April 13 , 2015

U.S. Department of Tran sportation, Docket Operations West Building Ground

Floor, Room w12 -140

1200 N e w Je rs ey Av e., S E Washington, DC 20590

Re : Petition of Coleman Engineering Company fo r an Exe mp tion Pu rsuant to S ec tion 333 of

the FAA Modernization and Refo rm A ct of 2012

D ea r Madam/Sir,

Pu rsuant to S ec tion 333 of the F AA Modernization and Re fo rm Act of 2012 (“Reform Act”) and

14 C. P.R. Pa rt 11, Coleman Engineering h ereby applies for an

exe mp tion from the Fe deral Avi ation Regulations identified below, to allo w commercial op erations of small unmanned ae rial vehicle s.

This exe mp tion is made b ased on information outlin ed in this petition, as we ll as the

acc ompanying DJI Ph antom 2 Op erators Manu a l (Appendix B) and the Coleman Engineering Op erational Limitations (Appendix C). The DJI Ph antom 2 UAS was sel ected b eca u se it has a

prov en ca pability for controlled flight as we ll as a gyro stabilized flight mode, GP S aided

nav igation, a compass, blinking L ED ’s on the bottom, a fa ilsa fe mo de for returning home, and

prop guards. Th e se d evices are offered for general sale around the wo rld and have often b ee n used as Model A ir craft in the USA.

The Requested exemption would authorize commercial operations using the DJI Phantom 2 for mapping and surveying applications. These operations will be subject to strict operating requirements defined in the user manual and conditions defined by the Safety Code of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level

of sa fety to currently authorized operations using manned aircrafts.

Sp ec ifically, the UAS is:

A lightweight (< 7.0 lb gross weight with all on -bo a rd equipment), battery o p er ated 4-

motor roto rc raft in the fo rm of a qu ad co pter that ta kes off and lands ve rt ically,

manu fac tu red by DJI, Mo de l Ph antom 2 , with the following equipment:

 An on-bo ar d flight computer with G PS n avigation and location ability that

re ce ives signals for flight controls from a ground-based transm itt er /controll er ;

 An on-bo ar d c am era ca pable of ca

pturing imagery in the form of full color, high definition still photos and video;

 An on-bo ard telemet ry system that d e liv ers flight d a ta fr om the on-boa rd flightcomputer to the on -boa rd ra dio transmitter including a ltitu de AGL, h o ri zontal

and v er ti ca l speed, compass dir ec tion of flight and direction back to i ts launch site;

 A 600mW, 5.8GHz on- bo a rd ra dio t ra nsm itt er th at t ra nsmits live video fro m the onboa rd ca me ra plus a ll the f li ght d a ta fr om the telemetry system described above;

The Gro un d S ta tion I nc l ud e s:

 A Pilot in Command (PIC) in op er ational cont rol of a flight operation from

b eginning to end and who con trols the UAS while in the air;

 A 100mW, 2.4GHz ra dio t ra nsm itt e r/ con trolle r op er ated by the PIC to control

the UAS while in f

li ght;

 A ra dio r ece iv er r ece iving live video and flight data fr om the on-boa rd

ca m er a and compu te r pro jec ts it all together onto a screen for th e PIC to view during fligh t;

 A Visual Obs er

v er (V O) is a person who p rovides a second p air of eyes to visually tr ac k the UAS while in flight.

Pro posed Op er ations

Coleman Engineering in tends to use UAS in two genera l areas. First, Coleman Engineering

seeks an exe mp tion to p erfo rm vid eo filming and photog ra phing by a ir

for public and priva te

use. The purpose of this photography will be to aid in topographic mapping of ground based

features on the earth. S ec ond, it will e mp loy UAS’s to inspec t lan d, resid ential, comme rc ial

, industrial structure s and prop erty.

Sp ec ifically, Coleman Engineering will use UAS’s that are equipped with ca me ra s and

senso rs in order to engage in the following com me rcial ac tivities:

(a ) Taking photographs to support pro fe ss ional operations in engin ee ri ng, land

su rveying, archit ec ture, r ea l estate and other related professiona l ac tivities.

(b) Insp ec tions by air of agricultura l area s.

(c ) Inspe ct ions by air of in frastru c tu re such as bridges, high ways, electrical installations,

d a ms , aqueducts, photovoltaic po we r stations, wind farms and pipes. Th e se inspections

will on ly be done under contr ac t with the owners or with any local government authority.

(d) Insp ec tions by air of land and residential, commercial and industrial structure s,

on ly und e r contr ac t with the o wn ers or with any lo ca l government authority.

(e ) Insp ec tions by air to de te ct sour ces of pollution and gas emissions, unde r contr ac t
with the owners in the area or with any lo cal government autho rity.

(f ) Support provided to s ea rch and resc ue o perations an d recon na is san ce in cases of n ee d,

e me rgency or na

tu ral disasters and on ly when go vernment autho rities have requ ested it by

contract or donation.R elevant Statu to ry Authority

This Petition fo r Exe mp tion is submitted pursuant to S ec tion 333 (a ) thro ugh (c) of the FA A
Modernization and Reform A ct of 2012 ("Re fo rm Act"). Cong re ss has directed the F AA "to safely

a cce lerate the inte gration of c iv i l unmann ed a ir craft systems into the n ational airspac e system."

