1

October 5 , 2015



## Rentenbach Constructors Inc orporated

2400 Sutherland Avenue Knoxville, TN 37919

- 2354 Phone: (865) 546

- 2440 Fax: (865) 546

- 3414

www.rentenbach.com

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE, West Building Ground Floor, Room W12

- 140, Washington, DC 20590

Request for Exemption under Section 333 o f the FAA Modernization and Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b).

PETITION FOR SUMMARY EXEMPTION

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Rentenbach Constructors , Inc. , an operator of Small Unmanned Aircraft (UA) hereby

app lies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UA , the DJI Phantom 3 Professional

.

TABLE OF CONTENTS

I. GLOSSARY OF ABBREVIATIONS........................

........................ .............................. .................... ..... ........... 3

II. QUICK REFERENCE SUMMARY

...................................................................................................... .... ... ..... ......... ..4

III. BACKGROUND

............................................. ........................... .......................... ....................... ... ...... ........4

IV. RENTENBACH CONSTRUCTORS, INC. REQUESTS THAT THE PUBLICATION AND COMMENT
PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87.

.......... ................................................... ...... ............ .................................................................................. ..... 4

V. FEDERAL REGISTER SUMMARY ......................................................................

.......................................... 5

VI. PETITIONER’S CONTACT INFO ........................................................................

............................. ............ 6

VII. LIST OF REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED ..............

.............................. .... 62

VIII. OPERATING DOCUMEN TS ................................................................................

............................. ....... . 6

IX. STATUTORY AUTHORITY TO GRANT THIS PETITION.................................

.............................................. 6

X. EQU IVALENT LEVEL OF SAFETY..................................................................

............................. .................. 7

XI. REGULATIONS FROM WHICH EXEMPTION IS NEEDED...........................................................................

....... 12

A. 14 C.F.R. § 61.23(a) & (c): Medical Ce rtificates...................

................ .................................. . ................... 12

B. 14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 14 C.F.R. § 61.315(a): Sport Pilot Limitations.............................................................................................

..... ............ .....................1 2

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

............... . ........1 2

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

... ......................................... ........... ............ 12

E. 14 C.F.R. § 91.119: Minimum Safe Altitudes........................................................

........................ ............. 12

F. 14 C.F.R. § 91.121: Altimeter Settings...........................................................

............................................ 12

G. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditi ons...............

..................................... 13

H. 14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): Maintenance Inspections.............................................................................................

......................................... .............. 13

XII. CONCLUSION.............................................................................................................................................

...... ... 13

XI I I. APPENDICIES

...................................................................................................... .......... ........................ 143

I. GLOSSARY OFABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

GLONASS Global Navigation Satellite System

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Take

- Off and Landing4

II. QUICK REFERENCE SUMMARY

 Types of aircraft to be flown:

 DJI Phantom 3 Professional

 The operations will be for:

 Aerial data collection v ia video and photography

 The petitioner will operate under the restrictions listed below.

 We already agree to all the restrictions listed in Exemption # 11284 which are listed below.

III. BACK G ROUND

Unmanned Aircraft Systems: D JI Phantom 3 Professi onal

Rentenbach Constructors, Inc

. seeks an exemption to operate the DJI system for compensation or hire
withi n the (NAS). The DJI Phantom 3 P rofessional is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with Global Navigation Satellite System (GLONASS) and Ground Control Station (GCS) utilizing a 2.400 GHz Remote Control system with a comp uter tablet. The DJI Phantom 3 P rofessional has a maximum gross weight of approximately 2 pounds 13.2 ounces, while having a width of 24 inches and
a h eight of 9 inches, and a maximum speed of approximate ly 31 knots. The DJI Phantom 3 P rofessional (UA) is equipped with four main rotors; utilizing Lithium Polymer batteries to power the electric motors. The DJI Phantom 3 professional (UA) that will be oper ated by Rentenbach Constructors, Inc. will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration
Mark ing.

IV. RENTENBACH CONSTRUCTORS, INC. REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87.

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of my petition for exemption?

Th e FAA may not publish a summary of your petition for exemption and request comments if you present or we find good cause why we should not delay action on your petition. The factors we consider in deciding not to request comment include:

(a) Whether grant ing your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously.

(c) Whether our delaying action on your petition would affect you adversely.

(d) Whether you filed your petition in a timely manner.

