Caddis Aerial, LLC Section 333 Petition for Exemption
1 Submitted electronically

July 17 , 2015

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

RE: Petition for Exemption from Certain Federal Aviation Regulations according

to Section 333 of the FAA Moderniza t ion and Reform Act of 2012

Dear Sir or Madam:

Caddis Aerial LLC ( Caddis ) is applying for an exemption from the Code of Federal

R egulations as detailed below

.

The exemption would permit commercial operation of a small unmanned aircraft system ( UAS ) in the national airspace (NAS) as regulated by the FAA for the following uses:

• Aerial survey

• Pipeline inspection

• E nvironmental mapping and monitoring of natural resources including forest

and wetlands

• R esort and golf club inspection

• Rescue mission support including avalanche safety

• A ny other commercial and government uses offered by C addis to its clients

All operations performed by Caddis are cost effective and protect the public by reducing

the size of the aircraft from one weighing up to several tons to one weighing less than

55 pounds . In addition, the UA does not use flammable liquid fuel . Instead, it operates

on high

- energy batteries

. The UA is flown in the lower strata of controlled and

uncontrolled airspace at 4 00 ft. AGL and below

. Caddis commercial operations will be performed according to FAA regulations or amended FAA regulations as permitted
under a Section 333 Grant of Exemption

.Caddis Aerial, LLC Section 333 Petition for Exemption
2 BAC KGROUND AND REFERENCES

The Colorado Plateau covers more than 130,000 square miles. It is an arid, high

- desert region with some forestland . It includes the southwestern corner of Colorado, northwestern corner of New Mexico, northeastern corner of Arizona, and southeastern

corner of Utah

. The sparsely populated area is used for many purposes, including mining for mineral resources, electricity generation, logging, grazing, agriculture and

recreation . Federal, State and local governments must build and supply the

infrastructure need ed to access the local environment to manage wilderness areas

, population growth, roadways, electricity and water delivery

.

The owners of Caddis have served their commercial clients and the government agencies in The Four Corners region by providing data collection and aerial photography services with a manned aircraft

. The owners are submitting this 333 exemption petition to increase the safety of their operations and remain competitive economically within the region.

In support of this petition and the FAA’s determination process, previously granted 333 exemption petitions by the FAA with same or similar stated purposes using a UA are referenced below:

• Aerial survey: exemption no. 11436, Unmanned Experts, Inc.

• Pipel ine inspection: exemption no. 11241, Phoenix Air UNMANNED, LLC

• Natural resource mapping and monitoring (Forestry and wildlife mapping); exemption no. 11291, Altavian, Inc.

• Real estate, resort and golf club inspection: exemption no. 11403, Droneview, LL C

• Rescue mission support, first responders (avalanche safety): exemption no. 11282, Down East Emergency Medicine Institute

• Further commercial purposes for safety and public awareness of UA uses; exemption no. 11409, Wade Bell.Caddis Aerial, LLC Section 333 Petition for Exemption 3 NAME OF AGENT FOR CADDIS

Steve McCormack

Caddis Aerial LLC

2 Sandstone Dr. Durango, CO 81301

For technical and administrative questions on this petition, please contact:

Mr. Brian Dyer Remote Pilot Systems Telephone 484

- 680

- 7310

Email: Brian.Dyer@RemotePil otSystems.com

Submitted separately as confidential documents under 14 CFR Section 11.35 (b) are:

A

– Aibot X

- 6 User Manual

B

– Yuneec Typhoon Q500 User Manual

C

– Caddis Flight Operations Manual ( CFOM )

These documents contain proprietary information that is not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et.seq.

Thank you for your time and attention.

Sincerely,

Brian DyerCaddis Aerial, LLC Section 333 Petition for Exemption 4 DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM

Caddis qualified personnel wish to fly the following aircraft:

• Aibot X

- 6

• Yuneec Typhoon Q500 /Q500 +

The Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a hexacopter in a V

- 6 designed for aerial survey and inspection

. Aibot ix in Germany has delivered more than

200 aircraft since 2011. The flight control system used with the aircraft is designed and manufactured in Germany, has undergone conti nuous improvement and development

, with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency

failsafe to controlled descent or, if GPS signal is sufficient, to return to point

of takeoff.

• The pilot may override waypoint programming with manual stick control in case of emergency or route adjustment.

• Telemetry is displayed on the pilot ’s handheld controller and maybe announced by voice.

• The X6 is optimized for aerial survey with safety features to reduce pilot

workload , such as attitude stabilization, GPS satellite

- assisted navigation,

return to home and auto land.

The aircraft is less 1.2 meters, in diameter, is made of carbon

- fiber reinforced polymer in a high visibility color, with protective blade guards surrounding the six rotors, and is designed for a maximum takeoff weight of of less than 15 pounds and a flight time of

about 20 minutes with its dual

- battery power. Maximum speed is about 55 MPH, but

GSI treats this limitation as an emergency reserve, and plans no flying at greater than 25 MPH. The aircraft carries no flammable liquid fuel

.

Radio control and video transmission systems meet FCC requirements for operation in the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings aboutCaddis Aerial, LLC Section 333 Petition for Exemption 5 interference from devices operating at or near these frequencies or their harmonics are

documented in the Caddis Flight Operations Manual ( C FOM ), along with procedures to ensure radio safety with the UAS

.

The Yuneec Typhoon Q500 /Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of quadcopter design

. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 has the world's first Smart Transmitter (the "ST

- 10 series Ground Station" with 10 channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital

video link. The series operates on a bu ilt

- in Android touch screen. Safety features include Geo Fencing, Home Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a programmed permitted radius. When activated, Home Mode will automatically return the aircraft within a 10

- foot radius of its starting point. Should the transmitter signal be lost or visual line of sight with the aircraft impaired, upon signal, Return Home will automatically take control of the aircraft and return it to the operator/base station. Takeoff weight with manufacture provided camera and gimbal payload and battery is 3.75 lbs.

The Typhoon Q500 dimensions are 16.5x16.5x8.3 inches with a diagonal of 22.2 inches without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1V lithium polymer battery. Radio control and video transmission systems meet FCC requirements for operation in the unlicensed spectrum of 5.8 GHz ranges. The operating manual of the Typhoon Q500 warns against using the aircraft in areas

where radio interfe rence is possible , as does the CFOM

.

EXTENT OF RELIEF SOUGHT AND WHY

Caddis asks for relief from regulations tabled below, which the authority of the FAA has previously granted in exemption certificates number 11062 along with six others described as “in commonality” , and in number 11109, which are for use of electric

rotorcraft. The C FOM ) incorporates the conditions and limitations of these grants of exemption, and in some cases imposes stricter limits on its own operations.

CFR CODE CITATIONSCaddis Aerial, LLC Section 333 Petition for Exemption 6 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

61.113 (a) Private pilot privileges an d limitations: pilot in
command Holder of private pilot certificate may not act as pilot in command (PIC) for compensation or hire. Fly ing for compensation on survey missions is central to purpose of exemption

request. Characteristics of aircraft, VLOS, under 400 ft. AGL, trained visual

observer in radio communication with pilot; controlled access site
safet y protocols enhanced by Caddis flight safety plan; PIC with airman’s certification, appropriate medical and vision qualification or valid U.S. driver’s license, currency in the aircraft per 61.56, pilot training, testing, proficiency with
similar and same model UA; and inspection/maintenance are defined

in the CFOM and will ensure equivalent levels of safety

.

61.113 (b) Private pilot privileges and

limitations: Pilot in
command Holder of private pilot certificate may act as PIC for compensation or hire if flight is incidental to business or employment and does not carry passengers for compensation or hire. Flying for compensation on survey missions is central to

purpo se of exemption request, not incidental to business or employment. There is no passenger or pilot on
board the UA , thus safety issues are different than a manned flight.
Caddis ’ aircraft has programmable automated safety features and emergency responses, has pre

- flight checks for safety beyond commercial manned aircraft, can be geographically restricted by operator with programmable control points, has communications
with the PI C regarding fuel loss and other flight hazards. PIC will have ground school training certificate and additional 25 hours logged flight time and 25 hours classroom

and field instruction as stated in

C FOM.Caddis Aerial, LLC Section 333 Petition for Exemption
7 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.119 (c) Minimum safe
altitudes over other

than congested area Operating closer than 500 feet to a person, vehicle, or structure may be necessary for survey and equipment inspection. People will not be allowed over, under or within 500 feet laterally of the aircraft in flight. Some flights may require the participation or guidance of industry personnel, positioned as close as 200 feet. Caddis will brief them on safety and
obtain necess ary consent. Industry site safety rules will be followed.

91.121 Altimeter settings Procedures to set and
confirm altitude do not provide for operation of remote telemetry to UAS pilot. An onboard air pressure sensor and
software resolve he ight differ ences as small as one centimeter. Altitude is controlled by measuring air pressure and the z

- axis accelerometer/GPS values. The starting point is a relative he ight measurement calculated by the flight controller. Altitude above ground is displayed on the p ilot's handheld controller by telemetry, and alarms can signal conditions of

interest. 5 00 feet AGL is the maximum permissible in the

CFOM , which describes altimeter procedures.Caddis Aerial, LLC Section 333 Petition for Exemption 8 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.151 (b) Fuel requirement s for flight in VFR

conditions Rotorcraft under VFR must carry enough fuel to reach first landing point and then

another 20 minutes. The

multirotor aircraft specified in this petition are designed to fly for a maximum flight
duration of on more than
30 minutes with its two
batteries. B attery voltage under load is displayed on the pilot's handheld controller during flight. The X6 uses 2 lithium polymer batteries of

a multi

- ­ ‐ cell design, connected in parallel for redundancy and optimal current delivery. Battery chemistry does not support adequate current discharge below about 3 v per cell. Circuitry in the onboard flight controller measures voltage and will start a failsafe pr ocedure to land
before summed minimums are

reached. In the event that one or more cells fail, these minimums may be reached sooner than expected, due to rapid current drain against a smaller number of functioning cells. Caddis pilots are
trained to monitor voltage and recognize abnormal discharge in flight and to land sooner than
forced. If 20 minutes of flight time or 25% of reserve voltage under load is reached, pilot must commence landing.Caddis Aerial, LLC Section 333 Petition for Exemption 9 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.405 (a) Ma intenance required Required inspections and
discr epancies repaired
between the required inspections pertain to certificated manned aircraft and procedures conducted by licensed maintenance personnel. In the absence of certification requirements

for UAS and UAS maintenance personnel,
reasonable alternativ es must be developed to maintain equivalent levels of safety. Caddis will document maintenance, overhaul, replacement and inspection requirements in the
absence of manufacturer's requirements; will document and
maintain maintenance records and technician qualification criteria in

the C FOM.

91.405 (b) Maintenance

r ecords Qualifications for maintenance personnel for
UAS were not contemplated by these regulations, and a

reasonable alternative must be developed to maintain equivalent levels of safety. Qualifications, competence and testing for maintenance personnel

ar e defined in the CFOM

. Caddis will also abide by USDOT FAA

Notice N 8900.296

91.407 (a) (1) Operation after maintenance, preventive

maintena nce, rebuilding, or

alteration There is no authorization procedure for a person who

can approve a return to service of an UAS , and a
reasonable alternative must be developed to maintain equivalent levels of safety. Procedures for the PIC to test then approve a return to service after

m aintenance are defined in the

CFOM.Caddis Aerial, LLC Section 333 Petition for Exemption 10 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.409 (a) (1) Inspections Annuals conducted by a qualified inspector require

authorization criteria for that inspector, not yet
defined for UAS . A
reasonable alternative must be developed to maintain equivalent levels of safety. Schedules for inspection and responsibilities of the PIC and qualified technician are described in

the CFOM.

