3525 Santa Monica Dr. Abilene, TX 79605 (713) 598

- 3027 www.chaneyaerospace.com inquiries@chaneyaerospace.com

January 5, 2016 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 11, Chaney Aerospace, LLC, hereby applies for the grant of exemption from certain Federal Aviation Regulations for the PROtect multirotor manufactured by Chan ey Aerospace of Abilene, TX and the Apprentice S 15e fixed wing aircraft manufactured by E

- flite of Champaign, IL.

The Requested exemption would support an application for a commercial Certificate of Authorization to

use the PROtect sUAS and Apprentice S 15e sUAS to support aerial surveying, specifically wildland firefighting.

As detailed in this document and the attached PROtect and Apprentice S 15e User Guides, the requested exemption would permit the operation of a sUAS under controlled conditions in ai rspace that is limited, predetermined, controlled as to access, and would provide safety enhancements to the safety protocols by Chaney Aerospace, LLC. Approval of this exemption will also be in the interest of the general public as it will help aid wildl and firefighting efforts and will not invade on the privacy of the public.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 provides justification for the grant of the requested exemptions allowing commercial operation of Chan ey Aerospace’s sUASs for wildland firefighting efforts. We are prepared to modify or amend any part of our request to ensure an equivalent level of safety. If you require additional information, please do not hesitate to contact us at the

number listed.

S incerely,

Will Chaney,

Owner Chaney Aerospace, LLCChaney Aerospace, LLC Page 2 of 9 NAME AND ADDRESS OF APPLICANT

Chaney Aerospace, LLC Will A. Chaney

3525 Santa Monica Dr. Abilene, TX 79605 (713) 598

- 3027 wchaney@chaneyaerospace.com

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 CFR Part 21

14 CFR 45.23 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b)

VEHICLE DESCRIPTIONS

The aircraft Chaney Aerospace plans to use are the PROtect and the Apprentice S 15e.

Chaney Aerospace, LLC PROtect

The PROtect is a multirotor, more specifically a quadcopter, airframe manufactured by Chaney Aerospace, LLC. The PRO tect has a total weight of 6.5 pounds and can carry a payload up to 1.5 pounds. This gives the PROtect a maximum takeoff weight of 8 pounds. The PROtect is electrically powered by lithium polymer batteries and has a maximum flight time of 10 minutes . The maximum range of the aircraft is limited to visual line of site. Therefore, we have deemed the maximum operation range to be 1.5 nautical miles. The aircraft will not be flown when maximum sustained winds are above 30 miles per hour. For all flights, the a ircraft will take off and land vertically.

The PROtect has the ability to be controlled with computer assistance or completely by the computer through the onboard Pixhawk flight controller manufactured by 3D Robotics of California. Because the

PROtect is a multirotor, at all times during manual operations, flight is computer assisted to increase stability of the aircraft. Manual flight is controlled directly by the pilot in command. Autonomous flights are programmed through software at the ground control s tation (GCS). At the GCS, the aircraft can be programmed to fly specified courses through GPS.

Using the Pixhawk allows Chaney Aerospace to set operational thresholds on the flight controller such as battery reserve, altitude, range, and remote connectiv ity. Altitude is measured by a barometric pressure sensor on the Pixhawk and range is measured using onboard GPS. Ground speed is measured throughChaney Aerospace, LLC Page 3 of 9 GPS. The Pixhawk will not allow range or altitude parameters to be exceeded. In the event that connectivity i s lost with the pilot in command (PIC) remote control or the battery gets too low, the PROtect is programmed to return to the point of take

- off. For safety precautions, the PIC always has a switch on his remote programmed to force the aircraft to return to its take

- off point.

