### SUMM**AR Y** 

Systems Engineering and Laboratories seeks exemption from the requirements of **14 C.F.R**  **§§ 61.23(a)**  **and (c),**  **61.101(e)(4) and**  **(5), 61.113(a),**  **61.315(c)(2) &**  **(3), 91.7(a),**  **91.119(a), 91.121,**  **91.151(b), 91.405(a),**  **91.407(a)(1), 91.409(a),**  **91.417(a) a** **nd (b)** , to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Systems Engineering and Laboratories to operate an UAS for the commercial purpose of conducting aerial video and photography of inspection sites over certain areas of the United States.


### INTRODUCTION OF THE PETITIONER
Systems Engineering and Laboratories provides its clients with information about how an incident happened, surveys of incident sites, and reconstruction of incidents. The objective of Systems Engineering and Laboratories is to provide the best and most effective data to it’s clients.


### BA**CKGROUND** Unmanned Aircraft Systems: 3DR Y6
Systems Engineering and Laboratories seeks an exemption to operate 3D Robotics systems for compensation orhirewithin the NAS. The 3DRY6 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet orsmart phone systems in tandem with its own dedicated remote system. The 3DR Y6 UAS is controlled by a Pixhawk autopilot system, which is programmed using Mission Planner software. The 3DR Y6 has a maximum gross weight of 2 pounds 13 ounces with a diagonal size of 21.6 inches and a maximum speed of approximately 48 knots. The 3DR Y6 is equipped with six main rotors driven by a 4000mAh LiPo 4S powered electric motors and a GoPro Hero 3 for image capture. The 3DR Y6 has been approved for use in other exemptions (

### Exemption No. 12646A)

The 3DR Y6 that will be operated by Systems Engineering and Laboratories will be registered in accordance with **49 U.S.C.**  **44103, as**  **we ll**  **as 14**  **C.F.R. Part**  **47, and**  **marked in**  **accordance with**  **14 C.F.R.**  **Part 45.** 



### BA**SIS FOR PETITION**
Petitioner, Systems Engineering and Laboratories, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and FAA Modernization and Reform Act of2012 (FMRA), Section 333, hereby petitions the Administrator to commercially operate the 3DR Y6 UAS in the National Airspace System (NAS), and for an exemption from the requirements of**14 C.F.R**  **§§ 61.23(a)**  **& (c),**  **61.101(e)(4) &**  **(5), 61.113(a),**  **61.315(a), 91.7(a),**  **91.119(a), 91.121,**  **91.151(a)(1), 91.405(a),**  **91.407(a)(1), 91.409(a),**  **and 91.417(a)**  **& (b).** 

In consideration of the speed, weight, size, and limited operation area associated with the unmanned aircraft and its operation, Systems Engineering and Laboratories’ operation of 3DR Y6 meets the conditions of **FAA Modernization**  **and Reform**  **Ac t**  **of 2012**  **(FMRA) Section**  **333** and therefore, will not require an airworthiness certificate in accordance with **14 C.F.R.**  **Part 21,**  **Subpart H.**  Accordingly, Systems Engineering and Laboratories requests relief from **§§ 91.405(a),**  **91.407(a)(1), 91.409(a)(1)**  **& (2),**  **and 91.417(a)**  **& (b)** , as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.Systems Engineering and Laboratories submits thatthe requested relief is propersince an equivalent level

ofsafety will be ensured. Systems Engineering and Laboratories will use experienced personnel
ortechnicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3DR Y6 Instruction Manual). Furthermore,Systems Engineering and Laboratories will document and maintain all maintenance records forthe 3DR Y6 UAS.

**Relief from**  **certain requirements**  **of §**  **61.23(a) &**  **(c) entitled**  

### Medical**certificates: Requirement and** **duration**, is requested by Systems Engineering and Laboratories to operate the 3DRY6 without an issued medical certificate. Systems Engineering and Laboratories will require all pilots to have an annual physical to ensure the pilot is fitto command.

