, DC 20590** 

**Dear Sir or Madam:**

**Attached please find R&M Aerial Imagery, LLC' s req uest for an exemption from the**  **listed Federal Aviation Regulations to allow commer cial operations of its Small**  **Unmanned aircraft Systems ("sUASs") for aerial imag ery and survey of; real estate,**  **ground structure exteriors, research, development, test and evaluation of sUAS flight**  **operations aerial support within the designated FAA low altitude restrictions for local,**  **state, and federal government agencies.**

**R&M Aerial Imagery, LLC is a veteran owned Virginia corporation. The company has**  **over 30 years aviation flight experience in private and US Navy operations: mission**  **planning, airspace de-confliction and management, a irways navigation, airport takeoff**  **and landing procedures (VFR and IFR), aviation safe ty, research, development, test**  **and evaluation (RDT&E), airframe functional check f lights, aviation accident**  **investigations, scheduling, maintenance, aviation simulation, and standardized**  **training and flight procedures. The two principals of R&M**  **Aerial Imagery have 60 years combined experience in mechanics, electronics, elec**  **tro-mechanical repair, and ground safety. The attached company Operations Manual out**  **lines our safe and standardized operating guidelines for sUAS operations, training,**  **maintenance, and documentations from flight brief to debrief.** 

**Thank you for your time and consideration, and plea se contact us with any questions.** 

**Ronald Stites and Michael Kitchen R&M Aerial Imagery, LLC** 

**March, 9 2015**

**4412 Monmouth Castle Road Virginia Beach, VA 23455**  **Stitesrp@gmail.com MichaelBKitchen@gmail.com** 

**757-408-3648**

**757-292-0553**R&M Aerial Imagery Page 2

**I. RELEVANT STATUTORY AUTHORITY**

**Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the Reform**  **Act), R&M Aerial Imagery, LLC, (the operator); Rona ld Paul Stites and Michael Brent**  **Kitchen (the applicants), planned operators of Smal l Unmanned Aircraft Systems**  **(sUASs) equipped to conduct aerial photography and survey for various industries**  **hereby applies for an exemption from Federal Aviati on Regulations (FARs) to allow**  **commercial operation of their sUASs, so long as suc h operations are conducted within**  **and under the conditions outlined herein or as may be established by the FAA as**  **required by Section 333.**

**As described more fully below, the requested exempt ion would permit the operation of**  **sUAS by the applicants for commercial use that woul d provide the following benefits:** 

**1. Operations would be performed in an area of oper ation limited in size suitable to the**  **specific use, briefed in advance of flight.**

**2. The flight would be planned in advance to minimi ze hazards to persons and property**  **in the air and on the ground.**

**3. The operator would reasonably limit or control a ccess to provide safety to those not**  **involved in the operation.**

**4. Operation of a sUAS would provide significant sa fety, environmental and other**  **enhancements not possible by larger sized aircraft.**

**5. An FAA licensed airman will operate the sUAS.**

**6. Provide a beneficial and currently unavailable s ervice to government organizations**  **and the general public that would serve the public interest.** 

**Approval of this exemption would thereby enhance sa fety and fulfill the Secretary of**  **Transportation's (the FAA Administrators) responsib ilities to "establish requirements for**  **the safe operation of such aircraft systems in the national airspace system." Section**  **333(c) of the Reform Act.**

**It is possible to operate sUASs so to not create a hazard to users of the National**  **Airspace System (NAS), the public or pose a threat to national security if done so safely**  **and responsibly.**

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY **The applicants propose that the exemption requested herein apply to civil aircraft that**  **have the characteristics of sUAS and that operate w ith the limitations listed herein.**  **These limitations provide for at least an equivalen t or higher level of safety to operations**  **under the current regulatory structure as the propo sed operations represent a safety** R&M Aerial Imagery Page 3