E

- flite Apprentice S 15e

The Apprentice S 15e is a fixed wing airframe manufactured by E

- flite. The Apprentice S 15e has a total weight with fuel of 3. 5 pounds and can carry a payload up to 1.75 pounds. This gives the Apprentice S

1 5e a maximum takeoff weight of 5.25 pounds . The Apprentice S 15e has a length of 42.5 inches and a wingspan of 59 inches. The aircraft has a speed range of 10 knots up to 40 knots. The Apprentice S 15e is electrically powered by lithium polymer batteries a nd has a maximum flight time of 30 minutes. The maximum range of the aircraft is limited to visual line of site. Therefore we have deemed the maximum operation range to be 1.5 nautical miles. The aircraft will not be flown when maximum sustained winds

are above 30 miles per hour. For take

- off, the aircraft may be hand launched or use a runway. All landings will require use of landing gear on a runway.

The Apprentice S 15e has the ability to be controlled manually, with computer assistance, or completely by the computer through the onboard Pixhawk flight controller manufactured by 3D Robotics of California. Manual flight is controlled directly by the pilot in command. Autonomous and semi

autonomous flights are programmed through software at the GCS. At the GCS, the aircraft can be programmed to fly specified courses through GPS with specific limitations.

Using the Pixhawk allows Chaney Aerospace to set operational thresholds on the flight controller such as battery reserve, altitude, range, airspeed, and remote connectivity. Altitude is measured by a barometric pressure sensor on the Pixhawk and range is measured using onboard GPS. Airspeed is measured using a pitot static tube on the wing of the aircraft. Ground speed is measured through use of GPS. The P ixhawk will not allow range, airspeed, or altitude parameters to be exceeded. In the event that connectivity is lost with the PIC’s remote control or the battery gets too low, the PROtect is programmed to return to the point of take

- off and circle at a spe cified altitude. For safety precautions, the PIC always has a switch on his remote programmed to force the aircraft to return to its take

- off point.

Avionics System

For both aircraft, the avionics system will include a Pixhawk flight controller, radio r eceiver, and a data transmitter/receiver utilizing 915Mhz.

Payload

Both of the previously mentioned aircraft will have the capability and/or need to carry a high resolution

camera on a multi

- axis gimbal. In order to transmit video, a 5.8Ghz transmitter will be used. The video transmitter we use is permitted for use by the FCC. There for an FCC license is not needed for operation.

Aircraft Control

Manual control will be achieved using a 2.4 Ghz radio control. Telemetry data and autonomous controls

from the ground station will be transmitted and received on 915Mhz radio frequency. It should be noted that an FCC license is not required for the radio control or telemetry transmitter that will be used.Chaney Aerospace, LLC Page 4 of 9 Ground Control Station

The ground control station will consist of a computer for monitoring telemetry data from the aircraft in flight as well as programming the aircraft for autonomous flight. There will also be at minimum one video monitor for monitoring live video feed which is vital during wildfire opera tions. Operational checklist will also be located at the GCS along with the operations manual. The crew at the GCS will comprise of a PIC, a Visual Observer (VO), and at minimum one sensor/software operator. The sensor and software operators will process a erial maps and photogrammetry software to aid in operations.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

14 CFR Part 21, Subpart establishes procedural requirements for the issuance of airworthiness certificates. Given the size, weight, and limited operating area associated by the sUAS’s to be used by Chaney Aerospace, an exemption meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. The FAA is auth orized to exempt aircraft from the requirement for an airworthiness certificate. This exemption can be based upon consideration of the size, weight, speed, operational capabilities, proximity to airports, and proximity to populated areas of the sUAS in que stion.

A s UAS operated without an airworthiness certificate in the restricted environment and under the conditions and limitations proposed by Chaney Aerospace will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) oper ating with an airworthiness certificate issued under 14 CFR Part 21, Subpart H, and not subject to the proposed limitations and conditions.

1 4 CFR 45.23: Display of Marks

14 CFR 45.23 requires that operators of an aircraft must display the letter “N” fo llowed by the registration number. It also requires that for light

- sport, experimental, or provisionally certificated aircraft, the operator must display “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional” near each

entrance to the cab in, cockpit, or pilot station. The letters must be between 2 and 6 inches high.

