Mike & Vicki Brennan

dba: RainierDrones.com LLC

430 Bare Road

Ellensburg, WA 98926

EMAIL: MGR@RainierDrones.com

March 8, 2016

U.S. Department of Transportation, Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Section 333 Petition Exemption Request

Page of 1 22Salutations Madam or Sir:

On this day of March 8, 2016...

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Mike and Vicki Brennan dba: RainierDrones.com LLC, State of Washington UBI # 603-588-390, do seek an exemption from the Federal Aviation Regulations ("FARs") listed below to allow commercial operation of its UAV’s so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Mike Brennan, co-owner, did the majority of his flight training at FlightSafety International, holds a Commercial Pilot Certificate, and fully understands the responsibility and serious nature of operating under strict professional standards in the National Airspace System and will oversee/manage RainierDrones.com LLC accordingly.

RainierDrones.com LLC in this Petition for Exemption, seeks Relief from the following of Title 14 of the Code of Federal Regulations:

SECTIONS 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

The requested exemption would permit commercial operation of RainierDrones.com LLC, to utilize 3D Robotics Solo UAV multi rotor aircraft, weighing less than 55 lbs. including cargo. The applications for these UAV devices would consist of still photographs and/or video taken by an onboard camera and associated data processing functions and used for aerial videography and photography for:

• Real Estate Marketing

• Agricultural/Crop Related Inspections

• Agricultural Irrigation/Ditch Inspections

• Outdoor Rural events, both public and private observing prior permission/approval from the appropriate agencies/individuals

• Structural Inspections

• Local, County, Law Enforcement, Search and Rescue as needed/on call to serve in the public interest as sanctioned by the appropriate agency

Use of the UAV’s for the aforementioned purposes reduces the need to operate conventional aircraft or other equipment for the same purpose and provides high resolution digital imagery at a fraction of the cost of surveys and inspections using conventional means. The use of these UAV’s in our region of the Cascade Mountains of

Page of 2 22Washington State, can also benefit SAR, Law Enforcement and the like in steep, inaccessible, off trail terrain. Inspections of structures and agricultural ditches can be performed without endangering the inspector utilizing conventional high risk devices such as ladders, lifts or other equipment. The overall economic as well as safety benefits of operating these UAV’s becomes quite apparent in all market segments described above.

UAV Model to be utilized in RainierDrones.com LLC operations:

3D Robotics Solo UAV: A 4 rotor ”Quad” VTOL, Electric Motor Driven, Battery Powered Aircraft.

Estimated flight time: up to 25 minutes*

Default maximum altitude: 150 ft. (46 m) above ground level

Range: .5 mile (.8 km)

Payload capacity: 1 lb. (450 g)

Cruise speed: 18 mph (8 m/s)

Maximum speed: 33 mph (15 m/s)

Wind speed limitation: 25 mph (11 m/s)

Operating temperature: 32° F - 113° F (0° C to 45° C)

RainierDrones.com LLC seeks an exemption to operate 3D Robotics Solo Model Quad Copters commercially, for compensation or hire within the NAS of the United States of America.

RainierDrones.com LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 3D Robotics UAV ’s in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R. §§ 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, RainierDrones.com LLC operation of the 3D Robotics UAV ’s meet the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, RainierDrones.com LLC requests relief from Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth

Page of 3 22requirements for maintenance that only apply to aircraft with an airworthiness certificate.

RainierDrones.com LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. RainierDrones.com LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventative maintenance on the UAV’s using the methods, techniques, and practices prescribed in the operating documents (i.e., manual names). Furthermore, RainierDrones.com LLC will document and maintain all maintenance records for the UAV ’s.

Relief from certain requirements of Sections 61.113(a), entitled Private pilot privileges and limitations: Pilot in command, is requested by RainierDrones.com LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the UAV ’s in a manner consistent with this exemption, including normal procedures, abnormal procedures, emergency procedures and maintaining appropriate distances from people, vessels, vehicles, and structures.

RainierDrones.com LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the UAV’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, RainierDrones.com LLC will ensure that the UAV’s are in an airworthy condition, prior to every flight, by determining that the UAV’s are in compliance with the operating documents (i.e., manual names), and that the aircrafts are in a condition for safe flight. RainierDrones.com LLC seeks relief from Section 91.119(c), entitled Minimum safe altitudes: General, because the proposed UAV’s must fly lower than 400’ above the surface to accomplish certain operations such as photography and infrastructure inspections. As such, RainierDrones.com LLC will ensure that operations that occur less than 400’ above the surface will remain at least 500’ away from all nonparticipating persons, vehicles, vessels, and structures unless a barrier exists to shield nonparticipating persons or RainierDrones.com LLC has the owner’s permission to operate near the vehicle, vessel, or structure.