**enhancement to the already safe aerial commercial p hotography and survey operations** 

**conducted with conventional aircraft.**

**The sUAS's to be operated are multi-rotorcraft (MR) , each weighing 55 or fewer pounds**  **including payload. They would operate, under normal conditions, at a speed of no more**  **than 50 knots. The principal construction material of these sUAS craft lightweight**  **composites and/or plastic. Operations will be perfo rmed by a qualified sUAS operator**  **(the Pilot in Command, PIC), as outlined below, to insure that the sUAS will "not create**  **a hazard to users of the national airspace system o r the public." Given the small size of**  **the sUASs involved and the pre-planned environment within which they will operate, the**  **applicant believes that these operations fall squar ely within that zone of safety (an**  **equivalent level of safety) in which Congress envis ioned that the FAA must, by**  **exemption, allow commercial operations of sUASs to commence immediately. Our**  **standard sUAS operations (see attached Operations M anual) will prevent any possible**  **national security issues. The operation of sUASs b y knowledgeable professionals with**  **experience in the NAS will serve to enhance safety, add to the public benefit and reduce**  **environmental impacts related to current methods of aerial photography and survey.** 

**II. R&M AERIAL IMAGERY LLC PROPOSED OPERATIONS MEE T THE** 

**REQUIREMENTS OF SECTION 333 OF THE REFORM ACT**

**R&M Aerial Imagery LLC shall abide by FAA regulatio ns when conducting commercial**  **sUAS flight operations. 1. Safety is the first and foremost consideration f**  **or all sUAS commercial and flight training operations.**  **2. The sUAS operator will be an FAA licensed airman (preferably Armed Forces**  **veterans).**

**3. sUAS Observers will assists the sUAS PIC with he lp in spotting and avoiding**  **other air traffic, objects aloft, or ground hazards**

**. 3. All flights will be conducted within line of sig**  **ht of the operator. 4. The sUAS will weigh less than 55 pounds total.**  **5. Flights will be operated in FAA designated sUAS airspace envelopes.**  **6. The relevant airspace controlling agency will be notified as far in advance as**  **practicable. For flights within 5 miles of an airpo rt, the operator will provide the airport**  **operator or the airport air traffic control tower ( if the ATC is co-located at the airport)**  **with prior notice of the operation. 7. All flights will be operated under visual flight**  **rules (VFR). 8. The sUAS will give way to any aircraft carrying**  **people. 9. Minimum crew for each operation will consist of**  **the sUAS PIC and observer. The Observer will monitor safety of flight and will**  **be in voice communication with the**

**PIC. 10. Prior to a sUAS flight, the flight brief and FA**  **A airspace requirements will establish the mission flight envelope. All collisi**  **on hazards will be noted and safety procedures for ground personnel, property and fligh**  **t emergencies will be defined. 11. Flight planning will include flight completion**  **with at least 25 percent (25%) battery power remaining as measured by the sUAS software.** R&M Aerial Imagery Page 4

**12. All sUAS aircraft will utilize GPS navigation, failsafe, return-to-home (RTH)**  **and/or flight abort safety features. 13. All required permissions and permits will be ob**  **tained from applicable private, local, state, and federal governmental agencies.**  **14. Written electronic and/or oral permission from relevant property owners will be**  **obtained prior to an operation. 15. The sUAS pilot will be a FAA licensed airman tr**  **ained in advance for the safe operation of the sUAS to be operated. R&M Aerial Im**  **agery’s training syllabus is outlined in our Operations Manual (attached). This will incl**  **ude operation of the sUAS both in normal and emergency modes of operation, and will i**  **nclude complete familiarization with the sUAS manufacturer operation manual.**  **16. R&M Aerial Imagery representatives will establi sh a working relationship with the**  **local FSDO to annually review safety procedures and other operations to further**  **enhance safety. 17. R&M Aerial Imagery will conduct research, devel**  **opment, test and evaluation of sUAS operations with government agencies and provid**  **e lessons learned to all interested parties.** 

