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Kevin D Hubbard Ravenwood HD Services, LLC 13870 East River Vista Circle Palmer, AK 99645 (907)631

- 8791 Ravenwood.HD.llc@gmail.com
April 2, 2015
U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Request for Exemption Per PL 112

- 95 §333 from 14CFR 21 Part H, 14CFR 61.3, 14CFR 61.113, 14CFR 91.11 9, 14CFR 91.121, 14CFR 91.151 , 14CFR 91.405, 14CFR 91.407 , 14CFR 91.409, 14CFR 9 1.417

Please consider this a request for an exemption of the above applicable sections of 14 CFR for Ravenwood HD Services, LLC (hereafter ‘ Ravenwood ’) for the purpose of conducting commercial aerial survey and photography operations with its small Unmanned Aircraft System (sUAS) within United States airspace. The employment of sUAS platforms for these missions should provide the FAA with good cause to find that these operations enhance safety by eliminating the need to use conventional aircraft in t he sometimes unique environments where a small Unmanned Aerial Vehicle (sUAV) would be particularly adept, but a conventional aircraft may pose a hazard to its crew and those on the ground.

Ravenwood requests exemption from the following applicable regul ations, pursuant to the Administrator’s authority to grant exemptions contained in 49 U.S.C. §106(f), 40113, and 44701:
14 CFR 21 Part H 14 CFR 61.3 14 CFR 61.113, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151 , 14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.4172 | Page

CORPORATE EXPERIENCE (14 CFR 61.3 and 14CFR 61.113 ) The operational staff of Ravenwood is comprised of aviation professionals with varying degrees of experience. All Ravenwood operators have at a minimum passed an FAA Private Pilot Ground Sch ool course, completed the Ravenwood sUAS training course, and hold at least an FAA third class flight physical. The princ ipal (Chief) Operator is an FAA

-trained air traffic controller with more than 22 years’ experience in aviation safety. He has been a

certified professional controller at 3 Air Traffic Control Towers and Multiple radar facilities. He also has passed an FAA part 141 ground school at the University of Alaska Anchorage (UAA)(which included 2 hours in a full motion flight simulator) and is pursuing a Private Pilot Certificate and a Bachelor of Science degree in aviation management. He has more than 100 hours of flight time in small aircraft in Alaska, although none of it was as Pilot

- In

- Command. (PIC) He also completed the first ‘Introduction to Unmanned Aircraft Systems’ course offered by UAA. A complete resume is available upon request. This combination of experience and education provides a greater level of understanding and safety for the operation of a sUAS in the National Airspace System (NAS) than simply possessing a Private Pilot Certificate.

OPERATIONS Ravenwood operations utilize a sUAS in a manner that provides services not offered by manned aircraft and enhances the level of safety beyond which can be accomplished by manned aircraf

t. Examples of the proposed aerial photography operations include real estate, insurance damage assessment, and incident/accident documentation. Most operations restrict the use of the sUAS to a small area typically encompassing a limited number of residential and commercial properties at a time. The structures on these properties provide sufficient
p rotection from the sUAV, and photography can be completed with much less risk than what would be incurred in a manned aircraft operation at low altitudes. Our intended film production operation would typically include both photography and videography for commercial purposes including wedding and corporate events. These events are restricted to only the invited participants and are closed to the general public, providing the opportunity to operate only in an area where informed, consenting participants and personnel are present. Ravenwood will be able to provide a level of safety equal to or greater than the manned aircraft that would typically provide these servi ces. Finally, our survey operation includes the orthomosaic mapping of agriculture, construction, and industrial sites utilizing our sUAS rotorcraft flying pre

- programmed grids that can be interrupted and returned to a safe landing zone by our operators at any time. Currently these operations are executed by manned aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes and speeds in excess of 75 miles per hour. Our operation would greatly increase the level of safety, replacing manned aircraft with a sUAV3 | Page

weighing less than 7.5 pounds which carries no fuel, and restricted to speeds no greater than 40 knots. These sites are areas that can readily be secured by Ravenwood personnel and will not provide any additional risk to the gen eral public.