Corresponding to the above sub

- sections, Rentenbach Constructors, Inc. has good cause to request the FAA to waive the comment period and not delay action on the petition because:5

(a) Rentenbach Constructors, Inc. would not set any precedent. Rentenbach Constructors, Inc. agrees to the SAME exact limitations as Exemption # 11284

. T he aircraft, the Phantom 3, has already been evaluated under previous petitions and are deemed to have the equivalent level of safety if operated under the restrictions hereto a lready agreed upon.

(b) Rentenbach Constructors, Inc. agrees to the SAME exact limitations as Exemption s # 11284 and #12749

. (c) Delaying the granting of this petition would adversely affect the public, the FAA, and Rentenbach Constructors, Inc. The publ ic, as well as the FAA, would be better served by the FAA quickly granting this petition and thereby freeing up limited FAA resources and allowing FAA inspectors to dedicate their time and attention to much higher priorities. Moreover, Rentenbach
Construct ors, Inc. is adversely affected by the below listed regulations.

(d) The petition has been filed in a timely manner.

V. FEDERAL REGISTER SUMMARY

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

s hould it be determined that publication is needed.

Applicant seeks an exemption from the following rules:

14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for aerial data collection.

This exemption will al low commercial operations of UA S which will enhance safety by reducing risk. The alternative to using a UA S is to use a jet or piston power aircraft carrying large amounts of jet A or other fuel. Not only is the operation dangerous at the location, the aircraft must fly to the location and back to the home airport. Our UA S will weigh less than 55 lbs. and powered by batt eries which eliminates most of the risk because no highly flammable fuel will be involved. The UA S will carry no passengers or crew; thus, eliminating most of the risk to the pilot and personnel. The operations of the
UA S listed under the restrictions proposed herein will provide an equivalent level of safety as the Federal Aviation Regulations.6

VI. PETITIONER’S CONTACT INFO

In accordance with 14 CFR § 11.81, Rentenbach Constructors, Inc. provides the following information in support of its petition for exemption:

Rentenbach Constructors, Inc.
Attn: Elizabeth Erin Walker Email: liz.walker@rentenbach.com
651 East 4 th Street, Suite 403 Chattanooga, Tennessee 37403

- 1930 Phone: 423

- 826

- 1640
Fax: 423

- 826

- 1644

VII. LIST OF REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

 14 C.F.R. § 61.23(a) and (c)

 14 C.F.R. § 61.101(e)(4) and (5)

 14 C.F.R. § 61.113(a)

 14 C.F.R. § 61.315(a)

 14 C.F.R. § 91.7(a)

 14 C.F.R. § 91.119(c)

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)(1)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(1) & (2)

 14 C.F.R. § 91.417(a) & (b)

VIII. OPERATING DOCUMENTS

Rentenbach Constructors, Inc. will operate only within the limitations below. The limitations below, from the previously granted exemption s , will be followed if there is a conflict with the UAS’s user
manual , Appendix A

.

IX. STATUTORY AUTHORITY TO GRANT THIS PETITION

The Federal Aviation Act express ly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under § 40101 of the Act that includes UAS’s, from the requirement that all civil aircraft must have a curr ent airworthiness certificate. “The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the pub lic interest.” 49 U.S.C. § 44701(f). See also 49 U.S.C. § 44711(b).

This exemption petition is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law directs the Secret ary of Transportation to7

consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the FAA Modernization and Reform Act. In making this dete rmination, the Secretary is required to determine which types of UA do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UA’s size, weight, sp eed, and operational capability

 Ope ration of the UA in close proximity to airports and populated areas

 Operation of the UA within visual line of sight of the operator (VLOS)

If the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." The FAA has already established requirements for summary grants which will be further
discussed below.

X. EQUIVALENT LEVEL OF SAFETY

The applicant pro poses that the exemption requested herein applies to civil aircraft that have the characteristics and that operate with the limitations listed herein.