**III. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED**

14 CFR Part21, Subpart H: Airworthiness Certificate s **14 C.F.R. Part 21, Subpart H - Airworthiness Certif icates and 14 C.F.R. §91.203(a)(I)**  **The FAA has stated that no exemption is needed from this section if a finding is made**  **under the Reform Act that the sUAS selected provide s an equivalent level of safety**  **when compared to aircraft normally used for the sam e application. These criteria are**  **met, and therefore no exemption is needed.** See **Grant of Exemption to Astraeus Aerial, Docket No. F AA-2014-0352 at 13-14,22. If, however,**  **the FAA determines that there are**

**some characteristics of the chosen sUAS that fail t o meet the requirements of the**  **Reform Act, an exemption is requested.**

14 CFR 91.203(a) & (b) Civil aircraft: Certificatio ns required. **The regulation provides that an airworthiness certi ficate, with the registration number**  **assigned to the aircraft and a registration certifi cate must be aboard the aircraft.** 

**Subparagraph (b) provides that the airworthiness ce rtificate be "displayed at the cabin**  **or cockpit entrance so that it is legible to passen gers or crew." A sUAS is too small to**  **carry documentation, does not have an entrance, and is not capable of carrying**  **passengers or crew. To obtain an equivalent level o f safety and meet the intent of**  **91.203, we propose that documents deemed appropriat e for this aircraft by the FAA will**  **be co-located with the crew at the ground control s tation and available for inspection**  **upon request. ln order to identify the aircraft, we propose the use of the sUAS' unique**  **manufacturers serial number, and a contact telephon e number be mounted on the**  **sUAS on a placard of reasonable size in relation to the sUAS. ln the event that a unique**  **manufacturers serial number is not available, the p reviously mentioned placard will be**  **affixed to the sUAS consisting of the model name an d number of the sUAS, as well as a**  **contact telephone number.**R&M Aerial Imagery Page 5

A. Equivalent Level of Safety **The sUASs identified in the Operations Manual are s afe when taking into account their**  **size, weight, speed, and operational capability. Al l of the sUASs weigh less than 55**  **pounds and will be flown at less than 30 miles per hour. The sUASs carry neither pilots**  **nor passengers, carry no explosive materials and or flammable liquid fuels, and operate**  **exclusively within the parameters stated in the Ope rations Manual.** 

**For commercial hire, R&M Aerial Imagery will fly th e DJI Inspire 1 with the following**  **model specifications:**

**Weight (Battery Included) 2935 g Hovering Accuracy (GPS mode) Vertical: 0.5 m**  **Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150**  **°/s Max Tilt Angle 35°**  **Max Ascent Speed 5 m/s Max Descent Speed 4 m/s**  **Max Speed 22 m/s (no wind) Max Flight Altitude 4500 m**  **Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes**  **Diagonal Distance 559 to 581 mm**

**Dimensions 438x451x301 mm**

**DJI Remote Controller Operating Frequency 5.725~5.825 GHz 2.400~2.483 G**  **Hz Transmitting Distance (outdoor and unobstructed) 2**  **km**

**If, in the future, R&M Aerial Imagery procures diff erent models of sUAS (Other than DJI**  **Inspire 1) for use in commercial operations, we sha ll provide the FAA with: model name,**  **specifications, controlling frequencies, safety inf ormation, and maintenance plans and** 

**documentation. ,**

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exem ptions from requirements of regulations prescribed pursuant to Sections 4470 1 (a) and (b) and Sections 44702 - 44716).