Although the UAS will not have an airworthiness certificate, an exemption may be needed because the UAS does not require a pilot. Because there is no pilot, there is no entran ce to the cabin, cockpit, or pilot station to where the word “Experimental” can be displayed. Also, 2 inch lettering will not be possible due

to the size of the aircraft.

The aircraft will be marked with registration information on an exterior surface as well as the following:

Chaney Aerospace, LLC

3525 Santa Monica Dr. Abilene, TX 79605 (713) 598

- 3027

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

14 CFR 61.114(a) & (b) limit private pilots to non

- commercial operations. Chaney Aerospace will not carry a pilot or passengers, therefore the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating Chaney Aerospac e’s air craft to have a private pilot’s

license rather than a commercial pilot’s license to operate the small UASs previously listed. Unlike a

conventional aircraft that carries a pilot and passengers, Chaney Aerospace’s UASs are remotely

controlled with no persons onboard. The area of operation will be controlled and restricted, and all flightsChaney Aerospace, LLC Page 5 of 9 will be planned and coordinated in advance. The risks associated with the operation of the PROtect and Apprentice S 15e are so diminished from the level of risk asso ciated with commercial operations contemplated by 14 CFR Part 61 that allowing operations as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR 61.113(a) & (b).

14 CFR 91.7(a): Civil aircraft airworthiness

1 4 CFR 91 .7(a) prevents an aircraft from flying unless it is in an airworthy condition. Because an airworthiness certificate will not be issued for the sUAS, there will be no FAA standard for determining

airworthiness.

By using safety checklists prior to flight and following the user manual for maintenance, an equivalent standard of safety will be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

Due to the size of the sUAS, and that there is no pilot onboard, i t has no ability or need to carry a flight manual. Also, if the manual were kept in the aircraft, the PIC would not have access to it during flight operations.

To keep a standard of safety, a flight manual will be kept at the ground control point allowin g the pilot of

the sUAS to have immediate access to the aircraft manual.

14 CFR 91.103: Preflight action

This regulation requires each pilot in command shall become familiar with all available information concerning to flight as well as take certain act ions.

An exemption is requested because the preflight actions will be slightly different than that of a manned aircraft. Our pilot will take separate actions such as checking weather conditions, flight battery requirements, checking takeoff and landing di stances, and all other actions in the user guide and safety checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned fre e balloon) that is being used for flight instruction unless that aircraft has fully functional dual controls. By design, sUASs and remotely operated aircraft do not have onboard controls since the aircraft are not manned by a pilot.

Manual control of the f light is accomplished through the use of a control box that communicates with the

aircraft via radio communication.

An equivalent level of safety is provided by the fact that neither a pilot nor passengers will be onboard the aircraft. Also, in the event that a pilot needs to be trained for an aircraft, two remote controls can be linked allowing the trainer to regain control of the aircraft from the trainee at any time. This provides for a safe training experience.

14 CFR 91.119: Minimum safe altit udes

14 CFR 91.119 requires that an aircraft must fly at a minimum of 500ft AGL unless taking off or landing. It also states that an aircraft may not be operated within 500 feet of any person, vessel, vehicle, orChaney Aerospace, LLC Page 6 of 9 structure. Since we are flying a sUAS, we must fly below 400ft AGL. Therefore we cannot comply with

this rule.

By flying below 400ft AGL, this will keep us out of the way of other manned aircraft in the same airspace which provides safety to those in the air space around us. Certain missions may require us to be closer than 500ft to people, vessels, vehicles, and or structures. This is because the aircraft will be used in firefighting situations where such objects or personnel will be in the area. Due to the size of the aircraft compared to a man ned aircraft, the risk posed to objects and personnel is not comparable to that of a manned aircraft and should be considered in granting an exemption. Furthermore, the aircraft will not be operated over any property without the land owner’s permission, an d it will not be operated over congested areas. Any personnel on the ground with fire operations will be briefed of the safety risks involved with a sUAS flying in the airspace above them. Also, the aircraft will be operated at an altitude allowing an emer gency landing without undue hazard to persons or property if mechanical system failures

arise.