Flight Safety All Ravenwood HD Imaging operations will be performed by Ravenwood HD Services llc trained and certified operators that have at minimum passed an FAA Private Pilot Ground School and hold a current FAA class 3 medical certificate. Operators, Visual Observers and where necessary Site Security Coordinators will participate in a preflight safety briefing for each mission. The mission will be executed only after a safety assessment has been completed and Threat/Error M itigation s are in place. Any operations under the exemption will be conducted in accordance with the Ravenwood Flight Operations Manual

.

Aircraft Ravenwood HD Imaging will operate variations of the 3D Robotics X8+, an eight motor rotorcraft. The X8+ is a commercially available, off

-the

- shelf sUAS. The X8+ is a rotorcopter configuratio n and will weigh no more than 7.5 pounds. The X 8+ will operate no faster than 4 0 knots groundspeed. The X8+ is agile, having the ability to hover, and move about its three axes simultaneously. The X8+ will be operated below 400 feet Above Ground Level (AGL) and continuously within the operator’s line of sight, so as not to create a hazard t o users of the NAS or public. The X8+ is equipped with failsafe protocols that can either return the aircraft to a predetermined point and land, or land immediately if that action has been deemed safer by the operator in the preflight planning. Because of the X8+’s specifications and flight characteristics, it poses no threat to national security.4 | Page

Limitations The limitations and conditions that Ravenwood HD Services, llc agrees to be bound to include: 1. The X8+ tak eoff weight will be less than 7.5 lbs. unle ss operating under an approved modification. 2. The X8+ will be operated at less than 40 knots groundspeed. 3. Flights will be operated within unaided visual line of sight of an operator and observer. 4. The X8+ will never be operated directly over a person, and will remain at least 100 feet from all persons. 5. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions. 6. Flights will be operated at an altitude of no more than 400 feet AGL. 7. Maximum total flight time for each operational flight will be 30 minutes. 8. Flights will be terminated at 20% battery power reserve should that occur prior to 30 minutes. 9. Minimum crew for each operation will consist of the sUAS Operator, the Visual Observer and may include a security coordinator. 10. The sUAS operator will be a Ravenwood HD Services trained operator and will maintain at least an FAA third class medical certificate. The observer will be a Ravenwood HD Services trained observer

. 11. A briefing will be conducted in regard to the planned sUAS operation prior to each flight. All Ravenwood personnel who will be participating in that flight shall be present for the preflight briefing. 12. When necessary, and at least 72 hours prior to flight, the operator will file FAA Form 7711

- 1, or its equivalent, with the appropriate Flight Standards District Office. 13. Observer and Operator will at all times be able to communicate by voice with each other. 14. Whe n necessary, permission from relevant property owner s will be obtained. 15. If the sUAS suffers a ‘lost link’, the X8+ will perform the predetermined flight maneuver to land as soon as practical as outlined in the preflight briefing. 16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergenci es

. 17. All accidents and incidents shall be recorded in the aircraft log and reported in accordance with FAA directives.5 | Page

X8+ CONTROL
The control of the X8+ will be through a Radio Transmitter and Receiver operating on frequency 915 Mhz. This frequency is FCC approved and provides more than adequate range for operations within line of sight of the operator. The X8+ sUAS is also equipped with flight telemetry radios for semi

- autonomous operation using highly precise GPS data, while maintaining a constant link between the X8+ vehicle and the ground station. The semi

autonomous mode of the X8+ is similar to a small manned aircraft operating with a 3 axis autopilot; operator input is still a function of the system. (Lost link procedures still apply)

X8+ PAYLOAD The X8+ manufacturer’s payload capacity is listed at 800 grams, which equals 1.7 6 lbs. The X8+ vehicle weight with battery is listed at 2,560 grams which equals 5.6 4 lbs. Specific payload configurations will result in variable payloads. Every flight payload will be documented in the aircraft log. Without a manufacturer’s approved modification, the X8+ will not be operated outside parameters set forth in the manufacturer’s handbook.