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: **The reasons why granting the exemption would not ad versely affect safety, or how the**  **exemption would provide a level of safety at least equal to that provided by the rule from**  **which you seek exemption.**

**Operations under this exemption will be closely con trolled and monitored by the**  **operator and will be conducted in compliance with l ocal public safety requirements, to**  **provide security for the area of operation. R&M Aer ial Imagery will provide the FAA with**  **advance notice of all operations via coordination w ith the local FSDO. In all cases, the** R&M Aerial Imagery Page 6

**sUASs operated under the proposed conditions, will be at least as safe as, or safer than**  **conventional rotorcraft operating with an airworthi ness certificate without the restrictions**  **and conditions of the proposed sUAS operations.**

**The aircraft themselves do not need a means to comm unicate with other aircraft or** 

**ATC.** See **Grant of Exemption, Docket FAA-2014-0352 at 13.**

B. 14 C.F.R. Part 27 Airworthiness Standards: Norma l Category Rotorcraft **14 C.F.R. Part 27 sets forth the procedural require ments for airworthiness certification**  **of normal category rotorcraft. To the extent the Pe titioner's sUASs would otherwise**  **require certification under Part 27, Petitioner see ks an exemption from Part 27's** 

**airworthiness standards for the same reasons identi fied in the request for exemption**  **from 14 C.F.R. Part 21, Subpart H,** supra.

C. 14 C.F.R. §§ 91.9(c), 4S.23(b) and 4S.27(a): Air craft Marking and Identification Requirements **Petitioner seeks an exemption from the aircraft mar king and identification requirements**  **contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45. 27(a).** 

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual , Marking and Placard requirements, provides that:

**No person may operate a U.S.-registered civil aircr aft unless that aircraft is identified in**  **accordance with Part 45 of this chapter. 14 C.F.R. § 45.23(b), Markings of the Aircraft, sta**  **tes: When marks include only the Roman capital letter "N**  **" and the registration number is displayed on limited, restricted or light-sport cat**  **egory aircraft or experimental or provisionally certificated aircraft, the operator m**  **ust also display on that aircraft near each entrance to the cabin, cockpit, or pilot stati**  **on, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "rest**  **ricted," "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**  **rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks req**  **uired by § 45.23. In a previous Grant of Exemption, the FAA determined that exemption fro**  **m these requirements was warranted provided that the aircraft "have identifi**  **cation (N-Number) markings in accordance with 14 CFR part 45, Subpart C if the ma**  **rkings are as large as practicable."**

Re **FAA Docket No. FAA-2014-0352.**

Equivalent Level of Safety **R&M Aerial Imagery will mark all aircraft with thei r N-Number in a prominent spot on the**  **fuselage with markings that are as large as practic able.** 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manua l in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certific ation and RegistrationR&M Aerial Imagery Page 7

**Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may operate a U.S.-registered civil a**  **ircraft- (2) For which an Airplane or Rotorcraft Flight Manu**  **al is required by § 21.5 of this chapter, 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. 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: (1) An appropriate and current airworthiness certif**  **icate.(b) No person may operate a**

**civil aircraft unless the airworthiness certificate required by paragraph (a) of this section**  **or a special flight authorization issued under § 91 .715 is displayed at the cabin or**  **cockpit entrance so that it is legible to passenger s or crew.** 

**R&M Aerial Imagery does not request an exemption fr om this section but instead**  **notifies the FAA that, in accordance with FAA Offic e of Chief Counsel's Opinion dated**  **August 8, 2014, the sUAS flight manual, registratio n certificate and other documentation**  **will be kept at the control station with the PIC du ring flight. The Chief Counsel's Office**  **has held that for all sUAS operations, this alterna te method constitutes full compliance**  **with the regulations.**

**E.** 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness **Petitioner seeks an exemption from 14 C.F.R. § 91.7 (a), which requires that a civil**  **aircraft be in airworthy condition to be operated. The FAA has stated that no exemption**  **is required to the extent that the requirements of Part 21 are waived or found**  **inapplicable. Accordingly, Petitioner requests tha t the requirements for Section 91.7 be**  **treated in accordance with Section III (A),** supra.