RainierDrones.com LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the UAV’s will not have a typical barometric altimeter onboard. However, altitude information of the UAV’s will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with RainierDrones.com LLC operation of the UAV’s within visual line of sight, at or below 4 00’ AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, RainierDrones.com LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. RainierDrones.com LLC submits that safety will not be affected by operation of the UAV ’s during daylight hours in visual meteorological conditions (VMC) under visual flight

Page of 4 22rules (VFR), for a total duration not greater than that recommended by the manufacturer.

In accordance with 14 C.F.R. § 11.81, RainierDrones.com LLC provides the following information in support of its petition for exemption:

The name and address of the Petitioner is:

Mike and Vicki Brennan

430 Bare Road

Ellensburg, Wa 98926

A point of contact for RainierDrones.com LLC is:

Mgr@RainierDrones.com

The Specific Sections of 14 C.F.R. From which RainierDrones.com LLC Seeks Exemption.

1. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 61.113(a). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsection (a) prescribes the following, in relevant part: (a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

2. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a) prescribes the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.119(c). Section 91.119, entitled Minimum safe altitudes: General, subsection (c) prescribes the following, in relevant part:

Page of 5 22(c) Except when necessary for takeoff or landing, no person may operate an aircraft over other than congested areas below 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

4. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a) prescribes the following, in relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to –

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

5. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.7, entitled Fuel requirements for flight in VFR conditions, subsection (b) prescribes the following: (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

6. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a) prescribes the following: Each owner or operator of an aircraft – (a) 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[.]

7. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Page of 6 22Section 91.407, entitled Operation after maintenance, preventative maintenance, rebuilding, or alteration, subsection (a)(1) prescribes the following: (a) No person may operate any aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless – (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

8. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.409(a)(1) and 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a) prescribes the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, unless it has had –

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

9. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsection (a) and (b) prescribes the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include –

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

Page of 7 22(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks The Relief.

1. Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks Relief From Section 61.113(a).

Relief from Section 61.113(a) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain training and currency requirements, to conduct the proposed UAV flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as a PIC of an aircraft in connection with any business or employment if (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more entirely below, RainierDrones.com LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate a UAV

Page of 8 22unless that PIC has demonstrated, through OEM training and currency requirements, that the PIC is able to safely operate the aircraft in a manner consistent with the operations specifications as described in this exemption including normal procedures, abnormal procedures, and emergency procedures to include evasive maneuvering and maintaining appropriate distances from people, vessels, vehicles, and structures.

Further, RainierDrones.com LLC submits that all flights of the UAV’s conducted by the PIC pursuant to the grant of this Petition (1) will be incidental to RainierDrones.com LLC ’s business; and (2) will not carry passengers or property for compensation or hire.

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a), entitled Civil aircraft airworthiness, is requested to the extent required to allow RainierDrones.com LLC to determine that the operations UAV is in an airworthy condition prior to every flight by ensuring that the UAV is in compliance with the applicable operations and maintenance manuals, and that the UAV is in condition for safe flight.

RainierDrones.com LLC seeks the requested relief because the proposed UAV’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, RainierDrones.com LLC will ensure that the UAV is in an airworthy condition based upon its compliance with the operating documents prior to every flight, and as stated in the conditions and limitations below.

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the proposed UAV , which utilize barometer and GPS equipment, to ensure that a ground level pressure setting will be established prior to each flight, and in order to report altitude to the PIC.

RainierDrones.com LLC seeks the requested relief because the proposed UAV do not utilize a typical barometric altimeter that may be set as contemplated by Section 91.121. As more fully set forth below, an equivalent level of safety will be maintained since the UAV’s are equipped with a barometer and GPS equipment, which will ensure that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UAV , above ground level (AGL), on the heads-up display of the GCS.

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b), entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered UAV , during daylight hours in visual meteorological conditions under visual flight rules (VFR), to

Page of 9 22continue for a total duration not greater than that recommended by the manufacturer for safe operation.

RainierDrones.com LLC seeks the requested relief, because without an exemption from Section 91.151(b), the flight time duration of the battery powered UAV will severely constrain the practicality of many of the operations RainierDrones.com LLC proposed to conduct pursuant to this Petition.

5. Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, RainierDrones.com LLC requests relief from these Sections because the UAV’s do not require an airworthiness certificate. As set forth more fully below, the selected UAV’s meet the conditions of Section 333 of the FMRA for operation with an airworthiness certificate. Accordingly, RainierDrones.com LLC will perform maintenance, alterations, or preventative maintenance on the UAV’s as prescribed by the manufacturers’ maintenance documentation where applicable, or by returning the aircraft to the manufacturer when operator maintenance is not recommended. Furthermore, RainierDrones.com LLC will maintain maintenance logbooks for each UAV.