Pu rsuant to S ec tion 333 of the Re fo r m Act, the F AA Administr ator is to permit unmanned a ir craft

sy st ems to op erate in the Na tion al Air Sp ac e (" N AS ") wh e re it is safe to do so b as ed on the following considerations:

• The UAS’s size, weight, sp ee d and operationa l cap ability;

• Operation of the UAS in close proximity to ai rpo rts and populated ar ea s; and

• Operation of the UAS within the visua l line of si ght of the operator.

Addition ally, the FAA Administr ator h as gen eral authority to grant exe mp tions from the agen cy's
safet y re gulations and minimu m st and ards wh en the Administr ator d ec ides a requested

exe mp tion is in the public in terest. See 49 U.S.C. § 106(f) (d efining the authority of the

Administr ator); 49 U. S.C. § 44701 ( f) (permitting exe mp tions from§§ 44701 (a), (b) and§§ 44702-44716,et seq.). A p art y requ e st ing an exe mp tion must explain the reasons why the exe mp tion: (1) would benefit the public as a wh o le, and (2) would not adv e rs ely aff ec t safety (or how it would

p rovide a level of safety at le a st equ al to the ex is ting ru les). See 14 C. F.R. § 11.81 (petitions for exe mp tion).

Coleman Engineering’s Pro posed UAS Op er ations Mee t the Re qu ir e me n ts of S ec tion 333 of the

R efo rm Act

Coleman Engineering’s p rop osed op erations in th is Pe tition for Exe mp tion qu al if y for exp edite d approval pursuant to Se ction 333 of the Re fo rm Act as e ac h of the statutory criter ia and

relevant f ac tors a re satisfied.

Ap proval is Wa rr anted Based on the UAS S iz e, W e ig ht, Sp ee d, and Operat io nal Ca pa bility

Coleman Engineering will e mp loy the DJI Ph antom 2 qu ad copters fo r the operations specified i n th is Petition for exe mp tion. The Ph antom 2 UASs have a ma ximum take-o ff weight of less than 7 pounds, the flight sp eed will not ex cee d 35 miles per hour, and it will not be flown in controlled airsp ace or at an altitude that ex cee ds 400 feet AGL. All flights will be flown in such a way that th ey

ca n be safely terminated with a reserve battery power of 25% of the battery's maximum cha rg e. The

DJI Phantom 2 UAS do not ca rry any flammable propellant or fu e l. The Ph antom 2 UAS also has

an in teg ra ted GPS system that ca lculates the UAS ’s position and h eight and relays that information

via a s ec ur e conn ec tion to the operator. Addition ally, the Ph antom 2 UAS contain a failsafe mode if

its conn ec tion to the remote control is lost, and th i s system permits the UAS to return to a pred etermined

location and

land without in

ju ry or d amage.

Ap proval is Wa rr anted Based on the Op er at io nal R e st r ic t io n s Set Fo rth in the Op er at io ns Ma nu al.

Colman Engineering’s Op erations Limitations and the DJI's o perators manual contain a ll of the

p ro ce dures and limitations n ece ssa ry to succe ss full y perfo rm the op erations specified in th i s Petition

fo r Exe mp tion. (Appendices B & C).P ub lic Inte re st

The public in terest will be se rv ed by g ra nting Coleman Engineering’s Petition fo r Exe mp tion. Congre ss has established a n ation al policy that fa vo rs early in te gration of U AS ’ s into the NAS in controlled, safe wo rk ing environments such as those proposed in this Petition. In addition, the public also has an interest in red ucing the h a za rds associated with al te rnate methods of conducting

si m ilar op erations. Currently operations are cond ucted using teams th at phy si call y climb onto

stru ctures usi ng ladders, using low flyi ng h elicop ters or aircraft, or simply not available by

tr aditional me ans. By using UAS, exposu re to physi ca l hazards will be re du ce d of conducting the

op eration while re maining sa fe ly on the ground.

Addition ally, Coleman Engineering’s intend ed uses for the UAS’s have identi fi able safety b enefits

th at include re du cing the dange r and emi ss ions associated with full s iz e h elicopters. UAS h ave no fu e l to ignite or explode, no cre w, adds a greater deg re e of flex ib ility wh ich supplements the cu rre nt

ca pabilities of

fe red by mann ed a ir craft, and public in terest for a gro und imp ac t of a small lightweight

UAS is further minimized from an ec ological and safety standpoint.

Fe de ral Register Su mm ary

Pu rsuant to 14 C. F.R. Part 11, the following su m ma ry is provided for pub l ic ation in the

Fe d era l Re g is ter, should it be d e te rmin ed that publi ca tion is n ee ded:

Coleman Engineering seeks an exe mp tion from the following rules:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b)

The exe mp tion will enhan ce sa fety by re d ucing risk to the general publ ic and prop ert y owners from the substantial hazards associ ated with per fo rming equivalent work with

conv ention al aircraft, rotorcraft, or other methods.