F. 14 C.F.R. § 91.103: Preflight Action **Petitioner seeks an exemption from 14 C.F.R. § 91.1 03, which requires a PIC to**  **become familiar with specific information before ea ch flight, including information**  **contained in the FAA-approved Flight Manual on boar d the aircraft. While the PIC will**  **be familiar with all information necessary to safel y conduct the flight, an exemption is**  **requested to the extent that an FAA-approved Flight manual is required.** 

Equivalent Level of Safety **An equivalent level of safety will be provided by f ollowing the company Operations**  **Manual and flight manual provided by the manufactur er. The PIC will take all required**  **preflight actions - including performing all requir ed checklists and reviewing weather,**  **flight requirements, battery charge, landing and ta keoff distance, aircraft performance**  **data, and contingency landing areas - before initia tion of flight. The Operations Manual**  **and manufacturer's flight manual will be kept at th e ground station with the operator at** 

**all times.**R&M Aerial Imagery Page 8

G. 14 C.F.R. § 91.109(a): Flight Instruction **Petitioner seeks an exemption from 14 C.F.R. § 91.1 09(a), which provides that "[n]o**  **person may operate a civil aircraft (except a manne d free balloon) that is being used for**  **flight instruction unless that aircraft has fully f unctioning dual controls." sUASs and**  **remotely piloted aircraft, by their design, do not have functional dual controls. Instead,**  **flight control is accomplished through the use of a device that communicates with the**  **aircraft via radio frequency.**

Equivalent Level of Safety **Given the size and speed of the sUASs employed by R &M Aerial Imagery, an**  **equivalent level of safe training can still be perf ormed without dual controls because no**  **pilot or passengers are aboard the sUASs, and all p ersons will be a safe distance away**  **in the event that the sUASs experience any difficul ties during flights. Training flights will**  **be conducted with the provisions in the Operations Manual and in compliance with FAA**  **approved sUAS airspace envelopes. Accordingly, R&M Aerial Imagery's proposed**  **method of operation provides equivalent levels of s afety.** 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes **Petitioner requests an exemption from the minimum s afe altitude requirements of 14**  **C.F.R. § 91.119. Section 91.119 prescribes the mini mum safe altitudes under which**  **aircraft may not operate, including 500 feet above the surface and away from any**  **person, vessel, vehicle, or structure in non-conges ted areas.**  See **14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operat**  **e at less than those minimum altitudes when it can be operated "without hazard t**  **o persons or property on the surface," provided that "each person operating the**  **helicopter complies with any routes or altitudes specifically prescribed for helicopter**  **s by the FAA."**

Equivalent Level of Safety **Compared to flight operations with rotorcraft weigh ing far more than the maximum**  **weights proposed herein, and given the lack of flam mable fuel, any risk associated with**  **these operations is far less than those that presen tly exist with conventional aircraft. An**  **equivalent level of safety will be achieved given t he size, weight, and speed of the**  **sUASs, as well as the location where it is operated . In order to avoid any risk to aircraft,**  **flight operations will be restricted to 400' AGL or below.** 

I. 14 C.F.R. § 91.121: Altimeter Settings **The regulation provides that aircraft shall maintai n cruising altitudes by reference to an**  **altimeter setting available within 100 nautical mil es of the aircraft. This petition seeks**  **an exemption from 14 C.F.R. § 91.12 I, which requir es a person operating an aircraft to**  **maintain cruising altitude or flight level by refer ence to an altimeter that is set to the**  **elevation of the departure airport or barometric pr essure. The sUAS will normally will be**  **flying close to the ground, and in line of sight of the PIC. This line of sight operation will**  **provide separation from other aircraft, obstruction s, terrain, and would override the use**  **of an altimeter for such a purpose.**R&M Aerial Imagery Page 9

Equivalent Level of Safety **The FAA has stated that an equivalent level of safe ty can be achieved if the sUASs will**  **be operated at 400' AGL or below and within visual line-of-sight in addition to GPS**  **based altitude information relayed in real time to the operator.**  See **Grant of Exemption**

