Jarrett C Speith

President/CEO Sky

- Forge Robotics
950 Lincoln Street Suite 201 Bellingham, WA 98229
360.202.9148

U.S. Department of Transportation Document Management System
1200 New Jersey Ave, SE Washington, DC 20590

Dear Sir or Madam:

Sky

- Forge Robotics LLC ( SFR ) located at the corner of 10th St. and Mill Ave., South Bay Suites Bellingham, WA 98229, and Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("F AA Reform Act") and 14 C.F.R. Part 11, hereby respectfully requests exemptions from several provisions of the Federal Aviation Regulations ("FAR"), to allow commercial operations of its Small Unmanned Aircraft System ( UAS) for aerial imaging for safety, m onitoring, training, and remote sensing of secured controlled environment sites, so long as such operations are conducted within the conditions outlined herein or as established by the FAA as required by
Section 333.

S pecifically Section 333 which authori zes the FAA to determine:

1. If certain 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 o f the national airspace system or the public or pose a threat to national security; and

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

o peration of unmanned aircraft systems identified under paragraph (1).

As detailed in the document we and the attached Flight Manual and Operating Instructions, w e are writing to request that SFR , LLC, an owner and operator of small unmanned aircraft, be exempted from th e Federal Aviation Regulations ("FARs") listed below so that SFR , may operateU.S. Department of Transportation

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its small unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as long as such operations are cond ucted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

14 C.F.R. Part 21
14 C.F.R. 45.23 (b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & ( b)
14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a)(1) 14 C.F.R. 409 (a)(2)
14 C.F.R. 417 (a) & (b)

SFR has been and is actively involved in the education, awareness, training, research

, and technical development of UAS/ UAV service applications to provide high definition aerial imagery and remote sensing capabilities with small, unmanned aircraft and lightweight UAS's.

The substance of this request is essentially the same as that granted to ASTRAEUS AERIAL Regu latory Docket No. FAA

- 2014

- 0352 and VIKING UNMANNED AERIEL SYSTEMS, INC Regulatory Docket No. FAA

– 2014

– 0850 in that SFR is engaged in training, aerial photograph and imaging
, and 3d mapping of agriculture and structures using similar lightweight, remote
controlled UAS's in remote areas t o minimize th e need to climb such structures and other high
risk activities.

SFR has fully equipped each of its small unmanned aircraft for aerial imaging , primarily for use in the inspection of towers and structures that would otherwise require climbing a t great risk to the personnel involved, though given the stability and maneuverability, they may be used by law enforcement personnel, search and rescue and by other first responders for other aerial photography including video and remote sensing.

SFR exemption request would permit its operation of lightweight, unmanned (remotely controlled in line of sight) UAS's in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, sectioned off locations will allow SFR to operate withinU.S. Department of Transportation

3/1/15 Page 3

current safety parameters as well as new ones being implemented. As identified, similar lightweight, remote controlled UAS's are legally operated by amateurs with no flight experience, safety plan or controls in place to prevent catastrophe

. SFR will dictate precise and repeatable preflight planning, decision making, and operator risk mitigation procedures to mitigate risk to personnel and property.

Granting SFR 's request comports with the Secretary of Transportation's (FAA Administrator's) responsibilities to not only integrate UAS's into the national airspace system, but to" ... establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system" under Section 333 of the Reform Act. Further, SFR w ill conduct its operations in compliance with the protocols described herein or as otherwise established by the FAA.

The Extent of Relief SFR Seeks and the Reason It Seeks Such Relief:

SFR submits this application in accordance with the Reform Act, 112 P.L . 95 §§ 331

- 334, seeking relief from any currently applicable FAR's operating to prevent SFR contemplated commercial inspections, research and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such inte gration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. SFR lightweight UAS's meet
the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of SFR l ightweight UAS's are expressly contemplated by the Reform Act. SFR would like to operate its lightweight UAS's prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary i n determining the types of UAS's that may operate safely in our national airspace system.
Considerations include:

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated near airports or populated areas; and, Whether t he UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for SFR

.

SFR UAS's uses primarily multi counter

- rotating propellers for extreme balance, control and stability. They each typically weig h less than 55 pounds, including camera or other equipment.
Each of SFR 's small unmanned aircraft is designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations but
operate o nly within the line of sight of the remote control pilot. In addition to the remote control pilot, SFR uses a camera operator, such that, at minimum, two SFR personnel govern the safe flight of an SFR aircraft at all times.