**Relief from**  **§ 61.101(e)(4)**  **& (5),**  **61.113(a), and**  **61.315(c)(2) &**  **(3) entitled**  

### Recreational **pilot privileges**  **and limitations,**  **Private pilot**  **privileges and**  **limitations: Pilot**  **in command,**  **and** 

### What **are the**  **privileges and**  **limits of**  **my sport**  **pilot certificate?**  respectively, is requested bySystems Engineering and Laboratoriesto the extent necessary to allow
a PIC holding a recreational, private, or sport pilot certificate, as well as a state Driver’s license, and who has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the 3DR Y6 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structureswhere necessary.

**Relief from**  **§ 91.7(a),**  **entitled** 

### Civil **aircraft airworthiness** , because the 3DR Y6 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Systems Engineering and Laboratories submits the they will ensure that the 3DR Y6 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and3DR Y6 Professional Instruction Manual), and that the aircraft are in a condition forsafe flight.

**Relief from**  **§ 9** **1.119(c), entitled**  

### Minimum **safe altitudes:**  General
, because Systems Engineering and Laboratories intends to use the 3DR Y6 to collect aerial video and photographs of buildings and structures involved in an investigation. Outside of structures involved inan investigation, Systems Engineering and Laboratories will maintain safe distance from structures, people, vessels, and vehicles.**Relief from**  **§ 91.121,**  **entitled** 

### Altimeter **Settings**, as the 3DR Y6 UA will not have a typical

barometric altimeter onboard. However, altitude information of the 3DR Y6 UAwill be provided tothe PIC via GPS equipment and radio communications telemetry data link, which downlinks from the UA to the Ground Control System for active monitoring of the flight path. This altitude information, combined with Systems Engineering and Laboratories’ operation of the 3DR Y6 within visual line of sight atorbelow400 feetAGL, will ensure a level ofsafetyequivalent to § 91.121.

**Relief from**  **§ 91.151(b),**  **entitled** 

### Fuel**requirements for flight in VFR condition.**  Systems Engineering and Laboratories submits that safety will not be affected byoperation ofthe 3DR Y6 UAduring daylightvisual meteorological conditions (VMC) underVFR, with enough battery powertofly for a total duration of approximately 13 minutes to the first point of intended landing and,assuming normal cruising speed, to fly afterthatforat least 5 minutes
In accordance with 14 C.F.R. §11.81, Systems Engineering and Laboratories provides thefollowing information in support of its petition forexemption:



### A. **Name and address Of The Petitioner.**

The name and address ofthe Petitioner and point ofcontact is:
Systems Engineering and Laboratories Corporation Frank Johnson 12785 Hwy 64E Tyler TX, 75707 903

-566

-1980 

### fjohnson@sealcorp.com

**B. The Specific**  **§§ of 14 C.F.R. From Which Systems Engineering and Laboratories Seeks**  **Exemption.**

**1. Systems Engineering and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§ 61.23(a) & (c).** 
§ 61.23, entitled 

### Medicalcertificates: Requirementandduration, subsections (a)and (c) prescribe the following **(a)** 

### Operations**requiring a**  **medical certificate.**  **Except as**  **provided in**  **paragraphs (b)**  **and (c)**  **of this**  **section, a**  **person —**  (1) Must hold a first-class medical certificate: (i) When exercising the pilot-in-command privileges of an airline transport pilot certificate; (ii) When exercising the second-in-command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or (iii) When serving as a required pilot flightcrew member in an operation conducted under part 121 ofthis chapter ifthe pilot has reached his or her60th birthday.

(2) Must hold at least a second class medical certificate when exercising:(i) Second-in-command privileges of an airline transport pilotcertificate in part 121 ofthischapter (other than operations specified in paragraph (a)(1)(ii) ofthis section); or (ii) Privileges ofa commercial pilot certificate; or (3) Must hold at least a third-class medical certificate

— (i)When exercising the privileges ofa private pilot certificate; (ii)When exercising the privileges ofa recreational pilot certificate; (iii)When exercising the privileges ofa student pilot certificate; (iv) When exercising the privileges of a flight instructor certificate and acting as the pilot in command; (v) When exercising the privileges of a flight instructor certificate and serving as a required pilotflight crewmember; (vi) When taking apractical test in an aircraft for arecreational pilot, private pilot, commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or (vii) When performing the duties as an Examiner in an aircraft when administering a practical test or proficiency check foran airman certificate, rating, orauthorization.