**to Astraeus Aerial, Docket No. FAA-2014-0352. As th e attached aircraft Owner’s**  **Manual indicates, the chosen sUASs meets these requ irements, and a zero altitude**  **initiation point will be obtained prior to flight.**

J. 14 C.F.R. § 91.1S1(a): Fuel Requirements for Fli ght in VFR Conditions

**Petitioner requests an exemption from 14 C.F.R. § 9 1.151(a)'s fuel requirements for**  **flight in VFR conditions. Section 91.151 states:**

**(a) No person may begin a flight in an airplane und er 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 crui sing speed –** 

**(1) During the day, to fly after that for at least 30 minutes; or** 

**(2) At night, to fly after that for at least 45 min utes.** 

**Here, the technological limitations on sUAS battery power means that no meaningful**  **flight operations can be conducted while still main taining a 30 minute reserve. R&M**  **Aerial Imagery proposes that all flights comply wit h this requirement by mandating that**  **the aircraft be safely landed with no less than 25% of battery life remaining.** 

Equivalent Level of Safety

**The FAA has stated that an equivalent level of safe ty is provided if the UAS flight is**  **terminated with at least 25% reserve battery power still available.**  See **Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0**  **352.**

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2 ); 91.417(a) and (b): **Maintenance Inspections**

**Petitioner seeks an exemption from the maintenance inspection requirements contained**  **in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2 ); 91.417(a) and (b). These**  **regulations specify maintenance and inspection stan dards in reference to 14 C.F.R.** 

**Part 43.** See, e.g., **14 C.F.R. §91.405(a) (stating that each owner or op erator of an**  **aircraft "[s]hall have the aircraft inspected as pr escribed in subpart E of this part and**  **shall between required inspections ... have discrep ancies repaired as prescribed in part**  **43 of this chapter"). An exemption from these regul ations is needed because Part 43**  **and these sections only apply to aircraft with an a irworthiness certificate, which the** 

**sUAS will not have.**R&M Aerial Imagery Page 10

Equivalent Level of Safety **An equivalent level of safety will be achieved beca use maintenance and inspections will**  **be performed in accordance with the sUAS aircraft o wner’s manuals and inspection**  **recommendations. R&M Aerial Imagery has elected to use its own process to maintain**  **its sUAS and ensure that only airworthy and safe sU AS will be allowed to operate in the** 

**NAS. Maintenance will be “on condition” for all a ircraft.** 

**The Operations Manual also sets requirements for ma intenance log books and record**  **keeping as well as routine and post-flight maintena nce. The Manual sets requirements**  **for both annual maintenance and preventative mainte nance based on hours of flight.** 

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations **Petitioner seeks exemption from 14 CFR § 61.113, wh ich restricts private pilot**  **certificate holders from flying aircraft for compen sation or hire, and would also require a**  **second class medical certificate. The purpose of Pa rt 61 is to ensure that the skill and**  **competency of any PIC matches the airspace in which the PIC will be operating, as well**  **as requiring certifications if the private pilot is carrying passengers or cargo for hire. In**  **this case, while the sUASs will be operated as part of a commercial operation, it carries**  **neither passengers nor cargo. In the Grant of Exemp tion in FAA Docket No. FAA-2014-**  **0352, the FAA determined that the unique characteri stics of sUAS operation outside of**  **controlled airspace did not warrant the addition co st and restrictions attendant with**  **requiring a PIC to have a commercial pilot certific ate and class II medical certificate.** 

Equivalent Level of Safety **Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because**  **the sUAS will not carry a pilot or passengers, the proposed operations can achieve the**  **equivalent level of safety of current operations by requiring the PIC operating the aircraft**  **to have a private pilot’s license rather than a com mercial pilot’s license to operate a**  **small sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a**  **ground-based operator. The operational area is cont rolled and restricted, and all flights**  **are planned and coordinated in advance. The risks a ssociated with the use of a sUAS** 

