October 19 , 2015

U.S. Department of Transportation Docket Operations, M
- 30 1200 New Jersey

Avenue, SE Room W12
- 140, West Building Ground Floor Washington, DC 20590
- 0001 Re: **Petition of aEON Aerial Systems**  **for an Exemption Pursuant to Section 333 of the**  **FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System** Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, aEON Aerial Sy stems hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJ I PHANTOM 3 (“PHANTOM”), DJ I INSPIRE I (“ INSPIRE”) , DJ I Spreading Wings S1000 (“SPREADING WINGS”) all of which are manufactured b y DJ I Innovations. Additionally the 3DR Solo (“ SOL O ”) manufactured by 3D Robotics , and the G4 Skycrane (“ SKYCRANE ”) manufactured b y service drone . Where all equipment is being referenced they will be referenced as (“ THE EQUIPMENT”). **I. REGULATIONS FOR WHICH EXEM**  **PTION IS REQUESTED** aEON Aerial Sy stems requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a);  14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  14 C.F.R § 91.103;  14 C.F.R § 91.109(a);  14 C.F.R § 91.119;  14 C.F.R § 91.121;  14 C.F.R § 91.151(a) & (b)  14 C.F.R § 91.203 (a) & (b);  14 C.F.R § 91.405(a);  14 C.F.R § 91.407(a)(l);  14 C.F.R § 91.409(a)(2);  14 C.F.R § 91.417 (a) & (b).**II. STATUTORY**  **AUTHORITY FOR REQUESTED EXEMPTIONS**

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspace sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft s ys tem where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national sec urity based on the following considerations:

 The size, weight, speed and operational capability ;  Operation in proximity to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency ’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701
- 44716, et seq. A party requesting an exemption must explain the reasons wh y the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81. **III. D**  **ESCRIPTION OF aEON AERIAL SYSTEMS**  **AND ITS SERVICES** aEON Aerial Sy stems is a compan y that seeks to utilize UAV's in order to provide aerial imaging, photograph y, videograph y and cinematograph y. The contact information for the petitioner, aEON Aerial Sy stems , is as follows: Andrew Corwin Owner aEON Aerial Sy stems 3900 S Hualapai Way , Ste 126 Las Vegas, Nevada 89147 Office

- 702
- 688
- 6488 **IV. DESCRIPTION OF PROPOSED OPERATIONS**  aEON Aerial Sy stems is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to perform aerial photography , videography , and cinematograph y not limited to but including: Precision aerial photography & cinematograph y for commercial & residential real estate, surve yi ng, land & property mapping, inspection, construction, landscape, news, law enforcement, public & private events, advertising & marketing, utility

infrastructure, search & rescue, agriculture, oil & gas rural development
.**A. The**  **Aircraft**

aEON Aerial Sy stems will operate the DJ I PHANTOM 3 (“PHANTOM”), DJII NSPIRE I (“INSPIRE”), DJ I Spreading Wings S1000 (“SPREADING WINGS”) all of which are manufactured b y DJ I Innovations. Additionally the 3DR Solo (“ SOLO ”) manufactured by 3D Robotics , and the G4 Skycr ane (“ SKYCRANE ”) manufactured b y service drone. The PHANTOM is a battery operated quadcopter with a maximum flight time of 25 minutes. The vehicle weighs approximately 2.75 pounds with a maximum takeoff weight of approximately