These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure. These limitations and conditions are identical to Exemption # 11284 except for the difference in aircraft

. Rentenbach Constructors, Inc. agrees to be bound when conducting commercial UA operations. The list of limitations and conditions include the following:

1. Operations authorized by this grant of exemption are limited to the Phantom 3 Professional when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be opera ted at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires
the PIC to be able to use human vision unaide d by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) o f the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during8

flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents mu st be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitat ions herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisi ons and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the oper ator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questio ns arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functiona l test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner s o as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection , and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety
bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a stat e, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the9

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appro priate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficien cy, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from

non participants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SV FR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as deno ted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made av ailable to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return t o a predetermined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is proh ibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations
shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for
a new or amended COA if it intends to conduct operations that cannot be conducted under th e terms of the attached COA.10

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N N umber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must b e available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all
times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a si tuation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicl es or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue
hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permi ssion from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov . For the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as
docu mented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the11

concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible
for the on

- scene operation of the UAS; d. Make, model, and serial or N

- Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial f ilming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; 13 g. Signatur e of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31 . Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Rentenbach Constructor , Inc.’s UA are rotorcraft, weigh ing 55 lbs. or less including payload. They operate, under normal conditions at a speed of no more than 50 knots and they have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only within
VLOS and on l y within the restrictions above . Such operations will insure that the UA will "not create a
hazard to users of the national a irspace system or the public."

Given the small size of the UA involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exempt ion, allow commercial operations of UA to commence immediately. Also, due to the size of the UA and the restricted areas in which the relevant UA will operate, approval of the application presents no national security issue.

Since the UA fully loaded weig hs no more than 55 lbs. and is operated without an onboard pilot, there is no ability or place to carry certification and registration documents or to display them on the unmanned aircraft. An equivalent level of safety will be achieved by keeping these do cuments at the ground control point where the pilot flying the UA will have immediate access to them. Also, given the size of the unmanned aircraft, the FAA registration number will be displayed on the airframe in as large a font as possible.12

XI. RE GULATIONS FROM WHICH EXEMPTION IS NEEDED

A. 14 C.F.R. § 61.23(a) & (c): Medical Certificates

Exemption # 11221, # 11284, and many others have provided that a U.S. driver’s license could be used in lieu of the medical certificate provides an equivalent le vel of safety.

B. 14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 14 C.F.R. § 61. 315(a): Sport Pilot Limitations

Exemption # 11221, # 11284, and many others have declared that there is an equivalent level of safety
as the FAR’s by requiring the PIC to “hold either an airline transport, commercial, private, recreational, or sport pilot certificate.” Likewise, Rentenbach Constructors, Inc. is also performing commercial UAS work and is asking for the same restrictions which ha ve been previously deemed to provide an equivalent level of safety as the burdensome regulations.

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

Sub

- sections 61.113(a) limit private pilots to non

- commercial operation s. Because the UAS 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 sport pilot license rather than a commercial pilot's lic ense to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board.

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

As there will be no airworthiness cert ificate issued for the unmanned aircraft, and no FAA regulatory standard will exist for determining airworthiness of the UA, the requirements contained in the UAS’s
user manual and the restrictions already agreed to will provide an equivalent level of safe ty.

Furthermore, all of the aircraft in the exemptions above ha ve been previously evaluated and deemed to have the equivalent level of safety of the regulations if operated under the restrictions above. Therefore, this aircraft should not be required to h ave an airworthiness certificate based upon the FA A’s previous determinations.

E. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated a t less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. Because of the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply w ith Section 91.119.

F. 14 C.F.R. § 91.121: Altimeter Settings

This regulation 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 appropria te altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude13

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to following the con fidentially submitted manual. Furthermore, many other petitions have been granted allowing GPS to be used in lieu of an altimeter setting.

G. 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, assuming normal cruising speed

- (1) During the day, to fly aft er that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." Applicant believes that an equivalent level of safety can be achieved by restricting operations to “the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.” E xemption # 11284, at page 5.

H. 14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): Maintenance Inspections

These regulations require that an a ircraft 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 the applicant. An equivalent level of sa fety will be achieved because these small UAS’s are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. Moreover, the operator is the person most familiar with the aircraft and best suited t o maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Lastly, the petitioner will operate in accordance with the UAS’s user manual which will provide an equivalent level of safety as the burdensome regulations.

XII. CONCLUSION

The operation of Rentenbach Constructors, Inc. using a small UAS, weighing less than 55 lbs., conducted under the proposed restrictions outlined above as well as the user manual, will provide an equivalent level of safety supporting the grant o f the exemptions requested herein. If I can be of any assistance to further expedite this petition, please do not hesitate to contact me at (423) 826

- 1640 or via email at liz.walker@rentenbach.com

.14

XIII. APPENDICIES

Appendix A:

Link to DJI Phantom 3 Professional User Manual :
http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf