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



## Petition for Exemption, requesting relief from the **FAA Modernization and Reform Act of 2012,**

**Public Law 112**

**- 95 FEB. 14, 2012, Section 333.** 

Wherea s, Great River Information Technologies LLC seeks relief from airworthiness certification requirements from the above mentioned regulations.

Great River Information Technologies is a multimedia solutions provider with the express purpose of providing aer i al videography

for r ealtors, crop inspection for farmers, and surveys for construction companies. We are requesting to use a UAS for aerial

data collection

.

Great River Information Technologies is represented by Robert Malli, Software Engineer

, U.S. Arm y Veteran, DC Area Drone User Group member and current Academy of Model Aeronautics member. Mr. Malli has over 20 years of software development experience and four years of UAS flying experience.

I. Contact Information

Robert	Malli 12602	Misty	Creek	Lane

Fa irfax,	VA	22033

703

- 538

- 6796 Robert@greatriverit.comII. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Great River Information TechnologiesRequests Exemption are:

14	CFR	2 1; 14	C.F.R.	45.23(b);

1 4	CFR	61.113	(a)	&	(b); 14	C.F.R.	91,	et	seq.; 14	CFR	407	(a)	(1); 14	CFR	409	(a)	(2);	and, 14	CFR	417	(a)	&	(b)

Great River Information Technologies seeks this exemption under the guidelines of Section333 specifically as it relates to the Agriculture Industry in the greater Midwest area under the small

UAS rule. The main operating focus will be in the state of Iowa. A small portion of business will be offered in the real e state industry

in Virginia area while most of the busi ness focus will be concentrated in the Midwest. We believe that we have put together a program as responsible operators of an UAS that will stand as an exemplary model on whom many others entering the market will

emulate.

Under the terms of this exemption , it is our intention to safely fly an UAS, specifically a DJI Phantom 3 and DJI S900. Both UAS weigh less than 15 pounds. Additionally the se drone vehicles

maintain a FPV connectivity utilizing a Lightbridge connection to an iPad Mini 3 HD field monitor, allowing the pilot to see exactly what the Drone camera sees. Additionally, our pilot apps logs all flight data and ensures the UAS is in a “safe to fly” zone to record

a safe and reasonable flight.

As air safety is of paramount importance, Great River I nformation Technologies has developed a highly structured safety flightmanual for our pilot as well as observer. As recent as the new proposed FAA regulation released as of February of 2015, Great

River Information Technologies intends to operate well wit hin the most stringent proposal required to operate an unmanned aircraft in the National Airspace System (NAS). We are prepared to attend any required course of study, participate in flight evaluation and pay any required fee(s) that may be instituted. We have many hundreds of combined hours of safe flying in the recreational

mode.

III. Public Interest

We firmly believe that granting this exemption will allow for expanded precision agriculture application development, such as crop health monitoring, irrig ation monitoring, fertilizer management, and herd management. In regards to the real estate industry, many properties are "hidden" behind walls and landscaping, resulting in diminished "curb appeal". Providing this relief would eliminate these problems a nd lead to increased commerce for both buyers, sellers, government taxation agencies, real estate affiliated compa nies, (title, escrow, notary), construction industry and home improvement businesses who rely on a thriving

real estate market.

Additional ly UAV's provide for property inspections including roof and chimney that can assist in identifying hard to observe defects in manufacturing and installation.

Currently, precision agriculture and real estate aerial videography/photography relies primar ily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting Great River Information Technologies’ , request for exemption will reduce current risk levels and thereby enhance safety.Lastly, aerial videograp hy provides the viewer with safe access to the property vicinity via a virtual view eliminating needless driving to determine how close a property is to a freeway, school, beach or nearby unsightly development. This in turn reduces

exhaust emissions and a ir pollution since our UAV's utilize battery power and have no negative impact on the environment.

IV. Reasons Why Great River Information Technologies' Exemption Will Not Adversely Affect Safety

Great River Information Technologie s ’ , exempt ion will not adversely affect safety. Quite to the contrary, for the reasons stated permitting us, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow us to contribute to the innovation and imp lementation of new and novel, as of yet undiscovered safety protocols and applications for development in cooperation with the FAA. In addition I, Robert Malli, submit Great River Information Technologies’ Policy & Procdures Manual. (Ap pendix A)

V. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates,

Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procureme nt of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of our, Great River Information Technologies', UAS permits exemption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety pursuant to Section333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and

Section 3 33 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas

such as air ports and dense populations. Great River Information Technologies', current and projected UAS's meet

or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft

without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Re gulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 87 38, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintainingany such required certifications and registrations by Great River Information Technologies.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Our UAS are, by definition, unmanned. They therefore do not hav e a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on

such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the larg est possibl e lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regu lation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations:

PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are

limited to non

- commercial operations. Great River

Informati on Technologies can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting

skills. The risks attended to the operation of our UAS is far

less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing Great River Information Technologies to operate our UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower

altitudes in certain conditions. Our UAS will nev er operate at an altitude greater than 200 AGL; safely below the standard

of 400 AGL. Great River Information Technologies will however operate our UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or

below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “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 discrepancies repaired as prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Great River Information Technologies’, UAS. However, as a safety pr ecaution we inspect our UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled

Airworthiness Certificat es, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of ourUAS permits exemption from Part 21 because Great River Information Technologies’ UA S meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both piec es of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Our UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an

airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

VI. In summary, Great River Information Technologies seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § § 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) t o commercially operate Great River InformationTechnologies’ small unmanned vehicle/lightweight unmanned aircraft vehicle in precision agriculture and real estate operations, and to develop applications in regards to these industries in the

Midwest and Vir ginia. Currently, precision agriculture and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting Great River Information Technologies’ request f or exemption will reduce current risk levels and thereby enhance safety.

Great River Information Technologies is dedicated and committed to promoting the safe use of UAV's in the United States. We look

forward to working with the FAA and promoting this ne w industry.

Along with this Petition we are respectfully submitting the following support documents.

Exhibit A: Presents our proposed safety guidelines , pre

- flight checklist, and their implementation incorporated into our GREAT

RIVER I NFORMATION T ECHNOLO GIES POLICY &

PROCEDURES manual.

Ex hibit B: Presents GREAT RIVER INFORMATION

TECHNOLOGIES PERMISSION/WAIVER document.