Aug 16 , 2015

United States Department of Transportation
Docket Management System 1200 New Jersey Ave SE Washington, DC 20590



## RE: Petition of Cenpac Images LLC for Exemption Pursuant to Section 333 of the
FAA Reform Act

Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Cenpac Images LLC
, operator of Sm all Unmanned Aircraft Systems (" UAS " ), hereby applies for an exemption from the listed Federal Aviation Regulat ions ("FARs") to all ow commercial operation of
its UASs. Cenpac Images LLC will conduct its operations within and under the conditions of this petition or as established by the FAA in granting a Section 333 exemption.



## Overview:

Cenpac Images LLC was foun ded to provide aerial image and data services for customers near Fresno,
California and surrounding areas.

Cenpac Images LLC intends to operate the Lehmann Aviation LA300 UAS to collect photos and videos for the following purposes:

 Precision Agriculture

 Real estate

 Construction site monitoring

 Inspection of buildings and structures

 Environmental monitoring

 Civil planning

 Stock aerial photography

## UAS to be used: Lehmann Aviation LA300 :

The Lehmann Aviation LA300 UAS consists of a fixed

- wing aircraft and ground control station . The
aircraft is a flying

- wing style with a single propeller mounted in the rear, driven by a Lithium Polymer battery powered electric brushless motor. It has a maximum gross weight of 2.09 lbs (950 grams) , a wingspan of 36.2 inch es (92 cm) , and a maximum speed of 43 knots ( 50 mph, 80 km/h ). The aircraft construction consists mainly of styrofoam with plastic components. The ground control station consists of a Microsoft Surface tablet PC with WiFi range extender operating at a fr equency of 2.4 Ghz. The Lehmann Aviation OpsCenter software is used to load a predefined flight plan into the aircraft before flight, and can send commands to the aircraft while it is airborne to alter course or abort the flight and return to the takeoff site if necessary. Additional emergency features include
automatic motor cu tout if the aircraft exceeds certain altitude or predefined flight area limitations.
Altitude readout in feet AGL is provided on the right side of the altitude readout bar to ensure compliance with altitude limitations. Additional information may be found in the LA300 User Manual and other documents submitted with this exemption request (these are proprietary
information of Cenpac Images LLC , and it is requested that they not be made available to the public).



## A

. N ame and address of the applicant :

Cenpac Images LLC
2491 Alluvial Ave Suite 22
Clovis CA 93611
Ph.: 559

- 908

- 7701
Email: lake345@gmail.com



## B

. Sections of 14 CFR for which exemption is sought:

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)
14 C.F.R. 91.119
14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. (91.401

- 91.417)

## C . Extent of relief sought and reason why Cenpac Images LLC seeks the relief:

Relief sought for 14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113 (a) & (b) limit s private pilots to non

- commercial operations. Cenpac Images LLC requests an exemption of this rule to allow Private pilot ce rtificate holders to act as PICs of it s UAS during commercial operations. As set forth more fully below in Section E
, Cenpac Images LLC believes that an equivalent level of safety will be maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate the UAS in a manner consistent with the operations specifications as set forth herein, including evasive and emergency maneuvers, as well as maintaining appropriate dista nces from people, vessels, vehicles and structures.

Relief sought for 14 C.F.R. 91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Since no airworthiness certificate is required for the UASs to be used, Cenpac Images LLC requests relief from this rule to allow for operation of its U ASs by determining airworthiness based on compliance with operating documents and conducting thorough pr eflight in spections prior to every flight, as described in the operating manual of the UAS.

Relief sought for 14 C.F.R. 91.119: Minimum safe altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) limits a ircraft flying over areas other than congested areas to a minimum altitude of 500 ' AGL. Over sparsely populated areas, aircraft cannot be operated closer than 500 feet of any person, vessel, or structure. Cenpac Images LLC requests an exemption to this rul e to allow for UAS operations from the surface to a maximum altitude of 400' AGL. This is to allow for low altitude aerial photography consistent with the intended use of sUAS, while maintaining an equivalent level of safety as described more fully in Sec tion
E below.