Conclusion

Coleman Engineering’s Petition fo r Exe mp tion satisfies the criter ia articulated in S ec tion

333 of the Refo r

m Act of 2012 including weight sp ee d, op erating ca pabilities, proximity to airports and populated ar ea s, operation within visua l line of si ght and nation al secu rity. Addition ally, the Petition provides more than adequ ate justification fo r the grant of the requ ested exe mp tions to p ermit Coleman Engineering to operate the se le cted UAS for the op erations specified herein.

G ra nting the exe mp tion will benefit the public in terest as a whole in several ways, includi ng (1 )

si gnifi ca ntly improving safety and reducing risk by alleviati ng human expo su re to danger, and (2)

i mp roving the quality of servi ce s and dec re asing op erating costs compared with conv ention al flight

o perations.

With the advent and availability of this technology surveying and mapping functions are changing from a traditional ground based operations to the aerial platform. Coleman Engineering will have the ability to collect a tremendous amount of data in a small fraction of the time that would be needed for ground based efforts. As project sizes increase, the savings to both Coleman Engineering and our Clients will increase greatly. The cost of purchasing our DJI Phantom 2 is next to nothing incomparison to that of a traditional manned aircraft. A major advantage of the low operational

expenses is that Coleman Engineering can provide these aerial acquisition services at a much lower cost to the consumer while remaining competitive and profitable. This will in turn lead to economic growth and stability at a local, state and federal lever.

Coleman rea li zes that other survey and engineering firms have already been granted an exemption touse there UAS for commercial purposes, as shown in FAA exemption No. 11266, Docket No. FAA2014 -0733 & FAA exemption No. 11285, Docket No. FAA-2014 -1015 & FAA exemption No. 11299, Docket No. FAA-2014-1008 & FAA exemption No. 11302, Docket No. FAA-2014 -1032.

With the DJI Phantom 2’s small and lightweight design it can be assembled and deployed in a manner of only a few minutes once the survey crews arrive on site. It will perform its mission effectively and efficiently and land directly at our feet. The data we collect will be able to be processed immediately. All of these factors prove to be a huge benefit to the consumer, and help advance the land surveying profession to a whole new level.

Very Respectfully,

James D. Blondheim

635 Circle Drive Iron Mountain, MI 49801 jblondheim@coleman-engineering.com (906) 774-3440

### Appendix A

The regulations f

rom w h ich the exemption is requested ar e listed b elow. Beside eac h regulation number is the p age of the a tt ac hed Ap pendix A upon which eac h may b e found

to ge th e r with our propo sed equival ent lev el of safety for e ac h regulation:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b)

Ex emptions Re qu ested

The Fe deral Aviation Act exp re ss ly grants the FAA the authority to issue exe mp tions. Thi s statutory authority, by its te rms, in cludes exe mp ting c iv il aircraft, as the term is defined unde r§
40101 of the Ac t, in cluding UASs, from its sa fe ty re gulations and min imum standards wh en the

A dministrator d ec id es a re quested exe mp tion is in the public in terest.

Coleman Engineering seeks an exe mp tion from sev era l interrelat ed provisions of 14 C. F.R. Parts 21, 27, 45, 61 and 91 for pu rposes of condu cting the requested operations usi ng a UAS. L is ted below a re the

sp ec ific s ec tions of 14 C.F.R. for which exe mp tion is sought:

14 C. F. R. Part 21, Subp a rt H - Ai rwo rthine ss C er ti fica te s

The F AA has stated that no exe mp t ion is n ee ded from th is s ec tion if a fi nding is made und er the Re fo rm Act that

the UAS se le cted p rovides an equivalent level of safety w he n compa re d to

a ir cra ft normal ly used

for the sa me appli ca tion. ( Regulato ry Do ck et No. F AA

2014-0352). Th e se criter ia a re me t, and th erefo re no exe mp tion is n ee ded.

E qu ivalent Level of Sa fety

The UA S selected by Coleman Engineering is safe when taking into a cc ount t he ir size, weight,

s pe ed

, and operational ca pabil it y. The UA S weighs less th a n 7 pounds and w ill be flown at less

th an 35 miles per hour a nd complete ly outside contro ll ed ai rs p ac e. Additionally, the UA S ca rry

n e ith er pilots nor pa ss engers, ca rry no explosive materia ls and or fla mm able liquid fuels, and

op era te exc lu sive ly

within the pa ramete rs stated in the Operator’s Manu al and Op er at ions

Limit at ions.

Operations under this exemption will be c lo se ly controlled and monitored by the op erator and will be

conducted in co mp liance w ith lo ca l public safety requirements, to provide secur it y for the area of

op eration. Coleman Engineering will also, if necessary, provide the FAA w ith advance notice of all

op erations v ia NO T AM S and in coordination wi th the lo cal FSDO. In al l ca ses, the UA S operated under the proposed conditions will be at least as safe as, or safer th an, conventional ro torcraft operating

with an airworthiness ce rtifi ca te without the res tr ictions and conditions of the pr opo sed UAS

op er at ions.