2.75 pounds. It has fixed landing gear, vibration dampers, small frame air in cline and minimalized gimbal mount, which allows for a 110 degree of view from the camera. Although the vehicle’s ground speed has a maximum of 25 mph, it will be operated between 2 and 1 5 miles per hour, and it will operate at or below 400 feet AGL. Th e INSPIRE is a battery operated quadcopter with a maximum flight time of 18 minutes. The vehicle weighs approximately 5.3 pounds with a maximum takeoff weight of approximately 7.5 pounds. It has retractable landing gear, vibration dampers, small frame ai r incline and minimalized gimbal mount which allows for a 94 degrees of view from the camera. Although the vehicle’s ground speed has a maximum of 49 mph, it will be operated between 2 and 5 miles per hour, and it will operate at or below 400 feet AGL. The PHANTOM’s and INPIRE’s manufacturer’s specifications are shown in the Appendix of the Quick Start Guide and the USER Manuals for each airframe. The inherent safety features, sophistication, programmability , GPS navigation, return home capability , airport vicinity no - fly feature and restricted altitude feature, as well as differentiating radio frequency

(rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purposes of this petition. These are hobby grade radio controlled UAVs that has the capacity for software upgrades. It is light, less than 3 and 8 pounds respectively including battery and camera. Incorporated into the programming of the PHANTOM and INS PIRE is an automatic return home feature that automatically directs the craft back to point of take

- off should communication with the transmitter be lost. The Phantom has a cruising speed of 15 knots, with a maxi mum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 2.75 pounds. The Inspire has a cruising speed of 15 knots, with a maximum speed of 42 knots. Maximum flight time is 18 minutes. Gross weight is 7.49 pounds. The PHANTOM and IN SPIRE have a communication link between the camera and aircraft allowing the operator or Pilot in Command (PI C) to monitor battery level, altitude (AGL), distance from PIC, camera imagery , and also control camera angle. The software for the PHANTOM and INSPIRE allows the operator or PI C to set maximum altitude AGL for each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default programmed into the UAV's software pre

flight to insure compliance with FAA standards adding to the safet y capabilities of this UAV. This UAV is programmed to remain in position when controls are released, maintaining altitude and GPS location.The PHANTOM and IN SPIRE have an altitude and radar m onitoring function that allows the

operator more precise determination of height, direction of flight and distance from the operator/PIC. The operator/PI C can monitor GPS lock status while the UAV is in flight, with the ability to anticipate loss of GPS lo cking so the operator/PIC can land the UAV as a precaution. The SPREADI

NG WINGS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic laptop, tablet, or smart phone s ys tems. The DJ I SPREADI

NG WI NGS has a maximum gross weight of approximately 8.2kg, while having a length of 0.9m, a width of 0.9m, a height of 0.6m, and a maximum speed of approximately

20 knots. The DJ I SPREADING WI NGS UAS is equipped with six main electric powered rotors dri ven b y L ithium Poly mer batteries. The multi

- rotor can carry a payload of up to 13 pounds, and has been operated with a payload of high

- resolution DSLR cameras, infrared cameras, and video cameras for photograph y, videograph y, geospatial analysis and photo grammetry
. DJISpreading Wings S1000 1. Frame a. Diagonal Wheelbase 1045mm b. Frame Arm Length 386mm c. Frame Arm Weight (Including Motor, ESC, Propeller ) 325g d. Center Frame Diameter 337.5mm e. Center Frame Weight (With L anding Gear Mounting Base, Servos) 1330g f. Landing Gear Size 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) 2. Motor a. Stator Size 41×14mm b. KV 400rpm/V c. Max Power 500W d. Weight(With Cooling Fan) 158g 3. ESC a. Working Current 40A b. Working Voltage 6S LiPo c. Signal Frequency

30Hz ~ 450Hz d. Drive PWM Frequency 8KHz e. Weight(With Radiators) 35g 4. Foldable Propeller (1552/1552R) a. Material High strength performance engineered plastics b. Size 15×5.2inch c. Weight 13g 5. Flight Parameters a. Takeoff Weight 6.0Kg ~ 11.0Kg b. Total Weight 4.2Kg c. Power Battery

L iPo (6S 、 10000mAh~20000mAh 、 15C(Min)) d. Max Power Consumption 4000W e. Hover Power Consumption 1500W (@9.5Kg Takeoff Weight) f. Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight)g. Working Environment Temperature