**(c)** 

### Operations requiring either a medical certificate or U.S. driver's license

(1) A person must hold and possess either a medical certificate issued under part 67 ofthis chapter ora U.S. driver's license when

— (i) Exercising the privileges ofastudent pilotcertificate while seeking sport pilot privileges in
a light-sport aircraft other than a glider or balloon; (ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a glider or balloon; (iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while acting as pilot in command or serving as a required flight crewmember of a light-sport aircraft other than a glider orballoon; or (iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot certificate in a light-sport aircraft other than a glider or balloon. (2) A person using a U.S. driver's license to meet the requirements ofthis paragraph must

— (i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and any judicial or administrative order applying to the operation of a motor vehicle; (ii) Have been found eligible for the issuance of at least a third-class airman medical certificate at the time of his or her most recent application (ifthe person has applied for a medical certificate); (iii) Not have had his or her most recently issued medical certificate (if the person has held a medical certificate) suspended or revoked or most recent Authorization for a Special Issuance ofa Medical Certificate withdrawn; and (iv) Not know or have reason to know of any medical condition that would make that person unable to operate a light-sport aircraft in a safe manner.


### 2. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§61.101(e)(4) & (5).**
§ 61.101, entitled 

### Recreational pilot privileges and limitations, subsection (e)(4) states the following:(e) Except as provided in paragraphs (d) and (i) ofthis section, a recreational pilot may notactas pilot in command ofan aircraft

— (4) For compensation or hire; (5) In furtherance ofa business;


### 3. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§ (5),61.113(a).** 
§ 61.113, entitled 

### Private pilotprivileges andlimitations: Pilotin command, subsection (a) states the following: (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft.



### 4. **Systems Engineering and Laboratories Seeks**  **Exemption From**  **The Requirement**  **Of §61.315(c)(2) & (3** **).** §61.315, entitled 

### Whataretheprivilegesandlimitofmysportpilotcertificate?, subsection (c)(2) & (3) states the following: (c) You may not act as pilot in command ofa light-sport aircraft: (2) For compensation or hire. (3) In furtherance ofa business.



### 5. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.7(a).**
§ 91.7, entitled 

### Civil aircraft worthiness, subsection (a), states that: (a) No person may operate a civil aircraft unless it is in an airworthy condition.



### 6. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.119(c).**
§ 91.119, entitled 

### Minimum safe altitudes: General, subsection (c) states that: Except when necessary fortakeoff or landing, no person may operate an aircraft below the following altitudes: (c) 

### Overother than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, orstructure.



### 7. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.121.**
§ 91.121, entitled 

### Altimeter Settings, subsection (a)(1) states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles ofthe aircraft;(ii) Ifthere is nostation within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure.



### 8. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§ 91.151(b).** 
§ 91.151, entitled 

### Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft 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, to fly afterthatforat least 20 minutes.



### 9. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.405(a).** § 91.405, entitled 

### Maintenance required, subsection (a) states: Each owner oroperator ofan aircraft

— (a) Shall have that 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 ofthis chapter.



### 10. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.407(a)(1).**
§ 91.407, entitled 

### Operation aftermaintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(1), states the following: (a) No person mayoperate anyaircraft that has undergone maintenance, preventive maintenance, rebuilding, oralteration unless

— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter.



### 11. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.409(a).**
§ 91.409, entitled 

### Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by §43.7 ofthis chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.