14 CFR 91.121: Altimeter settings

14 CFR 91.121 outlines the requirements for setting the altimeter in flight. These regulations provide that

the aircraft mus t maintain cruising altitudes by referencing altimeter settings within 100 nautical miles of

the aircraft.

Seeing as all flights will be kept below 400ft AGL, and will not be long distance, we find that it is more important to zero the onboard barometric altimeter prior to each flight. This will make it easier for the

PIC to confirm the altitude of the aircraft.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

14 CFR 91.151(a) prohibits a person from beginning a flight in VFR conditions unless there is enough fuel onboard the aircraft to reach the destination and fly for at least 30 minutes after. At night, the aircraft must be able to fly for 45 minutes after reaching its destination. We believe this section is set forth to provide the i ntent of a fuel reserve on the aircraft.

The PROtect is battery operated with a maximum flight time of 8 minutes with full payload with a single battery charged at 100%. Because the aircraft will not be flown more than 1/4 mile from the point of

intende d landing, a full battery charge at launch with a 10% fuel reserve will give the aircraft plenty of time to reattempt a landing. This scenario is highly unlikely as the aircraft does not need a runway because it is a multirotor and will land vertically on a predetermined spot. All aspects of flight: takeoff, climb, cruise, hover, descent and landing will be calculated with regards to time and fuel consumption in order to use the battery power effectively and to ensure we always land with a 10% fuel reserve.

The Apprentice S 15e is battery operated with a maximum flight time of 30 minutes with full payload with a single battery charged at 100%. Because the aircraft will not be flown more than 1.5Nm mile from the point of intended landing, a full battery ch arge at launch with a 15% fuel reserve (4.5 minutes) will give the aircraft plenty of time to reattempt a landing if needed and meet the intent of a fuel reserve. All aspects of flight: takeoff, climb, cruise, descent and landing will be calculated with re gards to time and fuel consumption in order to use the battery power effectively and to ensure we always land with a 15% fuel reserve. We believe that an equivalent level of safety is achieved because 4.5 minutes is more than enough time to attempt several landings if needed.Chaney Aerospace, LLC Page 7 of 9 14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The sUAS does not have a cabin, cockpit or pilot station and is operated without an onboard pilot. Because of this, there is no way to carry or display certification and registration documents.

To keep a standard of safety, documents applicable to the sUAS will be kept at the GCS where the pilot

will have immediate access to them.

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

These regulations that the owner or operator of an aircraft must have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancie s repaired as prescribed in part 43 of this Chapter and others shall inspect and maintain the aircraft in compliance with Part 43.

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply t o Chaney Aerospace, LLC. Maintenance will be accomplished through the operator pursuant to the user manual of the aircraft as well as maintenance techniques developed by Chaney Aerospace. Chaney Aerospace will designate, train, and document personnel who have authorization to perform inspections, maintenance, and alterations by means of maintenance instructions. Chaney Aerospace will ensure that its UASs are in working order prior to initiating each flight, perform regular maintenance, and keep a log of an y maintenance performed. Chaney Aerospace, more specifically Will Chaney, is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition to ensure safe operations. Due to the aircraft being limited in si ze, small payloads, restricted areas of operation, and limited flight times, Chaney Aerospace will keep an equivalent level of safety.

PUBLIC INTEREST

Wildland firefighting poses an inherent risk to those on the ground fighting to contain the fire. Wild fires also pose a risk to both public and private property. Both of these aspects make it imperative for those in charge of the firefighting operations to have the best data at their disposal. Small Unmanned Aerial Systems can be used to keep the general p ublic, public property, private property, government property and firefighters out of harm’s way. Therefore it is not only in the public’s interest, but also the government’s interest to approve exemptions for the flight of sUAS’s to assist in wildland fir efighting operations. Granting our request for exemption will allow Chaney Aerospace to advance public safety research and development in the areas of wildland fires and hazard incident management.