- 10 °C ~ +40 °C

6. Gain Value Settings a. For A2 Flight Controller i. Basic: Roll 120%, Pitch 120%, Yaw 120% ii. Attitude: Roll 170%, Pitch 170%, Vertical 120% b. For WooKong
- M Flight Controller i. Basic: Roll 180%, Pitch 180%, Yaw 120% ii. Attitude: Roll 180%, Pitch 180%, Vertical 120% The DJ I S1000 has been approved for commercial operations in Exemption Nos. 11280, 11279, 11278, 11863, 11260, 11253, 11228, 11160, and 11161
. The SOLO is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone s ys tems . The SOLO UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. 3DR SOL O KIT 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set

– Black, 3DR Solo Battery Charger, 3DR Solo Controller Charger Specifications: 1. General a. Weight: 3.3 lb / 1.5 kg. b. With Solo Gimbal and GoPro: 4 lb 2. Performance a. Maximum Speed : 55 mph / 88.5 km/h b. Maximum Altitude : 400' / 121.9 m AGL c. Flight Time : Up to 25 minutes 3. Flight Control Sy stem a. Model : Pixhawk 2 b. Software : APM flight control software and GPS 4. Handheld Transmitter a. Display : Color Screen for menu and live flight telemetry b. Battery : Lithium

- poly mer Capacity: 5200 mAh . Voltage: 14.8 VDC L ife: Up to 4 hours c. The 3DR Solo remote controller has an operating frequency of 2.4 GHz for telemetry and control. d. Maximum transmission distance: up to 2,500 ft (outdoors and unobstructed) 5. Mobile App a. Sy stem Requirements: Wi

- Fi enabled iOS or Android mobile device b. Wi

- Fi Range : Up to 2640' / 805 m (depending on environment) 6. FPV and Monitoring a. Video Downlink Latency: 180 ms b. Connectivity : 1 x HDMI output on Transmitter 7. Components a. Rotors : 4 x 10 x 4.5" / 25.4 x 11.4 cm self

- tightening propsb. Motors Velocity Constant: 880 kV c. Gimbal Compatibility : Solo Gimbal for HERO3+ and HERO4 GoPro Cam era 8. Flight Battery a. Model : Solo Battery

Voltage14.8 VDC b. Lithium

- poly

mer Capacity

5200 mAh The 3DR Solo has been approved for commercial operations in Exemption Nos. 12462, 12494, 12441, 12544, 12433, and 11935. The SKYCRANE is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) T he SKYCRANE is equipped with the latest MUL TIROTOR flight

- control, which allows an unprecedented flight and image stability . This is ensured by a 32
- bit p rocessor of the MULTIROTOR flight

- control with about 10 times more computing capacity, the most modern hardware components and a referenced GPS sy stem. Substantially

enhanced is the flight performance by the newl y developed engines. Brushless motors made by

Plettenberg as well as individually designed three

- blade rotors with winglets enable the most effective and s ilent uplift ever in this class. In comparable flight stability , due to the latest 32

- bit dual

- processor technology , which corrects the flight p osition 512 times per second and enables secure drone flight. No
- Panic

- Fun ction allows the UAV keeps its current position and place.

 Technical range 2,000 meter min.  Autopilot with 250 meter flight radius, position hold, coming home, automatic altitude c ontrol  Brushless gears from Plettenberg with handcrafted three

- blade rotors  Li ght and unbreakable full carbon frame  Two
- way

data telemetry

with language assistance  High performance flight battery (2 units)  Attitude control 512 times per second Yes  Automati c treble control 24

- bit barometric Yes  Autonomous flight max. 500 way points Optional  Auto start / auto landing assistant Optional  Battery

redundancy Yes  Cantilever beam plug s ys tem Optional  Camera suspension Optional  Digital option port (for future applications) Yes  Digital RC transmitter pilot Optional  Dimens ion Ø 114 cm, H. 50cm  D rive redundancy Yes  Emergency