91.409 (a) (2) Inspections Issuance of airworthiness

certificates for UAS under 55 pounds operated VLOS is not contemplated by these regulations Airworthiness is the responsibility

of the PIC and the technician as
defined in the CFOM

.

91.417 (a) Maintenance
records Regulations do not contemplate requirements or approval processes for maintenance and inspection
of uncertificated UAS

, however a reasonable
alternative must be developed to maintain equivalent levels of safety. The operator will maintain records

accordin g to the procedures as specified in the CFOM

.

91.417 (b) Maintenance
records Retaining and transferring

records of maintenance and defects according to standards prescribed for
authorized maintenance and inspection is not contemplated in the regulations for UAS . A
reasonable alternative is necessary to maintain equivalent levels of safety. Records and documentation will be kept for all maintenance performed, defects, and for all components specified in the CFOM

.Caddis Aerial, LLC Section 333 Petition for Exemption
11 PILOT IN COMMAND AND CREW

The pilot in command (PIC) must hold an a ir man’s certification recognized by the FAA

such as: an airline t ransport , commercial, private, recreational, sport pilot, or glider pilot (powered or non

- powered) and must be in complia nce with the training and testing specified in the CFOM . The PIC must hold a current FAA airman medical certificate as required by the class of airman certification. In the case of the sport pilot certification, the PIC must po s sess a valid U.S. driver’s license issued by a S tate, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must be in compliance with the training and testing specified in the operator’s manual.

The PIC must rem ain in radio communication with a visual observer who is in compliance with the training and test ing specified in the operator’s manual. The pilot must be able to acquire the aircraft with their own vision according to eye standards for a

third class airma n medical certificate or valid driver’s license according to the issuing

State

. The PIC must operate within visual line of sight only, and be able to see the
attitude and orientation of the aircraft by themself . If GPS or magnetometer is compromised, certa in safety features may not operate, and the pilot must understand by

their training and experience how to recover control.

OPERATION OF THE UNMANNED AIRCRAFT

The aircraft will be under the operational control of the petitioner.

1. The aircraft used for su rvey operations by Caddis will be the Aibot X6 and the Yuneec Ty phoon Q500 seri es as described in the C FOM, unless the FAA approves a further amendment to this petition.

2. The PIC will hold a transport, commercial, private, recreatio nal, sport pilot or glider powe red or non

- powered certificate , a third

- class medical certificate

or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government , and must meet flight review requirements in a n aircraft in which the PIC is rated, according to 14 CFR § 61.56.

3. Caddis pilots will operate at less than 400 feet AGL, in daylight hours only

,Caddis Aerial, LLC Section 333 Petition for Exemption
12 and within visual line of sight of the PIC, five (5) nautical miles or more away from an airport reference point as denoted in the current FAA Airport / Facility Directory (AFD) or as denoted in the current FAA / facilit y directory published charts, and use a C FOM

- qualified visual observer in

radio communication with the PIC.

4. Manufacturer’s limitations of the aircraft will not be exceeded, and Caddis’ operations will adhere to power reserves and lower operational limits
described in the CFOM

.

5. Preflight inspection by the PIC, and inspection and maintenance procedures will be followed according to the CFOM , and will be properly documented and sig ned for by an authorized technician who has completed training specified in the CFOM

.

6. Test flights by the PIC in connection with maintenance requirements will be
documented.

7. Manufacturer systems and safety bulletins will be followed, and flight critical components will be monitored and re placed when specified in the CFOM

.

8. Caddis maintenance personnel will document discrepancies discovered between inspections

.

9. If visibility is less than three (3) statute miles from the PIC, the aircraft may

not b e operated less than 500 feet below a cloud, or less than 2000 feet horizontally from a cloud

10. The PIC must follow emergency procedures as described in the CFOM in event of lost link, degraded navigation signals, or appearance of unauthorized persons within the secure flight perimeter

.