14 C.F.R. Part 27 Airworthiness S ta nd ar ds : Normal Category Rotorcraft

14 C. P.R. Pa rt 27 se ts forth the procedural requ ir ements for airworthiness certifica ti on of nor mal

ca tegory ro torcraft. To the extent th at Coleman Engineering UA S would othe rw ise require

ce rtifi ca tion under Pa rt 27, we seek an exemption f rom Part 27 's airworthiness standa rd s for the sa me

r ea sons identified in the request for exemption f rom 14 C.F.R. Pa rt 21, Subpa rt H.14 C. F.R. §§45.23(b), D is play of ma rks; ge ne ral

Th e se regu lations provide that eac h aircraft must display "N " and the aircr af t's reg is tration numbe r in le tt ers at l ea st 2 inches high. Additionally, the aircraft must disp lay the wo rd

"EXPERIMENTAL" in le tt ers at l ea st 2 in che s h igh n ea r the entrance to the ca bin, cockpit, or pilot station. The UAS do es not have an entrance in which the wo rd " EX PERIMENTAL " ca n b e pla ce d, and may not have a registration numbe r as si gn ed to it by the F AA.

Coleman Engineering p ro p oses to ac hieve an equivalent level of safety by including the word "EXPERIMENTAL" as large a s p ract ic able on the top of the aircraft, wh er e the PIC, V O and

others in the vicinity of the aircraft while it is p re p aring for lau nch will be able to see th e d e si gn ation. Final ly, the ground station will display a h igh contra st flag or b anner that cont ains the

wo rds "Unm ann ed Aircraft Gr ound Station" in le tt ers 3 in ch es high or greater. Sin ce the ai rc raft will opera te wi th in 3/4 NM of the ground station, the bann er should be visible to anyone that

obs er v es the air cr aft and chooses to inv e st igate its point of o rigin.

In a previous Grant of E xe mp tion, Regula to ry Do cket No. F AA -2014 -0352

, the F AA de te rmin ed

that exe mp tion from th e se re quirements wa s warranted provided tha t t he a ir craft "have

identifi ca tion (N-Numbe r) ma rkings in acco rd ance with 14 C. F.R part 45, Subpart C if the

ma rkings are as large as p racti ca ble."

14 C FR § 61.113 (a) a nd (b ); 61.3 (c

, 2 -v ): Pr iv ate Pilot Pr iv ileges a nd Li mitat io ns, Medical

C er ti ficate

In addition, Coleman Engineering se eks exe mp tion from 14 C. F.R § 61.113, which restricts priv ate pilot certifi ca te holders from flying aircraft for compensation or hire, and which would also require

a se cond class medical certificate. The pu rpose of th is section is to ensure the skill and compet en cy of any PIC wh e re the a ir craft is carrying p a sse ngers or ca rgo for hire. In thi s case, while the UAS will be op erated as part of a commercial operation, it ca r ri es n eith er pa sse ngers nor cargo. In the

G rant o f Exe mp tion in F AA Do ck et No. FAA-2014-0352, the F AA de te rmin ed that the unique

ch ar ac teristics of UAS ope ra tion outside of controlled airs p ac e did not war ra nt the addi ti on al cost

and restrictions attend ant with requiring the PIC to have a commercial pilot ce rtificate and cla ss II

medica l certifi ca te. Additionally, inst ea d of having a se cond or th ird class medi ca l, we suggest that

the PI C exercise the privileges similar to that of a sport pilot, requiring on ly a valid US driver’ s l ic ense.

Safety Mitigation

Coleman Engineering s ee ks to ensure sa fe operation by ensuri ng that any PIC is thorough ly

v ersed in airsp ace and communication issu es pertaining to all aircraft operators but also in the unique aspects of UAS flight.

W e believe the comb in ation of aer on auti ca l knowledge, UAS airmanship skill s, and v er ifi ca tion

th rough rema in i ng current is a su f fi cient method to ev a lu ate a pilo t’s qua li fi ca tions, g iv en tha t

op erations will be conducted within the limit ations outlined in th is petition. Like with any required skill, the more flight time the PIC gains, the more proficient the PIC becomes.14 C. F.R. § 91.7(a ) : Civil Ai rcr af t A ir wo rthine ss

Coleman Engineering seeks an exe mp tion from 14 C. F.R. § 91.7 (a), whi ch requires that a c iv i l a ir craft

be in ai r wo rthy condition to be op erated. The FAA has stated ( Re gula to ry Do ck et No. F AA -2014

- 0352) that no exe mp tion is required to the extent that the re quir ements of Part 21 are waived or found

i nappl ic able.

14 C.F.R. § 91.9 (b )( 2): C iv il Ai rcr a ft Flight Manual in the Ai rcr a ft

Given its s iz e, configu ration, and load ca p ac ity, the Phantom 2 has no ability to carry su ch a manua l

on the a ir craft, not only because the re is no pilot on board, but because the re is simp ly no ro om or

ca p ac ity to carry such an item on the a ir craft.