D. Reasons Why Granting RainierDrones.com LLC ’s Request Would Be In The Public Interest.

Granting the present Petition will further the public interest by allowing RainierDrones.com LLC to safely, efficiently, and economically perform aerial photography, videography, agricultural inspections, property inspections and aerial mapping over areas of the United States.

Additionally, use of the 3D Robotics Solo UAV’s will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of RainierDrones.com LLC’s proposed operation of UAV’s will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3D Robotics Solo UAV’s are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3D Robotics Solo UAV would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced.

Page of 10 22The 3D Robotics Solo UAV ’s do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, cruise, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency of the 3D Robotics Solo UAV ’s.

Conducting aerial image acquisitions with the 3D Robotics Solo UAV’s, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial photography, videography, inspection, and agricultural mapping flight operations. By using battery power and electric motors, the 3D Robotics Solo UAV’s produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 10-20 gallons per hour of leaded aviation fuel. The 3D Robotics Solo UAV’s, while reducing the carbon footprint of aerial data acquisitions, also eliminates noise pollution, as the UAV ’s are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the 3D Robotics Solo UAV’s to perform aerial image acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 3D Robotics Solo UA’s (all weighing less than 10 pounds at their maximum gross weights and with no fuel on board) has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing 3000-6000 pounds and carrying 50-100 gallons of fuel).

3. Performing aerial image acquisitions with the 3D Robotics Solo UAV’s will benefit the Economy. In addition to being safe and efficient, the 3D Robotics Solo UAV’s are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 3D Robotics Solo UAV’s will allow United States based companies, like RainierDrones.com LLC to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to maintain competitive. Operating the battery powered 3D Robotics Solo UAV ’s is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the 3D Robotics Solo UAV’s, companies such as RainierDrones.com LLC can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the 3D Robotics Solo UAV ’s provides a stable workforce that increases consumer

Page of 11 22spending, improves tax revenues, and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, RainierDrones.com LLC’s proposed operations of the 3D Robotics Solo UAV’s will not implicate any privacy issues. Specifically, the Solo UAV’s will be operated only in compliance with limitations set forth in the Granting of this Petition and operating documents (i.e. 3DR Solo Flight Operations Manual) which guides operations around persons and property, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. Section 91.119.

E. Reasons Why Granting RainierDrones.com LLC ’s Request Would Not Adversely Affect Safety.

1. Reasons Why The 3D Robotics Solo UAV ’s Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FRMA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and their operation, RainierDrones.com LLC’s operations of the 3D Robotics Solo UAV ’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAV to operate without airworthiness certification and sets forth requirements for considering whether a UAV will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

. (a) In General. – Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operatesafely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

. (b) Assessment of Unmanned Aircraft Systems. – In making the determination under subsection (a), the Secretary shall determine, at a minimum—

. (1) Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

Page of 12 22. (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

. (c) Requirements for Safe Operation. – If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, RainierDrones.com LLC submits that the included UAV’s can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of these UAV’s ; (b) the pilot certification requirement; and (c) the specific operating 3D Robotics Solo Safety Features

The 3D Robotics Solo UAV’s also have many safety features to mitigate events like loss of link and loss of navigational capability.

Although a degra dation or loss of control link, and/or degradation or loss of the source of navigation is unlikely, it is a situation that is well planned for and therefore, a benign event.

In the event of a loss of link, the aircraft will follow a user-selected procedure. The aircraft will proceed to the “home” position, which is set by the PIC prior to flight and can be changed in flight if necessary, at a set altitude. If link is not regained, the aircraft will initiate a decent and land at the designated “home” position.

If the GPS solution is lost during flight, the PIC will still have full control of the aircraft and can maneuver it back to “home” for a safe landing. As the PIC always flies the UAV in visual line of sight, it is immediately apparent if this situation occurs.

The 3D Robotics Solo Controller has many built in alerts and safety features as well. Five features; pause, regain manual control, return home, land, and motor shutoff are available in case of emergency. The motor shutoff feature is a two-step procedure to prevent inadvertent motor shutoff.

A complete description of the operation and specifications of the 3D Robotics Solo are provided in the Operator Manual.