AIRWORTHINESS CERTIFICATION
The X8+ operated by Ravenwood HD Imaging ha s a manufacturer’s maximum takeoff weight of 3,360 grams (7.5 0 lbs.) fully loaded. It carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within visual line of site of the operator. Operations under this exemption will be tightly controlled and monitored by the operator. The X8+ has the capability to safely fly and navigate after a total loss of power to one motor; this would be catastrophic to a typical 4 motor rotorcraft. By nature of its operation, the X8+ provides a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14CFR Part 21.

NATIONAL SECURITY

There is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.6 | Page

FLIGHT CREW (14CFR 21 Part H) All flight crew members will su ccessfully complete the Ravenwood HD Services training program and operators will maintain at least an FAA 3rd class medical certificate. The Ravenwood HD Services training program has been developed referencing the curriculum already in place by the U.S. Department of Interior (DOI) for training their sUAV pilots. This curriculum is currently accepted by the FAA as valid for the initial qualification of sUAS operators. The full Ravenwood HD Services llc training program is proprietary in nature and is available to the Administrator upon request. The Ravenwood Operator will remain the individual in charge of each flight and will not transfer responsibility for operational control of the X8+ aircraft to any other person, unless the flight is specifically for training purposes and not for hire. Any flight for training purposes will include a visual observer that is fully qualified for that position. The Visual Observer will be trained in accordance with the Ravenwood HD Services llc training program and will possess a current valid driver’s license issued in the United States

. Ravenwood HD Services llc requests an exemption from 14CFR 21 Part H until such a time that it has been established that the Ravenwood HD Services llc training program is capable of full compliance with the regulation (Number of successful graduates, certification of instructors, etc).

CREW RESOURCE MANAGEMENT (CRM)

All Ravenwood flight crew members will actively practice CRM in accordance with FAA guidelines. Further gui dance and details are covered in the Ravenwood HD Services training
program.
PREFLIGHT ACTION
Prior to each flight, the operator must conduct a pre

-flight inspection and determine the s UAS is in a safe condition for 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 X8+ , the aircraft is prohibited from operating until the necessary maintenance has been p erformed and the X8+ is found to be in a condition for safe flight. After the pre

-flight inspection, the operator will conduct a pre

-flight safety briefing with the observer and all other participants.7 | Page

MINIMUM SAFE ALTITUDES (14CFR 91.119)

Ravenwood H

D Services llc requests authority to operate at altitudes up to but not exceeding 400 feet AGL. Ravenwood HD Services llc will maintain a safe operating area in order to protect structures and people not associated with the operation. At no time will the X 8+ be operated directly over a person. The X8+ will be operated at least 100 feet from all
persons. The X8+ will be continuously operated at an altitude which will allow a safe descent and recovery should a mechanical issue arise.

ALTIMETER SETTING (14CFR 91.121)

The X8+ utilizes a highly accurate GPS altimeter. An equivalent or greater level of safety is provided during preflight where the Ravenwood operator will compare the GPS altimeter with the pressure alt imeter for the nearest FAA METAR report and verify accuracy to within 50 feet as indicated on the applicable VFR sectional chart.

FUEL REQUIREMENTS (14 CFR 91.151 )
The X8+ is powered by a battery, which provides up to 30 minutes of powered flight. Because of the absence of flammable operating fluids, an X8+ does not pose the same level of risk as a conventional aircraft. All Ravenwood operators will terminate flights when remaining battery power level reaches 25%, or 30 minutes flight time is reached, whichever comes first after takeoff. Since no flights conducted by Ravenwood will require traditional petroleum based fuel, and those flights will be for less than 30 minutes, Ravenwood requests relief from 14CFR 91.151.

