CCLD Technologies Inc

2705 Faith Industrial Drive, Buford GA, 30519 Email: bburke@ccldtech.com

Petition: March 24 th 2015
U.S Department of Transportation, Docket Operations Federal Aviation Administration West Building Ground Floor, Room w12

- 140 1200 New Jersey

Avenue, SE, Washington DC 20590
Subject: Request for exemption of certain conditions from the Title 14, Code of Federal Regulations (14 CFR) for CCL D Technologies.

Sir or Madam: CCL D Technologies Inc. is here b y requesting exemption from specific regulations of Title 14 of the Code of Federal Regulations. These exemptions are in accordance with the Section 333 of the FAA Modernization and Reform Act of 2012. According to current FAA rules and regulations all recreational unmanned aviation fly ing must be kept below 400 feet AGLand the pilot must kee p line of sight on the aircraft. CCLD Technologies Inc. is requesting for the permission of the FAA to be able to use a unmanned Ariel vehicle for commercial use to fl y and inspect cell phone towers, and other tall structures for consumers. In doing so CCLD will abide by all FAA regulations such as, staying under 2,000 feet AGL and will not fly in restricted areas. If exemption is allowe d, CCL D will be able to provide high definition Laser scanning as well as Thermal Im aging for inspections to detect cracking in towers, bridges, and other structures, as well as provide full data extraction for construction companies for build outs, as bui lt survey s and progression builds. Being able toconduct such inspections will help each state’s Department of Transportation detect and correct

any bridge, road or structure damage before it causes harm for the community

. In order to maintain a completely safe operating environment CCL D will not, in any circumstances will never enter Class B, C, or D airspaces. CCLD will also keep all awareness of any TFR’s, restricted/prohibited areas. CCLD will not come within three nautical miles of any active airfields or airports. We will fly in areas that we have been given clearance to fl y in, and file NOTAMs at least 24 hours to operating. CCLD will notify all parties affected by

the area being flown b y our UAV. CCL D will conduct and receive an y prior authorizations required from local areas before flight is confirmed.

**AIRCRAFT DISCRPTION :**  CCLD Technologies would be operating with the Aibotix X6. This is a 6 bladed multi rotor aircraft that weighs less than 14 pounds. I t is made of Carbon Fiber Reinforced Poly mer. I ts dead weight is 7 pounds; its takeoff weight is 10.3 pounds. Its max speed is 31 MPH. 30 minute flight times. It is equipped with accelerometer, magnetometer, barometer, ultrasonic sensors and gy roscope. It operates on L ithium

- Poly mer 10,000 Milliamp batteries. This is a (VTOL) Vertical Takeoff and landing aircraft. CCLD Inc. will operate a n unmanne d aircraft weighing less than 14 poun ds and is bright green in color, which will make it highl y visible and identifiable. Our Aircraft will possess all programmable failsafe’s such as lost communications, lost geospatial positioning, and lost magneto features, as well as instantaneous overrides. All operations with our UAV will be kept in the line of sight of the pilot. It will not cause hazard to users or an y surrounding by standers or to the users of the national airspace s ys tem, or pose a threat to the national securit y. The UAS will maintain 2 way communication with all crewmembers and observers as well as the local CTAF or other necessary operational freque ncies during the flight. With this petition CCL D Technologies Inc. is requesting an examination of its UAS by the FAA to be exempt from certain parts of Title 14 Code of Federal Regulations. CCLD Technologies Inc. will use the Aibotix x6 aircraft strictl y for business purposes. We will operate under all normal conditions at a speed no more than 22 knots (KIAS) and has the capability to hover. We will alway s be kept in line of sight of pilot i n control. Operation guidelines are within the 100 foot radius surrounding the telecommunications or utility structure and under 400 feet AGL. **REQUEST FOR EXEPTION FROM:**
**§21.1(a)(1)(iii):** This part prescribes procedural requirements for issuing and changing airworthiness certificates.Reason for Exemption:

CCLD Technologies Inc. requests approval to produce documentation verified and signed by a licensed A&P which states that that the aircraft in use will adhere to the M IL