Utilizing battery power and no c ombustible fuels, flights generally last between five and twenty
minutes. SFR does not operate its UAS's with less than twenty five percent battery capacity. Safety systems in place include a GPS mode that allows SFR UAS's to hover in place ifU.S. Department of Transportation

3/1/15 Page 4

communicatio n with the radio control pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. Further, SFR fleet is programmed, in some instances, to slowly follow a predetermined set of waypoints to return to a safety point if communicat ions are lost or battery drops below twenty five percent

.

SFR does not operate its UAS's near airports and generally does not op erate them near populated areas when conducting training, inspections, or imaging activities.

SFR operation of its fleet of small unmanned aircraft will not "create a hazard to users of the national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). Given the small size and weight
of SFR UAS's, combined with their operation in cordoned off and well

- controlled areas, SFR fleet falls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Indeed, SFR UAS's have a demonstrable safety record a nd do not pose any threat to the general public or national security. The FAA has the authority to issue the exemption to SFR pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Commercial and Public Benefits Granting SFR exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Second, SFR conducts r esearch into safe UAS operations every time it flies one of its UAS's. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Allowing SFR to log more flight time directly relate s to its research and its ability to further enhance current safety measures. Third, the public has an interest in reducing the danger associated with current aerial inspection methods, namely, resorting to physically climbing high or compromised structure s to inspect.

Granting SFR exemption request substantially furthers the public's interest in ways known and currently unknown. Permitting SFR to immediately fly within the United States furthers advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel and first responders with state of the art equipment that does not cost
millions of dollars.

Reasons Why SFR Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

SFR exemption will not adversely affect safety. Quite the contrary, for the various reasons stated, permitting SFR to log more flight time will allow SFR to innovate and implement new and as of yet undiscovered safety proto cols.

SFR UAS's weigh less than 55 pounds complete with cameras and sensorsU.S. Department of Transportation

3/1/15 Page 5

SFR only operates its UAS's below 400 feet;

SFR UAS's only operate for 5

- 45 minutes per flight;

SFR lands its UAS's when they reach 25% battery power;

SFR remote control pilots ope rate SFR UAS's by Visual Line of Sight (VSOL)

SFR remote control pilots have video backup should they somehow lose sight of the UAS; SFR staffs each flight with a remote control pilot and camera operator;

SFR UAS's have GPS flight modes whereby they hover and then slowly land if communication with the remote control pilot is lost or battery power is below25%;

SFR actively analyses electronic flight data and other sources of information to constantly update and enhance safety protocols;

SFR only operates in secured areas that are strictly controlled, are away from airports and populated areas;

SFR conducts extensive briefings prior to flight, during which safety carries primary importance;

SFR always obtains all necessary permissions and permits prior to oper ation;

SFR provides a level of safety at least equal to existing rules, and in nearly every instance, greater than existing rules. It is important to note that absent the integration of commercial UAS's into our national airspace system, helicopters are th e primary means of aerial photography. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight UAS.

First, the potential loss of life is diminished because UAS's carry no people on boar d and SFR only operates in specific areas away from mass populations. Second, there is no fuel on board a
UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of SFR UAS's allow our remo te control pilots to avoid hazards. Fourth
the SFR UAS will allow the replacement of helicopters or other small aircraft to conduct similar work in a safer more affordable and environmentally friendly manner. Finally , given their small size and weight, eve n when close enough to structures or property to capture required images,
SFR UAS's present a marked increase in safety over traditional larger aircraft. Accordingly, SFR UAS's have operated and will continue to operate at and above current safety levels.