Safety Mitigation

The sa fe ty relat ed p urpose of this manu al requirement ca n be equally satisfied by ma in ta in ing the Phantom 2 Manual at the g ro u nd control point wh e re the pilot flying the Phantom 2 will have

immediate a cce ss to it. A cc o rdingly, we req uest an exe mp tion from § 91.9(b) (2 )'s flight manua l requirements, on the condition th a t the Ph antom 2 flight ma nu al be av ai la ble a t the p oint of control during each operation.

14 C. F.R. § 91.103: Prefligh t Ac tion

Coleman Engineering seeks an exe mp tion from 14 C.P.R.§ 91.103, whi ch requires a PIC to

b ec ome familia r with sp ec ific info rmation befo re each flight, in cludi ng information contain ed in

the FAA-approved

Flight Manual on bo ard the aircraft. While the PIC will be fa miliar with all

in fo rmation n ece ss ary to sa fe ly con du ct the flight, an exe mp tion is requ ested to the extent that an
F AA -approved Flight manua l is required.

Safety Mitigation

An equivalent level of safety will be prov ided by following the A ir craft Operations Manual and flight manu al provided by the m an ufacturer. The PIC will take a ll re qu ired pre fl ight action s, including p er fo rming a ll required ch ec klists and reviewing weather, flight requirements, bat te r y ch arge, landing and takeo ff distan ce , a ir craft perfo rmance data, and contin gency landi ng ar ea s b e fo re initiation of flight. The Op erators Manu al and Operation al Limitations will be k ept at the ground station with the op erator at all time s.

14 C. F.R. § 91.109(a ) : Flig ht Inst ruction

Coleman Engineering seeks an exe mp tion from 14 C.F.R. § 91.109 (a), which p rovides tha t "no p erson m ay operate a civ il a ir cra ft (ex ce pt a manned free balloon) that is being used fo r flight inst ru ction unless that a ir craft has ful ly functioning du al controls." UAS and re mo tely piloted a ir craft, by their d esign, do not have fun ctional dual cont rols. Instead, flight cont rol

i s acc omplished through the use of a device that communicates with the a ir craft via radio

communications.Safety Mitigation

Giv en the size and sp ee d of the UAS employed by Coleman Engineering, an equivalent level of saf e

tr a in ing can still be perfo rm ed without du al cont rols be ca use no pilot or passengers a re ab oard the UAS, and a ll p ersons will be a sa fe distan ce away in the ev ent th a t the UAS en counters any difficulties during flight instruction. In addition, we will co ndu ct flight tra in ing at our Res ea rch and

Dev elopment test sites, which a re lo cated on our own property. Th e se tr a in ing flights will be

conducted in a st e rile area and will otherwise comply with the prov is ions in the Operator’s Manu a l

for flights at the R&D facility. The F AA h as stated ( Re gula to ry Do ck et No. F AA -2014 -0352) th at no

exe mp tion is required.

14 C. F.R. § 91.119: Minimum Sa fe Altit ud es

Coleman Engineering requests an exe mp tion from the minimum safe altitude re quirements of 14

C. F.R. § 91.119. S ec tion 91.119 p re sc ri bes the minimum safe altitud es unde r which aircraft

ma y not ope ra te, in cluding 5 00 feet above the surface and away from any p erson, vessel,

v ehicle, or structure in non-co nge st ed areas. Se e 14 C.F.R. § 91.119 (c ). S ec tion 91.1 19 (d)

allows for a h elicopter to operate a t le ss th an those minimum altitudes wh en it ca n be o perated "without hazard to persons or prop erty on the surf ace ," p ro v ided th a t "e ac h person operating the

h elicopter complies with any routes or altitudes specifically prescribed for helicopter by the

FAA.”

Safety Mitigation

Compa re d to flight operations with roto rc raft weighing far more than t he ma ximum w eights

p roposed h erein, and given the l ac k of fl ammable fu el, any risk associat ed with th ese

op erations is far le ss th an those that presently exist with conventional aircraft. An equivalent

lev el of safety will be achieved given the si ze, weight, and speed of the UAS, as we ll as the

location whe re it is ope ra ted. In o rd e r to avoid any risk to aircraft, flight op erations will be

restricted to 400' AGL or below.

14 C. F.R. § 91.121: Al timeter Settings

This petition seeks an exe mp tion from 14 C.F.R. § 91.121, which requires a p erson operating an

a ir craft to ma in tain cruising altitude or flight lev el by reference to an altimeter tha t is set to the

elevation of the departure airport or barometric pr essure. An exe mp tion is required to the extent
that the UAS do es not h ave a b arome tr ic altime te r, but rather a GPS altitude read out.

