U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room wl2-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Petition for Exemption Under 14 CF'R $ 11.S1 to Allow Commercial

Use of Unmanned Aircraft Systems

July 9, 2015

Petitioner:

Adams Integrated Robotics

James H. Adams, Jr., CEO

645 Adams Rd

Rowland NC 28383

Tel.: 910-422-2000

Email : ur9 I 0 42220 0 0 @ gmail. com

To Whom It May Concern,

This application is substantially based on the FAA's findings in Exemption No. 1 135 | granted to

bizUAS Corp on April 17, 2015, and in reliance on the analysis provided therein.

l. : Application is hereby made for gxemption

from:

a. FAA Modemization and Reform Act of 2012, PL I 12-95 FEB. 14, 2012, Section 333

b. 14 CFR Paft2l, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. l4 CFT Part 91: i. e1.103(bx2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 9l.l2l

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417
2. Relief sought:

Adams Integrated Robotics wishes to operate small unmanned Aircraft

Systems (suAS) for commercial purposes to include (but not be limited to)

l. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television,

public events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authoritv.

4. Aeial inspection/photography of residential/commercial utility infrastructure including

but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. The ability to offer training to persons individually or to those belonging to both

private and/or public organizations that have interests in the use and application of a UAS

for the purpose of the safe operation of a UAS to enhance the safety of the National

Airspace System (NAS) as well as for the protectiion of the persons and property.

b: This exemption will cover use of the following airframes, all of which will weigh less

than 55 pounds including payload and energy sources:

DJI Phantom2+, DJI Phantom 3, DJI Spreading Wings, ilDRobotics Solo, 3DtRobotics

Aero, 3DRoboticsIRIS+, 3DRobotics X8.

Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently

obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents

(e.g., power line inspections) and due to other dangerous activities that

can be avoided (e.g., scaffolding/rigging failures during stack or bridge

inspections).

ii. Reduces the cost of obtaining such information, which benefits

consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft.

Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 4471I and Pan

47 andPart45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the

manufacturer. All repair and maintenance work will be conducted or approve,d by

3.

4.
qualified personnel such as those authorizedby Robotic Skies (or equivalent,), and

will require a test flight after such work. Records of all maintenance and reparir

work will be kept in a maintenance log for each aircraft.

c' All flight operations will be conducted by at least two individuals (PIC and

observer) who will maintain verbal communication capability with each other at

all times during the flight, and who will remain stationary on the ground durirrg

the flight operations: PIC will hold either an airline transport, commercial, private,

recreational, or sport pilot certificate. The PIC will also hold a current FAA airman

medical certificate or a valid U.S. driver's license issued by a State. The pIC will also

meet the flight review requirements specified in 14 CFR $ 61.56 in an aircrafl in which

the PIC is rated on his or her pilot certificate.

d. All flight operations will be conducted in accordance with valid Certificates of

Authorization

e. All flight operations will comply with the following: i. The manufacturers'Aircraft Flight Manuals and Operation Guidelines ii. Adams Integrated Robotics flight operations policies including lost

communication and other emergency and safety procedures. iii. Conducted in VMC conditions during daylight hours. iv. PIC and VO will maintain VLOS at all times.

Pre-flight inspections (including ground control station, if any) and

safety risk assessments will be conducted prior to each flight.

Flight altitudes will remain below 400 feet above ground level.

Flight ground speeds will not exceed 50 knots.

Not intrude into Class B, C or D airspace.

Not be made near persons as required in I 4 CIrR 91 . 1 1 9 and not ovrlr

persons on the ground without their prior permission.

x. Each flight will be logged in both the PIC's and the aircraft logbooh. xi. Any incidents will be reported to NTSB within 24 hours of occurrence.

xii. Any applicable local FSDO requirernents.

Xiii. All other applicable regulations concerned with the operation of aircraft

Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending;data

with well- defined and tested lost link procedures in accordance with the UAS

Manufacturer User Manual.

v.

vi.

vii.

viii.

ix.

Sincerely,

James H. Adams, Jr.

CEO

Adams Integrated Robotics