Relief sought for 14 C.F.R. 91.121 Altimeter Settings. This regulation requires each person operating an aircraft to set the barometric altimeter to the appropriate altimeter setting so as to maintain a safe distance from other aircraft

. B ecause the UAS will
not have a n adjustable barometric altimeter, but instead a GPS altitude read

- out, an exemption is requested to allow operations with an equivalent level of safety.

Relief sought for 14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions. Section 91.151 (a) prohibits an individual from beginning “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, assum ing normal cruising 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 minutes.” The intent of this requirement is to provide enough fuel reserve in the event of delays due to congesti on or weather at an airp ort. Cenpac Images LLC requests relief from this rule to the extent requir ed to allow flight of their UAS to the firstpoint of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

Relief for this rule is requested because without an exemption from 91.151(b), the limited flight time
duration of Cenpac Images LLC 's battery

- powered UASs will severely constrain the pr acticality of flight operations while providing a negligible increase in saf ety.

Relief sought for 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (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 shal l 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. Cenpac Images LLC requests relief from these rules since they only apply to aircraft with an airworthiness certificate. Cenpac Images
LLC proposes to operate the Lehmann Aviation LA300 UAS , which meet s the conditions of Section 333 of the FMRA for operation without an airw orthiness certificate. All maintenance, alterations, or preventive
maintenance on Cenpac Images LLC 's UASs will be in accordance with the methods, techniques, and practices prescribed in the operating documents. Furthermore, only the Original Equipment
Ma nufacturer (OEM) or qualified OEM maintain ers will perform higher level inspections and maintenance per the operating documents and OEM standards. Cenpac Images LLC will document and
maintain all maintenance records for the p roposed UAS

.



## D. Why granting th e request would be in the public interest

Approval of exemptions allowing commercial operations of UASs will enhance safety by reducing the risk associated with performing similar operations in larger manned aircraft . Larger piston or turbine powered aircraft carry large amounts of flammable fuel, as well as living human beings. In some operations, especially low altitude aerial photography and inspection, these aircraft operate in close proximity to structures and other objects, increasing risk. In contrast, a UAS weighing fewer than 55 pounds and powered by small electric motors eliminates almost all of that risk given the reduced weight and lack of combustible fuel carried on board. The UAS will carry no passenge rs or crew and, therefore, will not expose anyone to the risks associated with manned aircraft flights.



## E. Why granting the exemption would not adversely affect safety, or how it would provide an equivalent level of safety

Why an exemption for the follow ing rule would not adversely affect safety: 14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. An equivalent level of s afety will be maintained by requiring the PIC of each UAS to demonstrate, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures

. Cenpac Images LLC submits that, due to the operational nature of UAS, the additional manned airmanship skills held by a

comm ercially certificated pilot do not transfer to additional skills during UAS operations. Cenpac ImagesLLC will ensure that the PI C of each UAS holds either an airline transport, commercial, private,

recreational, or sport pilot certificate accompanied by a current FAA airman medical certificate or valid U.S. driver's license, as required, and will be acc ompanied by a Visual Observer . The PIC will be required to have accumulated and logged, in a manner consis tent with 14 C.F.R. 61.51(b), 2 0 hours of total time as a UAS pilot including at least 5 of those hours as a UAS pilot operating the same make and model of
UAS to be used for ope rations under the exemption

. The PIC must also have satisfactorily demonstrated 

### evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures. In addition to the hour requirements, the PIC must accomp lish 3 take

- offs and landings in the preceding 90 days for currency purposes. The Visual Observer will have been given training on UAS regulations, the types of operations to be conducted, and procedures necessary for safe and effective conduct of their j ob duties.