L anding Yes  Device hull insurance Europe Optional  Flight Control MULTIROTOR G4 Dual 32 bit Yes Flight Control redundancy Optional

 F light data log 128 bit  Flight training and flight practice certificate Optional  GPS flight assistant (position Hold, Coming Home) Yes  Inspection (12 months, 25 flight lines, 350 starts) Optional  L1 GPS Yes  Live

- View 5.8 GHz Diversity Yes  M ax. airspe ed 40
- 50 km/h  M ax . Flight time (ideal) 12 Minutes  M ax. Take

- off weight (ideal) 12000 g  Pack size 97x97x 25cm (demontiertes Gimbal)  Payload (incl. camera suspension and flight battery) 6500 g  Servo connectors 6  Wind stable up to 10
- 15 m/s Considering the programmability and safety features of these UAVs, it serves as the best option to protect the Public and NAS for the purposes of this petition. Similarities, Distinctions and Differences aEON Aerial Sy stems is using a UAV that has the capability for taking off and landing at a single point, identical to a helicopter. There are no runway s, aided take off apparatuses, nor routes that need to be flown to areas being aerial video recorded or photographed. Allowing a reduced and more confine d area of flight. The motors, rotors, propellers, body /frame, landing pads, etc. for the UAV utilized in this petition are not complicated. Engineering and design allows lay man maintenance. Pre

- flight inspections for cracks, damage or other phys ical conditions that could hamper safe flight will be conducted prior to an y and all missions. Post flight inspections will also be conducted in order to aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thorough inspectio n of the UAV shall be conducted and flight response tested should a hard landing or crash occur insuring that the UAV can operate in a safe manner before conducting any further missions. Like the Astraeus Petition Petitioner aEON Aerial Sy stems request s waiver or exemption for markings due to the small size of the fuselage for THE EQUIPMENT
. Petitioner aEON Aerial Systems requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition of flight in co ngested areas. Petitioner aEON Aerial Sy stems requests waiver for this condition to allow reasonable and responsible videograph y in congested areas of subdivisions and neighborhoods. In compliance with Section 90.151 (a) THE EQUIPMENT are battery operat ed UAV/UAS with battery level monitoring capability . Full y charged battery flight time is rated at 18
- 25 minutes, with videos/photos taking much less time to record. Operator or PI C is warned when battery level is low.Petitioner aEON Aerial Systems requests waiver/exemption from Section 91.203 (a) since the

Phantom is a hobby

grade UAV/UAS that should not require an airworthiness certificate. Posting of special flight authorization would not be possible since THE EQUIPMENT have no cabin and are not larg e enough to carry a certificate. However, a special flight authorization can be maintained by

the operator to make available upon request. **B. aEON Aerial Systems**  **Proposed Operations Demonstrate an Equivalent Level of Safety**  **1. General Description of Proposed**  **Flight Operations** aEON Aerial Sy stems proposes to operate within the limitations and performance specifications listed in the USER MANUAL S (see attachments) , which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory

structure because the proposed operations represent a safety enhancement to the protocols. The proposed operations do not create any hazard to users of the national airspace s ys tem or pose a thre at to national security . The aircraft is a battery operated quad copter with a maximum flight time of 18

- 25 minutes. THE EQUIPMENT weighs approximately 2.6

– 25 pounds. It has vibration dampers and small frame air incline. The vehicle’s ground speed has a m aximum of 2 5
- 49 mph but it will be operated between 5 and 3 5 miles per hour, and it will operate at or below 2 00 feet AGL. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. THE EQUIPMENT carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated b y the petitioner reduces the risk to participating persons in close pro ximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of THE EQUIPMENT
. The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology , is mitigated b y placing limits on altitude, requiring stand

- off distance from clouds, permitting day time operations onl y, requiring that the aircraft be operated within visual line of sight , and requiring THE EQUIPMEN T to yi eld right of way to all other manned operations. Additionally , the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 13
. The petitioner’s aircraft has the cap ability to operate safely

after experiencing certain in

- flight failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifically low battery RTH and failsafe RTH . The aircraft is also able to respond to a lost