X8+ MAINTENANCE (14CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417) Ravenwood HD Services llc requests exemption from 14CFR 91.405, 14CFR 91.407, 14CFR 91.409 , 14CFR 91.417

. Ravenwood HD Services llc will conduct all maintenance on the X8+ in accordance with t he flight operations manual, pilot operating handbook , and any guidance received from the manufacturer

. Ravenwood HD Services llc will abide by all notices from the manuf acturer governing the maintenance, preventive maintenance, and alterations of the X8+.8 | Page

All maintenance will be conducted by a Ravenwood associate according to guidance from the manufacturer

. There is no certified FAA inspection process for sUAS’s, theref ore all inspections will be conducted by Ravenwood associates in accordance with manufacturer’s guidelines. These inspections will be conducted and documented after any maintenance and before every flight. A functional flight test will be conducted after m aintenance and before any flight for hire.

Summary Ravenwood HD Services llc intends to comply with every applicable regulation to the operation of the X8+ sUAS. Each request for exemption has been made with the understanding that Ravenwood is able to conduct operat ions that are at least as safe as or safer than those commercial operations that currently are conducted by manned aircraft. Ravenwood’s proposed exemptions and operational limitations are very closely aligned with other exemptions already granted, and also with pending proposed 14 CFR §91.107, which is specific to the operation of ‘micro’ unmanned aircraft. The proposed 14 CFR §91.107 has been attached for reference. Although the X8+ is above the weight restrictions for the proposed rule, it is applicable in nearly every other instance. In the event that 14 CFR §91.107 becomes effective, Ravenwood HD Services llc will be submitting a request to operate within those guidelines with minor exemptions to be addressed at a later date.

I appr eciate your assistance with this process, as I am aware of the massive undertaking that these exemption requests are. Please contact me at your convenience with any questions regarding this request.

Thank You,

Kevin D. Hubbard Managing Member and Chief Operator Ravenwood HD Services llc

Attached: Proposed 14 CFR §91.107, per UAS America Fund, llc X8+ Online Operating Manual: http://3drobotics.com/wp

- content/uploads/2015/04/X8

- Operation

- Manual

-vC.pdf9 | Page UAS America Fund LLC

Micro Unmanned Aircraft
Proposed Part 107
**§107.1 Applicability.** This part prescribes rules governing the operation of micro unmanned aircraft in the United States. For purposes of this part, a micro unmanned aircraft means a device capable of sustaining its own powered flight in the air, that is operated without the possibility of direct human intervention from within or on the device, and that: a) Weighs 3 pounds or less gross takeoff weight, including power source and payload; b) Is powered by an electric battery or other n on
- combustion power source; c) Is operated for a business, commercial, scientific, academic, research or other non

- recreational purpose; and is not a “model aircraft” subject to Public Law 112

- 95 § 336.

**§107.3 Waivers.** No person may conduct operations that require a deviation from this part except under a written waiver issued by the Administrator.
**§107.5 Careless or reckless operations**

. a) No person may operate a micro unmanned aircraft in a careless or reckless manner so as to endanger the life or property of another. b) No person may allow an object to be dropped from a micro unmanned vehicle if such action creates a hazard to other persons or property.
**§107.7 Certification, registration and other requirements.** c) Notwithstanding any other section pertaining to certification of aircraft or their parts or equipment, micro unmanned aircraft and their component parts and equipment (including ground station or radio control systems) are not required to meet the airworthiness ce rtification standards specified for aircraft or to have certificates of airworthiness. d) Notwithstanding any other section pertaining to registration and marking of aircraft, micro unmanned aircraft are not required to be registered or to bear markings of an y type, except that the name, address, and telephone number of the owner or operator shall be affixed to at least two externally visible locations on the micro unmanned aircraft. e) Notwithstanding any other section, micro unmanned aircraft operated pursuant to this part are not subject to any other federal aviation regulation, including any provision of parts 21, 45, 47, 61, or 91.
**§107.9 Daylight operations.** a) No person may operate a micro unmanned aircraft except between the hours of sunrise and sunset. b) Notwithstanding paragraph (a) of this section, micro unmanned aircraft may be operated during the twilight periods 30 minutes before official sunrise and 30 minutes after official sunset, or, in Alaska, during the period of civil twilight as defined in the Air Almanac, if:

1) The micro unmanned aircraft is equipped with an operating anti

- collision light visible for at least 3 statute miles; and 2) All operations are conducted in uncontrolled airspace.10 | Page

**§107.11 Operation near aircraft; right**

**- of** 

**- way rules.**  a) Each person operating a micro unmanned aircraft shall continually maintain vigilance so as to see and avoid aircraft and shall yield the right

- of

-way to all manned aircraft. b) No person may operate a micro unmanned aircraft in a manner that creates a collision h azard with respect to any aircraft. c) Each person operating a micro unmanned aircraft, upon hearing engine, rotor, or propeller sounds from an aircraft uninvolved in the operation, shall take precautionary steps to identify the altitude and flight direction of the uninvolved aircraft and yield right of way.
**§107.13 Operating limitations: altitude, airspace and locations.** a) No person may operate a micro unmanned vehicle at an altitude greater than 400 feet above ground level (AGL). b) No person may operate a micro unmanned vehicle within Class B, Class C, or Class D airspace or within the lateral boundaries of the surface area of Class E airspace designated for an airport, unless that person has prior authorization from the ATC facility having jurisdiction over that airspace. c) No person may operate a micro unmanned aircraft within 5 nautical miles of the geographic center of an airport as denoted on a current FAA

- published aeronautical chart unless that person has prior written authoriza tion from that airport’s management. This restriction does not apply to airports that are closed or abandoned. d) No person may operate a micro unmanned aircraft beyond his or her visual line of sight (VLOS). During the flight operation, the operator must be able to view the micro unmanned aircraft at all times using his or her own natural vision (which includes the use of vision corrected by standard eyeglasses or contact lenses but excludes the use for flight navigation purposes of vision

- enhancing devices s uch as binoculars, night vision goggles, powered vision magnifying devices, or video glasses designed to provide a “first person view” from a camera mounted on the micro unmanned aircraft), and must visually scan the surrounding airspace to see and avoid o ther air traffic. The maximum operating distance of a micro unmanned aircraft system from the operator under this subsection is 2,640 feet, regardless of the visual acuity of the operator. e) No person may operate a micro unmanned aircraft closer than 100 fee t from any persons uninvolved in the operation. f) No person may operate a micro unmanned aircraft over an open

- air assembly of persons. g) No person may operate a micro unmanned aircraft in special use airspace designated under Part 73 unless that person has pe rmission from the using or controlling agency, as appropriate. h) No person may operate a micro unmanned aircraft over privately

- owned property without the express or implied permission from the property owner, tenant in possession, or an authorized represent ative thereof. i) No person may operate a micro unmanned aircraft system within 5 nautical miles of any forest fire without authorization from the incident commander. j) Prior to operating a micro unmanned aircraft under this part, the operator shall become fami liar with all pertinent information concerning the proposed operational location, including but not limited to review of relevant NOTAMs. k) Any person intending to operate a micro unmanned aircraft within one mile of any active emergency shall first check fo r any NOTAMs with respect to restrictions on operations in that location.