Why an exemption for the following rule would not adversely affect safety: 14 C.F.R. 91.7(a): Civil
aircraft airworthiness. An equivalent level of safety will be provided by the PIC's thorough evaluation of the airworthiness of the UAS prior to every flight. This evaluation will consist of a thorough preflight inspection consistent with the operating manual of the UAS, compliance with all applicable operating documents, and verification that all required maintenance has been complied with. The preflight check will consist of a visual check of the physical condition of the aircraft and powerplant, an operational check of the flight control surfaces, and verification of strong signal between ground control station and aircraft.

Why an exemp tion for the following rule would not adversely affect safety: 14 C.F.R. 91.119:
Minimum safe altitudes. An equivalent level of safety will be maintained by the PIC and Visual Observer's careful observation of the UAS during all operations and the use of standardized callouts to prevent collision with structures, vehicles, and vessels. Visual Line of Sight with the UAS will be maintained at all times, and no non

participating persons will be present during flight operations. Altitude readouts on the grou nd station will be used to ensure that a maximum altitude of 400' is never exceeded to prevent flight at altitudes of manned aircraft. Additionally, the small size, light weight, low speed, and lack of combustible fuel in the
UAS contribute to a level of safety that meets or exceeds that that of manned aircraft operations in compliance with 91.119

.

Why an exemption for the following rule would not adversely affect safety: 14 C.F.R. 91.121 Altimeter Settings. An equivalent level of safety will be achieved by confirming the altitude of the launch site shown on the
GPS a ltitude indicator before flight, and operating the UAS at an altitude of no more than 400' AGL so as to maintain adequate separation from manned aircraft operating at higher altitudes. Visua l line of sight with the UAS will be maintained at all times, and a Visual Observer will be utilized to ensure the UAS is
clear of all manned aircraft.Why an exemption for the following rule would not adversely affect safety: 14 C.F.R. 91.151(a): Fuel

Requirements for Flight in VFR Conditions.
A n equivalent level of safety can be achieved by ensuring that the UAS has enough battery power to fly

to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5

m inutes. Due to the visual line of sight requirements for UAS, operations will never be conducted outside of the vicinity of the PIC and observer. All flights will be planned to allow for a minimum of 5 minutes of battery time remaining at the planned lan ding site. If an aborted landing must be conducted, the additional 5 minutes of reserve battery will allow for sufficient time to locate a new landing location and conduct a safe landing.

Why an exemption for the following rule would not adversely affect safety: 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

An equivalent level of safety can be obtained by complying with all inspections and maintenance required by the manufacturer. All maintenance, alterations, or preventive maintenance on Cenpac Images LLC 's UASs will be in accordance with the methods, techniques, and practices prescribed in the operating documents. Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM
maintain ers will perform higher level inspections and maintenance per the operating documents and
OEM standards. Cenpac Images LLC will document and maintain all maintenance records for the proposed UAS

.


## F. Summary for publishing in the Federal Register:

Cenpac Images LL C seeks exemption from the requirements of 14 CFR Sections 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), and 91.401

- 91.417.

This exemption will permit Cenpac Images LLC to conduct commercial operation of Unmanned Aerial Systems (UAS) within the National Airspace System for the purpose of aerial photo, video, and data
collection.



## G. Any additional information, views or arguments

Additional information may be found in the attached documents, which include the Lehmann Aviation LA300 User Manual and an image depicting the OpsCenter software.



## H. Operations outside of the United States

All operations will be conducted within the Unit ed States of America.

## Conclusion:

As detailed above, Cenpac Images LLC respectfully requests an exemption from the aforementioned sections of 14 CFR pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. If this exemption is granted, it will allow Cenpac Images LLC to conduct commercial operations of small UAS
under a set of ru les allowing for safe aerial data collection, benefiting the public and local economy.

Sincerely,

Cenpac Images LLC
2491 Alluvial Ave Suite 22
Clovis CA 93611
Ph.: 559

- 908

- 7701
Email: lake345@gmail.com