Equivalent level of safety

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR ₴ 91.203 (a ) ( 1)U.S. Department of Transportation

3/1/15 Page 6

14 C.F.R. 45.23 (b) Display of m ark s ; g eneral

.
Due to the size and nature of the UAS, it would be impossible to comply with the marking requirements. The equivalent level of safety will be provided to mark the UAS as “Experimental” that is clearly visible to the operator, pilot, or observer. The FAA has issued the following

ex emptions to this regulation: Exemption No’s 10700, 8738, 10167, and 10167A.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a UAS flight trai ning course specific to SFR operations before flying a UAS

. In substitute the FAA approved Private Pilot Ground School or equivalent may be completed as a further equivalent level of safety to this rule

. A minimum of 40 hour s instructional ground and 10 hours of supervise d flight time will be required of any operator prior to commercial application or use. Unlike a conventional aircraft that carries a pilot and passenger the UAS is a remotely controlled
with no living occupant or cargo. They are of operation is controlled and restricted, and all flights are planned and coordinated in advance. the risks associated with the operations of the
UAS are so diminished from the level of risk associated with the comm ercial operations contemplated by part 61, that allowing operations of the UAS as requietrsdte with a pilot who
has met the minimum requirements exceeds the present level achieved by 14 CFR 61.113 (a) & (b).

14 CFR 91.7 (a): Civil aircraft airworthiness

Th e regulation requires that no person may operate a civil aircraft unless it is in airworthy
condition. As there are no airworthiness certificates issued for the UAS aircraft, should this exemption be granted, no FAA regulatory standard will exist for deter mining airworthiness. Given the size, of the UAS and requirements contained in the operation manual for use, safety, and maintenance, as well as the use of safety checklists prior to each flight, as set forth, an equivalent level of safety will be provided

.
14 CFR 91.9 (b ) ( 2): Civil aircraft Flight manual, marking and placards.

Given the UAS size and configuration, there is no ability to place or carry a flight manual on the
aircraft.

The equivalent level of safety will be maintend by keeping the flight manual that the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption No’s 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, a nd 10700.U.S. Department of Transportation

3/1/15 Page 7

14 CFR 91.103 Preflight Actions

This regulation requires each pilot in command take certain actions before flight to insure safety of flight. An exemption is needed form this requirement as the pilot will take a separate list of preflight actions , including checking for wheatear conditions flight batter, take of ad and landing
clearances , and other actions specified in the SFR preflight checklist. These actions will profcie an equivalent level of safety.

14 CFR 91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully function dual controls.

By design the UAS and remotely piloted aircraft of this configuration do not have fully functional
dual controls flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has previolsyul approved exemptions for aircraft without fully funcitonlinal dual controls. See exemption No’s 5778K and 9862A. The equivalent level of safety provided by the fact that neither a pilot more passenger will be carried
in the aircraft , the ability to control the UAS via radio signal from the control, and by the size and speed of the aircraft.

14 CFR 91.121 Altimeter Settings

An equivalent level of safety will be achieved by the operator by using a GPS altitude readout and proper safety checklist and preflight planning confirming the altitude of launch site prior to flight

14 CFR 91.151 (a) VFR Fu el requirements for flight in VFR

An equiv alent level of safety will be achieved by limity flights to 30 minutes or enough battery
reserve to ensure the UAS lands at the ground control point with at least 20% battery power remaining (as determined by on bo ard monitoring system and the pilot). Furthermore the UAS
can be programed to safety descend and land automatically in the event of loss of communications or battery level is exceeded. Similar exemptions have been granted to other operations, including exemp tions 2689F, 5745, 10673, and 10808.

14 CFR 91.203(a) and (b): Carrying civil aircraft certification and registration

The UAS fully loaded weighs no more than 10lbs and is operated without an onboard pilot

. Therefore the is no ability to place or carry the certification and registration documents or display them on the UAS

.U.S. Department of Transportation

3/1/15 Page 8

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot of the UAS will have immediate access to them, the extent they a re applicatnle to the UAS . The FAA has issued numerous exemptions to this regulation such as Exemption No’s 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR 91.405 (a): 407 (a ) ( 1); 409 (a ) ( 2); 417 (a) & (b): Maintenance Inspections

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the SFR UAS . Mainteneatn will be accomplished hty eh operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be
achievedbecasue these small UAS are limited in sizes , complexity, and will carry only a small payuleo to operate for specific limited time. If mechanical issues arise the UAS can land safely immediately and will be operating no higher than 400 feet AGL. Preflight inspection will ensure
the UAS is in working order and requiremed maintenance will be performer. A flight and maintenance log will be kept with the operator and maintain the a ircraft in an airworthy condition to provide the equivalent level of safety.

Respectfully

,

Jarrett C Speith President/CEO Sky

- Forge Robotics