- link event with a pre coo rdinated, predictable, automated flight maneuver.**2. Reasons why the exemption would not adversely affect safety or how the**  **exemption would provide a level of safety at least equal to the existing rule.** Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, aEON Aerial Sy stems proposed operations using THE EQUIPMENT would “not create a hazard to users of the national airspace sy stem or the public or pose a threat to national security .” Reform Act Section 333(b ) ( 1). 1. The aircraft will be identified by serial number, registered with the FAA, and have identification (N

-Number) markings as large as practicable. 2. Flights will be operated within visual line of sight of the pilot in command (PI C). 3. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy

by PI C. 4. Maximum flight time for each operational flight will be approximately 15
- 20 minutes. 5. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. 6. The aircraft will be operated during daylight and in VFR conditions. 7. Flights will be operated at a lateral distance of at least 50 feet f rom an y persons or property not associated with the operation who have not given prior permission. 8. Flights will be limited to a groundspeed of 5

- 35 mph. 9. The PI C will possess at least a sport pilot certificate and a valid state driver’s license. 10. Any designee from aEON Aerial S ys tems will have completed a Basic Operator Course for THE EQUIPMENT
. 11. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 12. The flight operations will yield the right of way to other manned aircraft operations. 13. All persons who are not involved with flight operations w ill be required to stay 5 0 feet from the edge of the flight operation perimeter. 14. aEON Aerial Sy stems will provide NOTAM de tails to the FAA 24 hours prior to each flight. 15. All required permissions and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 16. Prior to commencing operations, aEON Aerial S ys tems will obtain a Certificate of Waiv er or Authorization (COA) from the FAA if flying above 200 feet AGL. 17. If the aircraft loses communications, it will have the capability to return to a pre determined location within the operational area and land. 18. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 19. The flight will be aborted in case of unpredicted obstacles or emergencies. 20. Each flight will be recorded in an Operations L og Book. 24. Maintenan ce on the aircraft will be recorded in a Maintenance Lo g Book.**3. Flight Recovery, Lost Communications, and Lost GPS Procedures** 

The flight recovery , lost communications, and lost GPS procedures are fu lly documented in the attached User Manuals. **V. SPECIFIC**  **FAR EXEMPTIONS REQUESTED**
aEON Aerial Sy stems seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations THE EQUIPMENT
. Listed below are (1) the specific FAR sections fo r which exemption is sought, and (2) the operating procedures and safeguards that aEON Aerial Sy stems has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

**A. 14**  **C.F.R. Part 21, Subpart H**

**– Airworthiness Certificates and 14 C.F.R.**  **§ 91.203(a)(1)** The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety whe n compared to aircraft normall y used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014

- 0352 at 13
- 14, 22. If, however, the FAA determines that there are s ome characteristics of THE EQUIPMENT that fail to meet the requirements of the Reform Act, an exemption is requested. **Equivalent Level of Safety:** THE EQUIPMENT are safe when taking into account its size, weight, speed, and operational capability
. THE EQUIPMENT weighs approximately 2.6
- 25 pounds and either wil l be flown at speeds of 5
- 35 miles per hour, and in visual line of sight of the operator
. THE EQUIPMENT do not carry pilots, passengers, explosive materials, or flammable liquid fuels. THE EQUIPMENT will be operated within the parameters of the User Manuals. aEON Aerial Sy stems will also provide the FAA with advance notice of all operations via a NOTAM and coordination with the local Flight Standards District Office ( FSDO ) . The proposed operations wi ll be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

