Intelligent Corporate Solutions, LLC

8 Redstone Ct. Mechanicsburg, PA 17050

Phone: 717

- 796

- 5920

E

- Mail: joseph@intelligentcorporatesolutions.com Web: www.intelligentcorporatesolutions.com



### April 10, 2015

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

Dear Sir or Madam :

This application is being submitted on my own behalf without legal council or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Intelligent Corporate Solutions, LLC, operator of Sma ll Unmanned Aircraft Systems (“S UASs”) equipped to conduct aerial photography and videography, hereby

a pplies for an exemption from the listed Federal Aviation Regulations (“FARs”) to all ow commercial operation of its S UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as requir ed by Section 333.1

As described more fully below, the requested exemption would permit the operation of small, unman ned and relatively inexpensive S UAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The pro posed exemption, if granted, would allow Intelligent Corporate Solutions, LLC to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.

Intelligent Corporate Solutions, LLC is an image processing company that plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Event Photography /Videogr aphy

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

Statutory Authority Section 333 , titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if c ertain unmanned aircraft systems m ay operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congres s made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all req uirements to permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following: Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2)

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. 91.205 (b)

### 2 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

Unmanned Aircraft System

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and personnel cost, reduced nois e and as such, a much smaller environmental impact which promotes public safety.

We are petitioning for exemption to enable Intelligent Corporate Solutions, LLC to operate a DJI Inspire 1 eq uipped with three

- axis gimbals and using High

- Def. cameras. This SUAS has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Inspire 1 also has the

fails afe function of the Naza

- M autopilot system, which means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS signal is good eno ugh, the system will automatically trigger Return to Home and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set below:

• Intelligent Corporate Solutions, LLC will only operate its SUAS in line of sight of a p ilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will ins ure that the SUAS will "not create a hazard to users of the national airspace system or the public."

• When flying SUAS within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid flying in the proximity of full

- scale aircraft.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

• The SUAS will be programmed so that it will not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform f rom which filming is planned.

• Minimum crew for each operati on will consist of the SUAS Pilot, and Visua l Observer.

• The S UAS operated by the petitioner weighs less than 55 pounds, including the payload (i. e. camera, lens, and gimbal).

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously mo ve vertically and horizon tally.

• Given the small size of the S UAS and the restricted sterile environment within which they will operate, our S UAS operations adhere to the Reform Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable th an larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the lik elihood of death or serious bodily injury. With a small payloa d and maximum flight time of only 20 minutes, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the ch aracteristics of large, complex properties with several buildings and large trees. The applicants in the past have chartered 2

- seat full

- sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost an d improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance , includ ing fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so.

a. No flight will be made with a Gross weight exceeding 55 pounds;

b. All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 25 knots and n o further than 3/4 NM from the PIC;

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to communic ate by voice at all times during a

flight operation;

d. Operations will be restricted to flights over private property with the permission of the property owner;

e. All required permits will be obtained from state and local government prior to operation;

f. Intelligent Corporate Solutions, LLC will not operate over densely populated areas;

g. Intelligent Corporate Solutions, LLC will not be operating over any open

- air assembly of people;

### 3 h. Intelligent Corporate Solutions, LLC will not be operating over heavily trafficked roads;

i. Intelligent Corporate Solutions, LLC will not be operating within 5 NM of an airport or heliport;

We respectfully request exemption under Section 333 to enable Intelligent Corporate Solutions, LLC to operate efficient, limi ted, low

- risk commercial SAUS operations for the activities stated respecting at all times the space and privacy of citizens and property whilst keeping our

skies safe.

Sincerely,

Joseph Toth Intelligent Corporate Solutions, LLC www.intelligentcorporatesolutions.com joseph@intelligentcorporatesolutions.com

717

- 796

- 5920

### 4 EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Intelligent Corporate Solutions, LLC requests an exemption from the following regulations as well as any additional regulatio ns that may technically apply to the operation of the SUAS System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to dev elop airworthiness standards for Unmanned Aerial Systems, we request an experimental certific ate be issued for the DJI Inspire 1 under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

a. Research and development

. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

b. Showing compliance with regulations

. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substant iate major design changes, and flights to sh ow compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experi mental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lig htweight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropr iate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMEN TAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The SUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equi valent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to se e the designation.

Addition ally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration informa tion at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words " Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

1 4 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pi lot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for com pensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employme nt if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry pas sengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Recreational Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.11 3 Subparagraph (b) even though the intent of this application is to

conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate . As no such certificate will be applicable in the form contemplated by the FARs , this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ens ure that flight manual information is available to the aircrew while operat ing the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet t he intent of 91.9, we propose that a current, approved SUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain f light tests. The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The SUAS System ground

- based

control station consists of a small hand

- held rad io transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes : General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than

### 5 500 feet to any person, ve ssel, vehicle, or structure. Since the typical mission of the SUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flo wn over prop erty or persons where permission has been obtained and careful pre

- flight planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, whic h should be considered in granting the exemption.

CFR 91.121 Altimeter settings . The regulatio n requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The SUAS will always fly below 400 feet AGL and will not need to maintain cruising a ltitudes in order to prevent confli ct with other aircraft. An Above Ground Level altimeter measurement above the launch and recovery point is

transmitted via radio from the SUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.1 51 Fuel requirements for flight in VFR conditions . The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at leas t 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The SUAV is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. S ince the aircraft will never fly more than 3f4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requir ement of this paragraph. We request an exemption to the word "fuel" and ask for an equiv alent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate mu st be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a m aximum g ross weight of 5.3 pounds, the S UAS is too smal l to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the

FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircr aft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraf t via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is

p rimarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragr aphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after mainte nance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every f light and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking e lectrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the siz e, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS Intelligent Corporate Solutions, LLC will be using the SUAS in a variety of applications that generally require expensive ful l

- size manned aircraft to complete. Small, light, u nmanned aerial vehicles offer myriad benefits over the use of full

- sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few. Replacing significantly larger

m anned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin o f safety for the pilots and crew. By granting Intelligent Corporate Solutions, LLC requested exemptions, the FAA will help drive de velopment of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Intelligent Corporate So lutions, LLC is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this

Petition.

Conclusion As pointed out in this application, all the SUASs which our compan y would use, under authorization by the US DOT

- FAA, are small, light

weight devices operated within the line of sight of the Pilot

- in

- Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spacepor t, or other location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All our SUASs have proven capability for controlled flight. They are devi ces offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 3 32, Public

Law 112

- 95, 2014, have already provided you with th e assurances on the airworthiness of SUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Intelligent Corporate Solutions, LLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and approp riate by the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUA S s may be used for legitimate commercial activities and under reasonably safe conditions.

### 6 8 Redstone Ct. Mechanicsburg, PA 17050

E

- Mail: joseph@intelligentcorporatesolutions.com

Web: www.intelligentcorporatesolutions.com

Phone: 717

- 796

- 5920