Safety Mitigation

The FAA has stated th at an equival ent lev e l of safety ca n be ac hieved if the UAS will be operated at

400' AGL or below and

within visua l l in e-o f- si gh t in addition to GPS b ased altitude information relayed in r ea l time to the op erator. See Grant of Exe mp tion to Astraeus Ae ri al, Docket No. FAA2014 -0352. As the attached Operations Manua l i ndicates, the cho sen UAS me ets th e se re quirements,

and a zero altitude in i tiation point will be obtain ed prior to flight14 C. F.R. § 91.151(a ) : Fuel Re qu ir e me nts for Flig ht in VFR Co nd itions

Coleman Engineering requests an exe mp tion from 14 C. F.R. § 91.15l( a)'s fuel requirements for flight in VF R conditions. S ec tion 91.151 states:

(a) No person m ay beg in a flight in an airplane und er VFR conditions unless (considering

wind and fo re ca st w ea th e r conditions) there is enou gh fu e l to fly to the fi rst point of

in tend ed landing and, assuming norma l cruising sp ee d -

(1) Du ring the day, to fly a ft er that fo r a t l ea st 30 minutes; or

(2) At night, to fly a ft e r th at for at least 45 minutes.

Here, the t ec hnolog ic a l limitations on UAS b atte ry power m ea ns that no m ea ningful flight

op erations ca n be conducted while st i ll maintaining a 30 minute reserv e. Coleman Engineering p roposes that all flights comply with this requirement by mandating tha t t he

a ir craft be safely landed with no le ss th an 25% of b attery l if e re ma ining.

Safety Mitigation

The FAA has stated th at an equival ent lev e l of safety is provided if the UAS flight i s

te rminated with a t l ea st 25% re serve b at te ry power still available. See G ra nt of Exe mp tion to

Astr ae us Ae ri al, Do cket No. PAA-2014 -0352. The Op erations Manu al con fo rms to this limit,

p roviding an equival ent lev el of s afety.

14 C FR 91.203(a) & (b) Civil air cr aft: C ert if ic a t io n s re qu i re d.

The regulation provides th at an a ir worthiness c er tifi ca te, with the reg is tration number a ss igned to

the aircraft and

a reg is tration ce rtifi ca te must be aboard the aircraft. Additionally, subparag ra ph (b) p rovides that the a ir

wo rthiness certifi ca te be "d is p layed at the ca bin or cockpit entrance so that it is legible to pa sse ngers o r crew."

At a maximum gross weight of le ss than 7 pounds, the UAS is too sma ll to car ry document ation, doe s not have an entran ce , and is not capable of ca rrying pa ss engers or cre w. To o btain an equival ent lev e l

of safety and mee t the in tent of 91.203, we propose that documents deemed approp riate for this ai rc raft by the F AA will be co-located with the cre w a t the ground con trol station and av a il able for insp ec tion

upon requ est. The F AA has stated ( Re gula to ry Dock et No. F AA -2014-03 52) that no exe mp tion i s required.14 C. F.R. 91.405 (a ); 91.407(a )( 1); 91.409(a)(2); and 91.417(a) and (b) Maintenance

R e qu ir ed

Coleman Engineering seeks an exe mp tion from the maintenance inspection requirements contain ed in 14 C.P.R.§ 91.405 (a ), 91. 407(a)(1), 91. 409(a)(2 ); 91.417 (a) and (b ). The se regulations specif y maintenance and insp ec tion standards in reference to 14 C.P.R. Part 43. S ee , e.g., 14 C.P.R. §

91.405 (a) (stating that ea ch owne r o r operator of an a ir craft " sh a ll h ave the a ir craft inspected a s

p re scribed in subpart E o f this part and sha ll b etw ee n required insp ec tions ...have discrepancie s

rep aired as prescribed in part 43 of th is ch apte r" ). An exe mp tion from th e se regulations is needed

b eca use Pa rt 43 and these se ctions only app ly to a ir craft with an airwo r th iness certificate, which

the U AS ’s will not have.

Safety Mitigation

An equivalent level of safety will be ac hieved b ec ause ma in ten ance and insp ec tions will be perfo rmed in acc o rd ance with the Op era to r s Man ual. As provided in the Op erato rs Manu al, flights will not be conducted unless a flight operations ch ec klist is per fo rmed that includes all of

the a ir craft's components.

### Appendix B:

### ANNEX B

### Academy of Model Aeronautics Na tional Model Airc raft Safety Code

Effective January 1, 2014

A. GENERAL : A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitation s of this code and is intended exclusively for sport, recreation

, education and/or competition. All model flights must be conducted in accordance with this safety code and any additional rules specific to the flying site.

1. Model aircraft will not be flown: (a) In a careless or reckless manner. (b) At a location where model aircraft activities are prohibited.

2. Model aircraft pilots will: (a) Yield the right of way to all human-carrying aircraft. (b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) (c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the ai rport operator. (d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. (e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. ( AMA Document 520-A.) (f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outs ide of the model aircraft. (This does not apply to model aircraft flown indoors.) (g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provision s of AMA Document #555. (h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pi lot’s ability to safely control the

model. (i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or d rops any object that creates a hazard to persons or property. Exceptions:

 Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight.

 Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flig ht. Model rockets may be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft.

 Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Progr am Document. (AMA Document #718.) (j) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510-A.)

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: (a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. (b) An inexperienced pilot is assisted by an experienced pilot.

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE app roved or comply with comparable standards.