11. A commercial Certificate of Authorization, if required by the FAA, will be obtained according to FAA’s designated procedure befor e any operations are conducted, and Notices to Airmen will be filed in accordance with FAA requirements

.

12. An N

- Number will be obtained for all aircraft operated

.

13. RF spectrum will be used in compliance with FCC requirements

.

14. Documents required by 14 CFR 91. 9 and 91.203 will be available to the PIC at the point of flight and control, and will be produced upon request by anyCaddis Aerial, LLC Section 333 Petition for Exemption 13 authority.

15. The aircraft will remain clear of and yield right of way to all manned aviation operations and activities at all times.

16. The P IC will operate the aircraft from a stationary ground position and not from any moving device or vehicle.

17. No operation over congested or densely populated areas is allowed, whether

or not these a r eas are depicted on aeronautical charts.

18. The safety of pe ople and property is paramount, and no operations may be

conducted within 500 feet of non

- participants or their property unless conducted according to safety procedures in the CFOM , which are approved by the FAA.

19. All operations will be conducted over cont rolled access property for which permission has been obtained prior to flight, and for which safety briefings have been completed according to the CFOM

.

20. All incidents, accidents, and transgressions of allowed flight boundaries will be reported as required by FAA and NTSB.

BENEFIT TO THE PUBLIC

Approval of exemptions allowing Caddi s commercial operations of UAs will enhance safety by reducing risk. By removing the use of conventional jet fueled aircraft weighing in tons for light

- weight, battery operated UAs in restricted areas for aerial inspection, geo

- mapping and image and film capture, is more environmentally sound

and safe . The use of battery

- powered UAs provides a smaller environmental footprint, increases safety be de creasing manpower and separates the aircraft operators form the craft. It further protects the public by being used in restricted

environme nts and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETYCaddis Aerial, LLC Section 333 Petition for Exemption 14 The survey aircraft will be operated in accordance with safety protocols defined in the

CFOM , for which we request approval by the FAA according to its authority granted by Congress in Section 333 of the FAA Modernization and Reform Act of 2012.

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and weight are a small fraction of any manned aircraft, and its safety systems reflect best design practices in the UAS industry.

In addition, Caddis will keep the approved CFOM at its ground control station. The PIC will have immediate access to it. Previous exemptions granted by the FAA concerning Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft Flight Manual is kept at the ground contr ol station of a UAS , where it can be immediately accessed by the PIC.

When properly operated by trained pilots, a well

- designed UAS can stay clear of people and property on the ground and in the air. Procedures, airmanship skills, training and testing requirements for UAS personnel in the CFOM will let the operator achieve safety levels in the NAS and on the ground that are equivalen t to or greater than that in manned aviation

SUMMARY FOR PUBLICATION

The following summary may be published in the Federal Register:

Caddis requests an exemption from:

14 CFR Parts 61.113 (a) and (b) 14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) (1), 91.409 (a) (2), 91.417 (a)

in order to operate a small unmanned aircraft system ( UAS ) for purposes of a erial inspections and monitoring, aerial geo

- mapping, and aerial imaging and filming and

aerial data collection . The PIC will be appropriately qualified with a current FAA approved pilot certificate for UAS operation and specialized training.

Operations will include aerial survey, pipeline inspection, environmental mapping and monitoring of natural resources including forest and wetlands, resort and golf club inspection, rescue mission support and avalanche safety, cinematography, videography c apture are conventionally done by manned aircraft operations which useCaddis Aerial, LLC Section 333 Petition for Exemption 15 je t fuel and weigh upwards of 5,000 lbs. These operations must fly the aircraft to and

from the operation’s location.

The survey aircraft used are electric multirotor weigh ing less than 15 lbs.

, are less than four feet in diameter, are equipped with flight control and safety features that prevent flyaway and minimize s the risk to people and property allowed within and outside the zone of operations.

Flight operations outside the secure areas are not allowed . There are no impacts to privacy.