- HDBK

- 516B Airworthiness Certification Criteria in lieu of an y co nventional aircraft airworthiness processes until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Report 112

- 381

. **§61.113(a):** N o person who holds a private pilot certif icate 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. Reason for Exemption: CCLD Technologies INC. will not pilot any aircraft carry ing passengers or propert y. However we do request approval to operate in a commercial capacit y for compensation or hire for the purposes of doing inspections on tall structures, and roadways until such time as the administration est ablishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Report 112

- 381. CCLD Technologies employ s a private pilot single engine land; rotorcraft

– helicopter certificate holder who can competentl y act as pilot in command over the unmanned aircraft. **§91.203(a)(1):** Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate use d to comply with this subparagraph

. Reason for Exemption: CCLD Technologies Inc. requests approval to produce documentation verified and signed by a licensed A&P which states that that the particular aircraft in use will adhere to the MIL

- HDBK

516B Airworthiness Certification Criteria in lieu of any conventional aircraft airworthiness processes required b y Part 91.203(a)(1) until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Report 112

- 381. The airworthiness documentation based on MIL

- HDBK

- 516B will be accessible by the ground based flight crew during all operations. **§91.203(a)(2):** Except as provided in §91.715, no person may operate a civil aircraft unless it ha s within it the following: An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certification iss ued under the laws of a foreign country
. Reason for Exemption: CCLD Technologies Inc. request s exemption from producing registration for its aircraft. This request couples with the request for exemption for airworthiness under §21.1(a)(1)(iii) in thispeti tion. This request acknowledges Order 8130.20 regarding registration requirements for

United States civil ai rcraft seeking airworthiness and requests relief until such time as the administration establishes a standard for national regulation for commercial unmanned aircraft operations pursuant to Report 112

- 381. Reason for Exemption: Given the unmanned nature of the aircraft, CCLD Technologies Inc. requests that it be approved to have an airworthiness documentation based on MIL

- HDBK

- 516B accessible to the ground based flight crew at all times. **§91.9(b)(2):** No person may operate a U.S.

- registered civil aircraft For which an Airplane or Rotorcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current appr oved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or an y combination thereof. Reason for Exemption: CCLD Technologies Inc. will be operating small, unmanned aircraft that do not possess a ty pe certificate, relievi ng it of the requirements for §21.5. Given the nature of the unmanned aircraft, CCLD Technologies Inc. wishes to require an aircraft manual present with the flight crew at ground level in lieu of making the aircraft manual available in the aircraft.
CCLD Technologies is a telecommunication company that has been in operation for 16 y ears. We have formed and held many multi

- million dollar accounts in which we have done service for in the past. CCL D Technologies plans to monitor and inspect all aspects o f the safet y portion of the Departments of Transportation, ensuring the public roadway s and bridges are safe for the population to travel on.

Pilots: All pilots will maintain currency on the UAS by

performing at least three launch and recovery operations that include maneuvering within the preceding 90 day s. Name: Cory

O’Leary Specs: Private Pilot L icense Training completed a Delta Connection Academ y in Sanford, FL. AMA Member Certified since 2009. Observer’s :All observers will maintain relevant currency according to FAR part 61 and be updated on all current UAS protocol. In addition to that all observers will meet the following requirements: 1. FAR Part 91 training 2. Knowledge of the capabilities of the unmanned aircraft in operation 3. Crew Resource training 4. Participation in preflight planning and mission planning 5. Capacity

to visuall y and audibly detect aircraft intrusions exceeding one nauti cal mile.

CCLD Technologies Inc. holds the highest regard for the rules and regulations of the FAA in protecting the general public as well as not to disrupt or interfere with the United States National Airspace S ys tem. On Behalf of all UAS advocates in both the public and private sections who are working toward a safe integration of the UAS world and the NAS world, we want to thank you for your consideration of this petition for exception, an also look forward to your comments and or feedback on how we c an continue to expand this outstanding technology

. 

# Brett Burke
Owner/ President CCLD Technologies Inc. bburke@ccldtech.com www.ccldtech.com