**§ 107.15 Meteorological conditions.** All flights under this part must be conducted under visual meteorological conditions. A micro unmanned aircraft may not be operated under this part 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 operator.
**§107.17 Operating limitations: ground speed.** No person may operate a micro unmanned aircraft in excess o f 40 knots ground speed.11 | Page

**§107.19 Operator qualifications.** a) An operator of a micro unmanned aircraft system under this part must be at least 18 years of age. b) No person may operate a micro unmanned aircraft system under this part without first passing the FAA private pilot written airman knowledge test administered by an FAA

- accredited pilot school or test center. Prior to any operation under this part, the operator shall send written notification to the FAA evidencing the test results together with the ope rator's name and contact information, which submission the Administrator will acknowledge in writing as constituting the operator's micro unmanned aircraft pilot certificate for purposes of 49 USC § 44711. This subsection shall not apply to micro unmanned aircraft systems operated as public aircraft. c) The FAA may pursue investigation and enforcement procedures set out in part 13 with respect to the operator of a micro unmanned aircraft systems, including potential suspension or revocation of a micro unmanned aircraft pilot certificate held by its operator. d) Any other FAA pilot certificate that has as a requisite a written airman knowledge test may, if said certificate is current and in good standing, serve as a micro unmanned aircraft pilot certificate under

s ubsection (b) even if the operator is unable to provide evidence of his or her written test results. Such pilot certificates will constitute the operator's micro unmanned aircraft pilot certificate for purposes of 49 USC § 44711 and part 13. e) No person shal l operate a micro unmanned aircraft for hire or for a commercial purpose (other than research and development activates relating to the micro unmanned aircraft or its related systems and components), without first undertaking and documenting the following steps to gain experience and proficiency with the micro unmanned aircraft model: 1) Review of the micro unmanned aircraft manufacturer's operating manuals and any instructional videos provided by the manufacturer. 2) At least 5 hours of total operating flight ti me; and 3) At least 25 takeoff

- and

- landing sequences. f) All operations under this part (including training) shall be documented and recorded in a permanent place such as a log book. For the purposes of meeting the minimum requirements of this subsection, each person must record the following information for each micro unmanned aircraft flight: 1) Date and time 2) Micro unmanned aircraft type, make, model 3) Route and boundaries of flight 4) Total duration of flight 5) Weather conditions of flight 6) Number of landings 7) Total flig ht time and/or lesson time 8) Remarks or other pertinent details
**§107.21 Alcohol or drugs.** a) No person may operate a micro unmanned aircraft

— 1) Within 8 hours after the consumption of any alcoholic beverage; 2) While under the influence of alcohol; 3) While using any drug that affects the person's faculties in any way contrary to safety; or 4) While having an alcohol concentration of 0.04 or greater in a blood or breath specimen. Alcohol concentration means grams of alcohol per deciliter of blood or grams of alcohol per 210 liters of breath.12 | Page

**§107.23 Insurance.** a) No person shall operate a micro unmanned aircraft for hire or for a commercial purpose (other than for research and development of the micro unmanned aircraft or its systems and components) unless he or she has in effect liability insurance coverage that at a minimum meets or exceeds the minimum motor vehicle insurance coverages for both property damage and bodily injury required in the state in which the operation occurs, and that has been issued specifically t o insure against risks of the operation of the micro unmanned aircraft. b) Insurance coverage to meet the requirements of this part shall be obtained from one or more of the following: 1) An insurer licensed to issue aircraft accident liability policies in any State, Commonwealth, or Territory of the United States, or in the District of Columbia; or 2) Surplus line insurers named on a current list of such insurers issued and approved by the insurance regulatory authority of any State, Commonwealth, or Territory of the United States or of the District of Columbia. c) All person who have operated micro unmanned aircraft under this part must present their logbook, proof of insurance, and evidence of submission to the FAA Administrator their written test results or their valid pilot certificate, or any other record required by this part for inspection upon a reasonable request by

a. The Administrator; b. An authorized representative of the National Transportation Safety Board; or

c. Any Federal, State, or local law enforcement officer.
**§107.25 Accident reporting.** In connection with any operation under this part, any incident involving $1,000 or more in third

- party property damage, and any accident involving any bodily injury, must be reported to the nearest FAA Flight Standard s District Office within three business days. Accidents involving a serious injury or death shall be reported to the NTSB pursuant to 49 CFR § 830.