**B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft**  14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent THE EQUIPMENT would otherwise require certification under Part 27, aEON Aerial Sy stems seeks an exemption from Part 27’s airworthiness stand ards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and**  **Identification Requirements** 14 C.F.R. §45.23(b), Markings of the Aircraft states:When marks include only the Roman capital letter “N” and the registration number is displayed

on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near e ach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport, “experimental ,” or “provisional,” as applicable. 14 C.F.R. § 45.27(a) states: **Rotorcraft.** Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. 14 C.F.R. § 91.9(c) states: No person may

operate a U.S.
- registered civil aircraf t unless that aircraft is identified in accordance with part 45 of this chapter. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N

-Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14. **Equivalent Level of Safety:** aEON Aerial S ys tems will mark all THE EQUIPMENT with their N
- Number in a prominent spot on the fuselage with markings that are as large as practicable.

**D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations**  aEON Aerial Sy stems seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PI C matches the airspace in which the PI C will be operating, as well as requiring certifications if the pilot is carryi ng passengers or cargo for hire. While THE EQUIPMENT will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA
- 2014
- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PI C to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined th at the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The PI C will possess at least a sport pilot certificate, a third class medical certificate, and w ill have completed a Basic Operator Course for THE EQUIPMENT . This is a 1
- day program that includes ground school and flight training.The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the

overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS
- specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 18. The proposed operations can achieve an equivalent level of safety b y requiring the knowledge and experience in THE EQUIPMENT operations described above. The restrictions aEON Aerial Sy stems has placed on THE EQUIPMENT operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA
- 2014
- 0352. aEON Aerial Sy stems will operate in restricted areas (the s ites) away from persons and property not involved in the operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified s ites. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.

**E. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness**  aEON Aerial Sy stems seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Ac cordingl y, aEON Aerial Sy stems requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft;**  **14 C.F.R. §§**  **91.203(a) and (b): Carrying Civil Aircraft Certification and Registration**  Pursuant to 14 C.F.R. § 91.9(b)(2): (b)No person may

operate a U.S.
- registered civil aircraft

-

... (2)For which an Airplane or Rotorcraft Flight Manual is required b y § 21.5 of thi s chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a)Except as provided i n § 91.715, no person may operate a civil aircraft unless it has within it the following: (1)An appropriate and current airworthiness certificate.(b)No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. aEON Aerial Sy stems does not request an exemption from this section but instead notifies the F AA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PI C during flight. The Chief Counsel’s Office has h eld that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19
- 20, and Grant of Exemption No. 8607.

**G. 14 C.F.R.**  **§ 91.103: Preflight Action**  aEON Aerial Sy stems seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA
- approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Under these circumstances, the FAA has stated that no exemption is requi red. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA
approved Flight Manual is required. **Equivalent Level of Safety:** An equivalent level of safety will be provided by following the User Manuals. The PIC will take all required preflight actions

- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas

- before initiation of flight. The User Manuals will be kept at the ground station ; with the operator at all times.

**H. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  aEON Aerial Sy stems seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o person may

operate a civil airc raft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted aircraft, b y their design, do not have functional dual controls. Instead, flight control is a ccomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with the aircraft via radio communications. **Equivalent Level of Safety:** When flight instruction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of THE EQUIPMENT , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. These flights will comply with the provisions in the User Manuals. Accordingl y, aEON Aerial Sy stems proposed method of operation provides superior levels of safety.**I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas** 

aEON Aerial Sy stems requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by aEON Aerial S ys tems
. See Grant of Exemption No. 11062, p. 20
- 21. **Equivalent Level of Safety:** Compared to flight op erations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presentl y exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of THE EQUIPMENT , as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set forth in the User M anuals and herein, THE EQUIPMENT will be operated at s ites, away from persons or structures not involved in the operation. All persons who are not involved with aEON Aerial Sy stems operations wi ll be required to be at least 50 feet from the flight operation perimeter.