Page of 13 222. Flight Operations of the 3D Robotics Solo UAV’s Are limited to the line of sight of a Certificated Pilot In Command with a visual observer. RainierDrones.com LLC will only employ pilots who meet FAA Requirements: Possess and meet currency requirements for at least a sport pilot certificate Possess a valid third class or better FAA airman medical certificat e

• In the case of the upcoming proposed Provisions of Part 107, in which a proposed new type of:” Unmanned Aircraft Operator Certificate” with a Specific UAS Rating is put into effect, RainierDrones.com LLC will continue to require said UAO Certificate Holder to adhere to the same flight proficiency/hours in type as below. ALL RainierDrones.com LLC PIC’s Must Successfully complete 25 HOURS of OEM training “in type” on the SOLO UAV being flown and demonstrate proficiency on that SOLO UAV. RainierDrones.com LLC will only utilize visual observers who are trained on the appropriate FAA rules and regulations required to perform their duties. Training records, flight time totals, and applicable flight currency records will be maintained by RainierDrones.com Co-Owner Mike Brennan.

3. Flights of the 3D Robotics Solo UAV’s will be conducted pursuant to specific operating limitations. In seeking this exemption, RainierDrones.com LLC proposes to commercially operate the specified UAV’s for the special purpose of conducting real estate photography, outdoor videography, property inspections, agricultural related inspections, SAR/Law Enforcement Aid in the United States, pursuant to the following specific operating limitations:

In studying past Section 333 Grants of exemption similar to our petition, we hereby propose to adhere to the following:

1. Operations by RainierDrones.com LLC are limited to the operation of 3D Robotics Solo UAV’s, weighing less than 55 pounds including payload. We understand that any other p roposed 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 will not be undertaken or permitted.

3 RainierDrones.com LLC UAV’s may not be operated at a speed exceeding 33 knots. RainierDrones.com LLC will utilize either groundspeed or calibrated

Page of 14 22airspeed to determine compliance with the 33 knot speed restriction. In no case will RainierDrones.com LLC UAV’s be operated at airspeeds greater than the maximum UAV operating airspeed recommended by the aircraft manufacturer.

4. RainierDrones.com LLC UAV’s must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. RainierDrones.com LLC UAV’s must be operated within visual line of sight (VLOS) of the PIC at all times. This requires RainierDrones.com LLC PIC to be able to use human vision unaided 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 by RainierDrones.com LLC must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of 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 will not be permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

7. RainierDrones.com LLC and all documents needed to operate the UAV’s 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 will be accessible during UAV operations and will be made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in RainierDrones.com LLC exemption and the procedures outlined in the operating documents, the conditions and limitations by the FAA take precedence and must be followed. Otherwise, RainierDrones.com LLC operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is understood that RainierDrones.com LLC operator’s responsibility to track such revisions 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 operator 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 questions arise regarding updates or revisions to the operating documents.

Page of 15 228. Any RainierDrones.com LLC UAV that has undergone maintenance or alterations that affect the UAV’s operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional 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 so as to not pose an undue hazard to persons and property.

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

10. Prior to each flight, the RainierDrones.com LLC PIC must conduct a pre-flight inspection and determine the UAV 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 UAV, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAV is found to be in a condition for safe flight.

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

12. Each UAV operated by RainierDrones.com LLC must comply with all manufacturer safety bulletins.

13. RainierDrones.com LLC PIC must hold either an airline transport, commercial, private, recreational, sport pilot certificate or in the case of acceptance/ implementation of the proposed provision of Part 107, specific to the “Operator Certification and Responsibilities” section relating to the proposed “Unmanned Aircraft Operator Certificate”, with small UAS rating if applicable at the time of this petition being granted, whichever is applicable at the time of this petition being approved. For the sake of the current conditions, default to the current standing of: The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

Page of 16 2214. RainierDrones.com LLC, will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAV in a manner consistent with how the UAV will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate 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, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAV 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 UAV with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. RainierDrones.com LLC operations will not be conducted at night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. RainierDrones.com LLC UAV’s will 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 denoted 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 available to the Administrator or any law enforcement official upon request.

17. RainierDrones.com LLC UAV’s will 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 any of RainierDrones.com LLC UAV’s lose communications or loses its GPS signal, the UAV must return to a pre-determined location within the private or controlled-access property.

Page of 17 2219. RainierDrones.com LLC PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. RainierDrones.com LLC PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UAV to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

All operations shall be conducted in accordance with an ATO-issued COA.

RainierDrones.com LLC may apply for a new or amended COA if it intends to :

Conduct operations that cannot be conducted under the terms of the COA.

23. 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

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. 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 be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

25. RainierDrones.com LLC UAV’s must remain clear and give way to all manned aviation operations and activities at all times.