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

2. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraft.

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) (a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. (b) At air shows or demonstrations, a straight safety line must be established. (c) An area away from the safety line must be maintained for spectators. (d) Intentional flying behind the safety line is prohibited.

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly licensed by the FCC are authorized to operate equipment on Amateur Band frequencies.

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA Documents #922 and #923.)

6. With the exception of events flown under official AMA Compet ition Regulations, excluding takeoff and landing, no powered model may be flown outdoors closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline.

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, exc ept to divert it from striking an

individual.

8. RC night flying requires a lighting system providing the pilot with a clear view of the model’s attitude and orientation at all times. Hand-held illumination systems are inadequate for night flying operations.

9. The pilot of an RC model aircraft shall: (a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses presc ribed for the pilot. (b) Fly using the assistance of a camera or First-Person View (F PV) only in accordance with the procedures outlined in AMA Document #550. (c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document # 560.

C. FREE FLIGHT

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function.

D. CONTROL LINE

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to fly ing. 2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precisio n Aerobatics. 4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to a ny above-ground electric utility lines. 5. The flying area must be clear of all nonessential participants and spectators before the engine is started.

### Appendix C Oper ational

Limitat io ns

1. The unmann ed a ir craft system ( UA S) wi ll weigh le ss th an 7 pounds, inc lu ding ener gy source(s)

and equipment.

2. The UAS will not be flown at a ground sp ee d ex cee ding 35 MP H.

3. F li ghts will be operated a t an altitude of no mo re th an 400 fee t above ground level (AGL), a s indi ca ted by the procedu re s sp ec ified in the operato r’ s manu al. All altitu d es re ported to ATC

must be in feet AGL.

4. The UAS will be op erated within visu al line of si ght (VLOS) of the PIC a t a ll t im es. Th i s

re qui re s the PIC to be ab le to use human vision u na id ed by any d evice other th an corrective

lense s.

5. All operations will utilize a visual obs er v er (VO). The VO may be used to sa tis fy the VLOS

re qui re ment as long as the PIC a lw ay s ma in tains VL OS ca

pability. The V O and PIC must be

able to communi ca te v er

bally a t a ll t im e s.

6. Prior to eac h f

li ght the PIC will insp ec t the U AS to ensure it is in a condition for sa fe f li ght. I f the insp ec tion re v ea ls a condition tha t af fe cts the s af

e op eration of the UAS, the a ir craf t i s

p rohib it ed fr om operating unti l the n ece ss ary maintenance has b ee n performed and the UAS is

found to be in a condition for s af e f li ght. The Ground Control Station, if utilized, will be

in cluded in the preflight insp ec tion. All ma in ten ance and a lt erations will be p rop er ly

do cumented in the a ir craft reco rds.

7. If the UAS h as undergo ne ma in ten an ce or a lt erations tha t af fe c t the UAS op eration or f li ght

ch aract er isti cs, e.g. repla ce ment of a f li ght cr it i ca l component, the UAS will und er go a fun ctiona l test f

li ght in acc o rd an ce with the op era to r’ s manu al. The PIC who conducts the

fun ctiona l te st f

li ght will make an entry in the UAS a ir craft reco rds of the f li ght. The

re quir em ents and p ro ce du re s for a fun ction a l tes t flight and a ir craft reco rd en try will be add ed to the opera to r’ s manu a l.

8. The operator wi ll follow the manufacturer’ s U AS a ir craf t/ component, ma in ten an ce , ov er h aul,

re pl ace ment, insp ec tion, and life limit re qui re me nt s. Wh en un av a il ab le, a ir craf t

ma in ten an ce /componen t/ ov er h aul, re pl ace ment, and insp ec tion/maintenance re qui re ments will

be e st abli sh ed and identified in the op era to r’ s manual. At a minimum, re q ui re ments for the following w il l be in c lu d ed in the op era to r’ s manu a l:

a. Ac tu a to rs / S er

vos;

b. T ra nsmi ss ion ( si n g le roto r) ;c. Po werplant ( moto rs);

d. Prope ll er s;

e. El ec tronic sp ee d controll er ;

f. Ba tt er ie s;

g. M ec hani ca l dyn a mic components ( si n g le roto r) ;

h. Re mo te command and control;

i. Ground control station ( if used ) ; and

j. Any other compon ents as det er min ed by the opera

to r;

9. The Pilot In Command (PIC) will po sse ss a t least a valid U.S. d river’s licen se.

1 0

. Prior to operations th e PIC will h ave acc umulated and logged, in a manner consistent with

14 CFR § 61.51 (b ), a minimum of five hours a s UAS pilot op erati ng of the make and model of

UAS to be util iz ed for op erations and th re e tak e-o ff s and th re e landin gs in the pre ce ding 90 days. T raining, p ro ficiency, exp e ri en ce -building, and take-off and landing cu rre n cy f li ghts ca n be conducted to acc omplish the re quired flight cycles and flight time.