**J. 14 C.F.R.**  **§ 91.121: Altimeter Settings**  This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport. THE EQUIPMENT use both barometric pressure sensors and G PS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that THE EQUIPMENT do not have a barometric altimeter setting. The altitude of the aircraft is monitored b y the PI C on the ground control station and by the visual observer. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual line

- of

- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20
- 21. As the attached User Manuals indicate, THE EQUIPMENT will be operated at or below 400 feet AGL and compl y with the limitations in the Grant of Exemption No. 11062. **K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  aEON Aerial Sy stems requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may

begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or(2) At night, to fly after that for at least 45 minutes. Here, the technological limitations on THE EQUIPMENT battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery

powered with a maximum flight time of between 18

- 25 minutes. aEON Aerial Sy stems proposes that the maximum flight time for each operational flight will be 18
- 2 5 minutes. The aircraft will be safel y landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21
- 22. The User Manuals pr oviding an equivalent level of safety b y s afel y landing with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and otherwise compl yi ng with the flight restrictions above.

**L. 14 C.F.R. §§ 91.405(a), 91.40**  **7(a)(l), 91.409(a)(2); 91.417(a) and (b):**  **Maintenance Inspections** aEON Aerial Sy stems seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certif icate, which THE EQUIPMENT will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, an d inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14
- 15. As provided in th e Manuals, flights will not be conducted unless a flight operations checklist is performed that includes all of the aircraft’s components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post - flight mai ntenance. The Manuals set requirements for both annual maintenance and preventative maintenance. **VI. PUBLIC INTEREST**  Granting aEON Aerial Sy stems petition for exemption furthers the public interest. National policy set b y Congress favors earl y integration of UAS into the NAS in controlled, safe working environments as proposed in this petition. By granting this petition, the FAA will fulfillCongress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Secti on 33 3 of the Reform Act.
aEON Aerial Sy stems will operate in a manner that will ensure the public’s safety and will set the example for others to emulate. It is well established that UAS provide an additional tool for the filmmaking industry , adding a greater degree of flexibility , which supplements the current capabilities offered b y m anned aircraft
. **VII. PRIVACY**  All flights will be conducted in accordance with any federal, state or local laws regarding privacy
. All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they will be made anony

mous. **VIII. NATIONAL SECURITY**  Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue. Furthermore, the security screening conducted b y the Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security. **IX. SUMMARY FOR FEDERAL REGISTER**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: aEON Aerial Sy stems seeks an exemption from the following rules in order to provide aerial imaging, photograph y, vid eograph y and cinematograph y : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C. F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l ); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b). The exemption will enhance safety b y reducing risk to the operator, the general public and property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation , and flight operations. **X. ATTACHMENTS**  Attachment 1: DJ I Phantom Pilot Training Guide v1.1 Attachment 2 : DJ I Phantom 3 Professional User Manual v1.2 Attachment 3 : DJ I Phantom 3 Quick Start Guide v1.0 Attachment 4 : DJ I Phantom 3 Safety Guidelines Disclaimer Attachment 5 : DJ I Inspire 1 User Manual v1.2 Attachment 6 : DJ I Inspire 1 Quick Start Guide v1.2Attachment 7 : DJ I Inspire 1 Safety Guidelines

Attachment 8 : DJ I Inspire 1 Maintenance Manual v1.0 Attachment 9 : S1000 User Manual v1.10 Attachment 1 0 : Multirotor SKYCRANE G4 Product Information Attachment 11 : 3DR Solo Manual **XI. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act

- size, weight, speed, operating capabilities, proximity to airports and populated areas, operatio n within visual line of sight, and national security considerations

- provides more than adequate justification for the grant of the requested exemptions to permit aEON Aerial S ys tems to operate THE EQUIPMENT
. Granting the requested exemption will benefit the public interest as a whole in many way s, including (1) significantly improving safety and reducing risk by

alleviating human exposure to danger; (2) improving the quality of services aEON Aerial S ys tems can provide to its customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft Respectfully

submitted, By : /s/ Andrew Corwin Owner aEON Aerial Sy stems