26. RainierDrones.com LLC UAV’s may not be operated by the PIC from any moving device or vehicle.

27. All Flight operations by RainierDrones.com LLC will 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 UAV and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are

Page of 18 22within 500 feet of the UAV , flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles, 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.

28. All operations by RainierDrones.com LLC will be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will 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

.

It is further understood, unless otherwise specified, RainierDrones.com LLC, its associative UAV’s, the UAV PIC, and the UAV operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

4. Reasons Why An Exemption From The Requirements Of Section 61.113(a) Would Not Adversely Affect Safety.

RainierDrones.com LLC submits that an equivalent level of safety established by Section 61.113(a) will be maintained because no PIC will be allowed to operate the UAV unless that PIC has demonstrated, through the proper UAV training and currency requirements, that the PIC is able to safely operate the UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

Considering RainierDrones.com LLC’s proposed area of operations and the operating limitations set forth above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No 11062); and the airmanship skills necessary to safely operate the UAV, RainierDrones.com LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for RainierDrones.com LLC ’s specific proposed flight operations.

Page of 19 22Additionally, the FAA has previously granted relief from Section 61.113(a) specific to UAS, in circumstance similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

As in Exemption No. 11109, RainierDrones.com LLC will not allow any PIC to operate the UAV unless that PIC has demonstrated through the UAV training and currency requirements that the PIC is able to safely operate the UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

5. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The level of safety established by Section 91.7(a) will be maintained because prior to every flight, RainierDrones.com LLC will ensure that the UAV is in an airworthy condition and safe for flight based upon the UAV’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a), specific to UAV , in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

6. Reasons Why An Exemption From The Requirements Of Section 91.119(c) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.119(c) will be maintained given the size, weight, and speed of the UAV as well as the location where it is operated. No flight will be taken without the required local and ATC coordination. Due to the advance notice to the property owner and participants in the aerial activity, all affected individuals will be aware of the planned UAV flight operations. Additionally, the FAA has previously granted relief from Section 91.119(c), specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

7. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because all the UAV RainierDrones.com LLC proposes to operate are equipped with a digitally encoded barometric altimeter and GPS triangulation equipment, with a zero altitude initiation point being established prior to each flight. As such, the PIC on the UAV is provided the altitude of the UAV above ground level (AGL) via a heads-up display of the ground control station (GCS).

Page of 20 22Additionally, the FAA has previously granted relief from Section 91.121, specific to UAV
, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

8. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.151(b) will be maintained because the operator will always have detailed information on the charge and state of the battery, and preset battery failsafe’s will prevent any loss of flight control due to power loss. The ground control station (GCS) for each SOLO UAV provides a battery indicator on the heads-up display, which indicates the UAV’s current remaining battery power measure in volts, and thus provides the PIC with constant awareness of the real-time battery voltage during a flight. Additionally, the FAA has previously granted relief from Section 91.151(b), specific to UAV, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). These previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAV are considered.

9. Reasons Why An Exemption From The Requirements Of Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, RainierDrones.com LLC submits that an equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b) will be met because RainierDrones.com LLC and the manufacturers of each aircraft, will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAV using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, RainierDrones.com LLC will document and maintain all maintenance records for each of the individual aircraft. Since each UAV will be inspected as prescribed by the manufacturer’s maintenance manual, RainierDrones.com LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2).

Additionally, the FAA has previously granted relief from Section 91.151(b), specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). These previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAV are considered.

Page of 21 22F. Summary That Can Be Published In The Federal Register. The Rules From Which RainierDrones.com LLC Seeks Exemption: RainierDrones.com LLC seeks exemption from the requirements of 14 C.F.R. Sections 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b. A Brief Description Of The Nature Of The Exemption RainierDrones.com LLC Seeks: This exemption will permit RainierDrones.com LLC to commercially operate Unmanned Aircraft Vehicles for the purpose of conducting photography, outdoor videography, property inspections, and agricultural inspections/ mapping within the United States.

G. Any Additional Information, Views, Or Arguments Available To Support RainierDrones.com LLC’s Request. This Petition is made pursuant to the FAA modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, RainierDrones.com LLC’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAV will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security, and further, provides the authority for such UAV to operate without airworthiness certification. As discussed in detail above, RainierDrones.com LLC will operate the specified UAV’s safely in the NAS without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, RainierDrones.com LLC seeks an exemption pursuant to 14 C.F.R. Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3D Robotics Solo UAV’s commercially, without an airworthiness certificate, for the limited purpose of conducting photography, outdoor videography, property inspection, and agricultural inspection/mapping within the stated operational guidelines. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing RainierDrones.com LLC to safely, efficiently, and economically operate these UAV’s commercially within the NAS.

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