11 . The UAS may not be op erated directly ov er any p er son, ex ce pt authori ze d and consenting

p er sonnel, below an altitude th a t is haz ar dous to p er sons or prop er ty on the su rface in the ev ent
of a UAS fa ilure or em er gency.

12 The op erator wi ll en su re th at no p er sons ar e allow ed within 500 feet of the area ex ce pt those

consentin g. This p rovision ma y be re du ce d to no le ss th an 200 fee t if it would not adv er sely affec t safety.

13 . The UAS wi ll abo r t the f li ght in the ev ent of unp re dicted obst ac les or em er gen cies in acc ordance

with the Op era to r’ s Manu a l.

14 . E ac h UAS operation will be completed with in 30 minute s f li ght time or with 25% ba tt ery powe r

re ma in in g, whi ch ev er o cc u r s first.

15 . The op erator wi ll ob tain an Air Tr aff ic Organ iz ation ( AT O) is su ed Certifi ca te of Wa iv er or Authorization (COA) prior to condu cting any op erations. This C OA will also re quire the
operator to re qu est a Not ic e to Airman (NOTAM) not mo re th an 72 ho u r s in adv an ce , but not

le ss th an 48 hou rs prior to the operation.

16 . All a ir craft operated

in acc ordance wi ll be id entified by s er ial numb er , re g is tered in

acc o rd an ce with 14 CFR p ar t 47, and h ave id entifi ca tion (N- Numb er ) m ar k in gs in

acc o rd an ce with 14 CFR p ar t 45, Subp ar t C. M ar k in gs must be a s l ar ge a s prac ti ca bl e.17 . E ac h UAS operated will comply with a ll manufac tu re r Safety Bulletins.

18 . The ra dio fre qu en cy sp ec trum used for operation and control of the UA will comply with the

Fe d era l Commun i ca tions Comm is sion (F CC ) or other appropria te go v er nment ov er si ght agen c y

re qui re ments.

19

. At l ea st th re e d ays be fo re sch eduled flight, the operator w il l submit a wr itt en Plan of

A ctivi ti es to the lo ca l FS DO with ju risdiction o v er the area of p roposed fl ig ht ar ea . The 3- day notifi ca tion ma y be wa iv ed with the con cu rre n ce of the FSDO. The plan of ac tivi ti e s

must include a t least the followin g:

a. Date s and t im e s for a ll f li ghts;

b. Na me and phone number of the operator

c. Mak e, mode l, and s er ial or N-number of UAS to be used;

d. Na me and ce rtifi ca te number of UAS PIC involv ed

e. A statement th a t the o perator has obta in ed p er mission fr om prop er ty own er s and/or

lo ca l o ff icia ls to conduct the flight op eration s ; the list of those who ga ve p ermi ss ion

must be made av a il able to the insp ec tor upon re q uest;

f. Sign a tu re of exe mp tion-holder or re p re sentative ; and

g. A des cr ip tion of the f li ght ac tivity, includi ng maps or di ag ra ms of any area, city, town, county, and/or state ov er whi ch fli gh ts will be condu cted and the altitud e s e ss entia l to

acc omplish the oper at io n.

2 0 . The documents re qu ired under 14 CFR §§ 91.9 and 91.203 will be available to the PIC a t the

Ground Control Station of the UAS any time the a ir craf t is opera tin g.

2 1

. The UA will re main cl ea r and yie ld the right of way to a ll oth er man ned op erations and ac tivitie s

at a ll t im e s ( in clud in g, but not limited to, ultralight v ehicle s, p arachute ac tivi ti e s, p ar as ailing

ac tivi ti es, hang g lid ers, etc.).

22

. UAS operations wi ll not be condu cted du ring n ight, as d ef

in ed in 14 CFR § 1.1. All operations

will be cond

ucted und er visu al meteo rologi ca l conditions ( VM C). F li ghts und er sp ec ial vi su a l flight ru le s (SVFR) ar e not autho ri ze d.

2 3 . The UAS wi ll not be op erated by the PIC fr om any movi ng d evice or vehicle.

24

. The UAS will not be op erated le ss than 500 f

ee t b elow or le ss than 2,000 feet horizontally fr om

a cloud or when visibility is le ss th an 3 statute mile s fr om the PIC.

25 . The UAS will not opera te in Cla ss A, B, C, or D air sp ac e without wr itt en app rov a l fr om the FAA.

The UAS ma y not op era

te within 5 n auti ca l miles of the geog ra phic center of a non-tow ered airpo r t as denoted on a cu rre nt F AA -publi sh ed aeron auti ca l ch ar t unless a le tt er of agreementwith tha t airpo rt’ s m an agement is obta in ed, and the operation is condu cted in acc ordance with a

NOTAM a s re qui re d by the op era to r’ s COA. The le tt er of agreement with the airpor t

man agement must be made av a il able to the Adm inist ra tor upon re quest.

2 6. Any in c id ent, acc id ent, or f li ght operation th at t ra nsg re ss es the lateral or v er ti cal bound ar ies of the operation a l area as def in ed by the appli ca

ble COA will be re po rted to th e F AA ’s UA S Integ ra tion O ff ice (AFS-80) within 24 hour s.