**are so diminished from the level of risk associated with commercial operations**  **contemplated by Part 61 allowing sUAS use by a priv ate pilot as the PIC exceeds the**  **present level of safety sought by 14 C.F.R.§61.113 (a) and (b).** 

**IV. DRUG AND ALCOHOL PROGRAM R&M Aerial Imagery has policies in place to ensure**  **that no person may act as a PIC, observer, or sensor operator if they are under the**  **influence of alcohol or any drug.**

**V. PUBLIC INTEREST**

**Granting R&M Aerial Imagery exemption request furth ers the public interest. National**  **policy set by Congress favors early integration of UAS into the NAS in controlled, safe**  **working environments such as those proposed in this petition. In addition, the public**  **also has an interest in reducing the hazards and em issions associated with alternate** R&M Aerial Imagery Page 11

**use of helicopters to conduct similar inspection op erations. The sUASs in question are**  **very light and do not carry any flammable fuel, fur ther reducing the risk from any**  **potential accident.**

**R&M Aerial Imagery intended uses for the sUASs have real-world benefits for civilian**  **markets, local, state and federal government entiti es and the public at large. This will**  **allow R&M Aerial Imagery to inspect difficult to re ach structures (smokestacks,**  **chimneys, building roofs, etc.). R&M Aerial Imager y sUASs enable elevated viewpoints**  **that are less expensive than traditional crane and boom operations with a smaller**  **ecological footprint. The sUAS work will aid in R&M Aerial Imagery member companies'**  **risk assessment, risk management, loss control, and surety performance programs.**  **These programs prevent accidents and injuries, and there is a strong public interest in**  **making these programs more effective through the us e of sUASs.** 

**Coordination and teaming with federal, state and lo cal governments in preparation for**  **emergencies will provide valuable training and onsi te information to first responders and**  **government entities.**

**VI. PRIVACY All flights will be conducted in accordance with an**  **y federal, state or local laws regarding privacy.** 

**VII. FEDERAL REGISTER SUMMARY**

**Pursuant to 14 C.F.R. Part 11, the following summar y is provided for publication in the**  **Federal Register, should it be determined that publ ication is needed:** 

**R&M Aerial Imagery seeks an exemption from the following rules:**  **14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 4 5.23(b); 14 CFR § 61.113; 14**  **CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 C FR 91.109(a); 14 CFR 91.119;**  **14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14**  **CFR 91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.41 7 (a) & (b).** 

**The exemption will enhance safety by reducing risk to the general public and property** 

**owners from the substantial hazards associated with performing equivalent work with** 

**conventional aircraft and rotorcraft.**

**VIII. CONCLUSION Satisfaction of the criteria provided in Section 33**  **3 of the Reform Act of 2012-size, weight, speed, operating capabilities, proximity to**  **airports and populated areas, operation within visual line of sight, and national**  **security-provides more than adequate justification for the grant of the requested exempt**  **ions to permit R&M Aerial Imagery to operate the selected sUASs and provide opportunitie**  **s for RDT&E in coordination with local, state and federal agencies.** R&M Aerial Imagery Page 12

**Granting the requested exemption will benefit the p ublic interest as a whole in, many**  **ways, including (1) significantly improving safety and reducing risk by alleviating human**  **exposure to danger, and (2) improving the quality o f services and decreasing operating**  **costs compared with conventional flight operations.**

**If you have any questions or require any additional information, please do not hesitate** 

**to call or email.**

**Ronald Paul Stites, 757-408-3648, stitesrp@gmail.co m**  **Michael B. Kitchen, 757-292-0553; michaelbkitchen@g mail.com** 

Attachments: 1) **R&M Aerial Imagery Operations Manual,** 2) **Inspire_1_User_Manual_v1.0** 3) **Inspire_1_Maintenance_ManualV1.0**