Using a sUAS, like the PROtect or Apprentice S 15e, instead of a manned aircraft will benefit the public by reducing air and noise pollution. In typical wildland firefighting operations, manned aircraft are used which commonly require the use of internal combustion engines as compared to the PROtect and Ap prentice S 15e which use battery power and electric motors. These manned aircraft burn leaded aviation fuel that further adds pollution into the Earth’s atmosphere. By using the PROtect and Apprentice S 15e, Chaney Aerospace is using environmentally consci ous alternatives to manned aircraft. Due to the PROtect’s and Apprentice S 15e’s size and propulsion package, it also serves as an alternative that reduces noise pollution when compared to manned aircraft.

Approving exemptions for operations of commercial sUAS reduces risk while enhancing safety. Unlike sUAS, manned aircraft pose a greater risk to the population due to their size, fuel source, and the fact that they carry human passengers and human pilots. By using sUAS’s in place of manned aircraft, risks due toChaney Aerospace, LLC Page 8 of 9 size, weight, and combustible fuel on board are reduced drastically. Also, the threat to life onboard the

aircraft is nonexistent.

EQUIVALENT LEVEL OF SAFETY

Chaney Aerospace believes that the grant from exemption from part s 21, 45.23, 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations will not affect safety because of the reasons stated below. Also, the limitations provide for an equivalent or higher level of safety to operations under the current regulatory structure. The proposed operations represent a safety enhancement to the protocols followed by manned aircraft.

During operations under an FAA issue d exemption, the following limitations will be in place and apply to operations for the PROtect and Apprentice S 15e:

1. Minimum crew for each operation will consist of a Pilot in Command and a Visual Observer.

2. The aircraft will be operated with both a PIC a nd a VO.

3. The pilot in command will be an FAA licensed airman with at least a private pilot’s certificate

and third class medical.

4. The pilot and visual observer will have been trained in the operation of the sUAS.

5. The pilot and visual observer will at all times be able to communicate by voice and/or text.

6. Flights will be operated within visual line of a pilot and/or observer.

7. All operations will occur below 400ft AGL.

8. Flight operations will be conducted 5 NM from an airport when applicable. Flight operation s within 5NM of an airport will require notification and approval from the local Flight Standards District Office and airport controller.

9. Operations will occur during daylight hours and under visual meteorological conditions only.

10. When necessary and applic able, the FAA will have notice of operations through the filing of

notices

- to

- airmen.

11. Written and/or oral permission from the relevant property holders will be obtained.

12. When necessary, applicable permits will be acquired from local authorities.

13. The aircra ft will not be operated over urban or populated areas.

14. The aircraft will not be operated over an open

- air assembly of people.

15. All flights will land with a 10% battery power reserve for the PROtect, and 15% for the Apprentice S 15e.

16. In the event of an unpre dicted situation, the sUAS will have the capability to return to a predetermined location and either land, hover, or circle.

Additionally, the PIC and VO will complete initial training in order to operate either of the aircraft for which the exemption is requested. We do not anticipate the need for a supplemental pilot due the simplicity of the systems. Finally, due to the size, weight, and operating conditions of both the PROtect and Apprentice S 15e, and the use of a fully qualified flight crew, Chaney Aerospace believes flight operations will have an equivalent or greater level of safety than manned aircraft performing the same

mission.

PRIVACY

All flights will be conducted over private property or controlled access property with the property

owner’s prior consent and knowledge. Any images taken of individuals will be taken of individuals who have consented to being photographed or filmed prior to filming or who have agreed to be in the area where imagery will be captured.Chaney Aerospace, LLC Page 9 of 9 FEDERAL REGISTER SUMMARY

Mr. Will A. Chaney, Owner, Chaney Aerospace, LLC, 3525 Santa Monica Dr., Abilene, TX 79605, petitioned the FAA on behalf of Chaney Aerospace, LLC for an exemption from part 21, 45.23, 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91. 151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations. Using an onboard

sensor (s) , the exemption would allow commercial operation of the PROtect small Unmanned Aircraft System , manufactured by Chaney Aerospace, and the Apprentice S 15e manufactured by E

- flite for aerial surveillance to aid in wildland firefighting and other commercial industries.