### 12. **Systems Engineering**  **and Laboratories**  **Seeks Exemption**  **From The**  **Requirement Of**  **§91.417(a) & (b).**
§ 91.417, entitled 

### Maintenancerecords, subsections (a) & (b), state the following:(a) Except forwork performed in accordance with §§91.411 and 91.413, each registered owneror operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate numberofthe person approving the aircraftforreturn to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor.(ii) The current status of life limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program underwhich the aircraft and itsappliancesare maintained

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner oroperator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated orsuperseded by otherwork orfor 1 year afterthe work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft atthe time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



### C. **The Extent**  **Of Relief**  **Systems Engineering and Laboratories Seeks**  **An d**  **The Reason** 

**Systems Engineering and Laboratories Seeks The Relief.**

**1. Extent**  **Of Relief** **Systems Engineering and Laboratories Seeks** **An d** **The Reason**  **Systems Engineering and Laboratories Seeks Relief From § 61.23(a) & (c).** 

Relief from § 61.23(a), entitled 

### Medical certificates: Requirement and duration, is requested to the extent necessary to allow a PIC, with a current physical from a physician, but no medical certificate, to pilot the 3DR Y6

.
The limitations of § 61.23(a) sets forth the level of medical certificate one needs in order to pilot an aircraft. However, because the 3DR Y6 does not require a physical pilot inside the vessel andbecause the 3DR Y6 can be programmed to safely return, within the same limitations the PIC would be required tofollow, tothe GCSand land in the event ofloss ofrange or other emergencies a current physical will maintain a similar level of safety as the medical certificate would. Systems Engineering and Laboratories requests that a current physical and valid driver’s license meet the safety requirements ofthis section.



### 2. **Extent Of**  **Relief Systems Engineering and Laboratories** **Seeks An** **d The** **Reason Systems Engineering and Laboratories**  **Seeks Relief**  **From §**  **61.101(e)(4) &**  **(5), 61.113(a),**  **An d**  **61.315(a).**

Relieffrom §§ 61.101(e)(4) & (5), 61.113(a), and 61.315(a), entitled 

### Recreational pilot privileges and limitations, Privatepilotprivileges andlimitations: Pilotin command, and 

### Whatare theprivileges andlimits ofmysportpilotcertificate?, is requested tothe extent necessary toallowa PIC holding a recreational, private, orsport pilot certificate, as well as valid driver’s license and current physical, and who has metcertain flight hour and currency requirements, to conduct the proposed UAS flight operations forcompensation or hire.

This relief is requested since the limitations set forth state that private, recreation, or sport pilots may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property forcompensation or hire.

As set forth more fully below, Systems Engineering and Laboratories submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the 3DR Y6 UAS unless that PIC has met certain flight hour and currency requirements, demonstrating thatthe PIC is ableto safely operate either the 3DR Y6 in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles, andstructures that are not part ofan investigation

Further, Systems Engineering and Laboratories submits that all flights of the 3DR Y6 conducted by the PIC pursuant tothegrantofthis Petition: (1)will be incidental to ForensicAnalysis & Engineering’s business; and (2) will not carry passengers or property forcompensation or hire.



### 3. **Extent Of**  **Relief Systems Engineering and Laboratories** **Seeks An** **d The** **Reason System Engineering and Laboratories Seeks Relief From § 91.7(a).** 

Relief from § 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

### allow Forensic Analysis & Engineering to determine that the 3DRY6UASis 

### in airworthy condition prior to every flight by ensuringthattheUAS isincom pliance withthe

### operatingdocuments (i.e. Monthly Maintenance Log, and 3DR Y6 Instruction 

### Manual). Systems Engineering and Laboratories seeks the requested relief because the 3DR Y6 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H. Therefore, Systems Engineering and Laboratories will ensure that the 3DR Y6 UAS is in airworthy condition based upon compliance with the operation documents (i.e. Monthly Maintenance Log, and 3DR Y6 Instruction Manual) prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.

### 4. **Extent Of**  **Relief Systems Engineering and Laboratories** **Seeks An** **d The** **Reason System Engineering and**  **Laboratories Seeks Relief From § 91.119(c).**

Relief from § 91.119(c), entitled 

### Minimum safe altitudes: General, will be necessary in order to conduct various investigations. The 3DR Y6 would need to get close to vessels, vehicles, and structures involved in the investigation in order to capture clear photographs ofthe inspection site.
Specifically, the § limits getting within 500 feet of any person, vessel, vehicle, or structure. Systems Engineering and Laboratories requests relieffrom this limit against vessels, vehicles, and structures only when part of an active investigation with the property owner’s previous permission. Considering the hovering capabilities of the 3DR Y6, which is ± 0.1 m vertically (when Vision Positioning is activated) and ± 1.5 m horizontally, a saferthan 500 feet distance can be maintained Furthermore, Systems Engineering and Laboratories will incorporate a second remote system so that the visual observer or a third participant can operate the photography while the PIC can verify that 3DR Y6 is maintaining a safe distance from the structure, vehicle, or vessel.

5. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason Systems Engineering and Laboratories Seeks Relief From § 91.121.

Relief from §91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DR Y6 UAS, which utilize barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Systems Engineering and Laboratories seeks the requested relief because the 3DR Y6 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief is sought to the extent necessary to comply with the applicable conditions and limitations stated below, As more fully set forth herein, an equivalent level of safety will be maintained since the 3DR Y6 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides that PIC with altitude information of the UA on the heads up display of the GCS.

6. Extent Of Relief Systems Engineering and Laboratories SeeksAnd The Reason Systems Engineering and Laboratories Seeks Relief From § 91.151(b).Relief from section 91.151(b), entitled Fuel requirements for flight in VFR conditions, is requested to the

extent required to allow flights of the battery powered 3DR Y6 UA during daylight hours in visual meteorological conditions, under visual flight rules, for a total duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Systems Engineering and Laboratories seeks the requested relief because without an exemption from this rule will severely constrain the practicality of any aerial video or still photo flight operations that Systems Engineering and Laboratories proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR Y6 UAS the operation documents, and Systems Engineering and Laboratories’ proposed operating limitations, ensure that Systems Engineering and Laboratories will safely operate the battery powered 3DR Y6 UA during daylight hours in visual meteorological conditions, under visual flight rules, with enough battery power to fly for a total duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

7. Extent Of Relief Systems Engineering and Laboratories Seeks And The Reason Systems Engineering and Laboratories Seeks Relief From §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), And 91.417(a) & (b).

Since §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), And 91.417(a) & (b) only apply to aircraft with
an airworthiness certificate, Systems Engineering and Laboratories requests relief from these §§ because the 3DR Y6 UAS does not requir e an airworthiness certificate. As setforth morefully below, the 3DR Y6 UAS meets the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333 for operation without an airworthiness certificate. Accordingly, Systems Engineering and Laboratories will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e. Monthly Maintenance Log and 3DRY6 Instruction Manual). Furthermore, Systems Engineering and Laboratories will document and maintain all maintenance records for the 3DR Y6 UAS.



### D. **The Reason**  **Why Granting**  **Systems Engineering and Laboratories Request**  **Would Be**  **In The**  **Public Interest ; That**  **Is, How It Would Benefit The Public A s** **A Whole.**
Granting the present Petition will further the public interest by allowing Systems Engineering and Laboratories to safely, efficiently, and economically perform aerial video and photography of homes, vehicles,vessels, construction sites, and other incident sites over certain areas ofthe United States.
Additionally, use ofthe 3DR Y6 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

### Systems Engineering and Laboratories proposed operation ofthe 3DR Y6 UAS will be realized without implicating any privacy issues.



### 1. **The Public Will Benefit From Decreased Congestion Of The NA S.** 

The 3DR Y6 UA is battery powered and serve as a safe, efficient, and economicalalternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing theamount ofmannedaircraft needed to perform aerial acquisitions, an exemption allowing the useofa3DR Y6 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.
Additionally, when Systems Engineering and Laboratories must collect video and photographic evidence ofships and vessels off the coast, using the 3DR Y6 will result in a reduction ofcongestion in the waterways and ultimately a reduction in fuel costs.
Furthermore, by reducing the number of manned aircraft operations in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 3DR Y6 UA does not require
an airport to takeoff or land. Likewise, a reduction of manned aircraftconducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.



### 2. **The Public**  **Will Benefit**  **From The**  **Safety An** **d Efficiency**  **Of The**  **3DR Y6 UA S.** 
Conducting aerial image acquisitions with the 3DR Y6 UAS, instead ofmanned aircraft, willgreatly benefit the public by drastically reducing the levels of air and noise pollution generatedduring traditional aerial video and still photography flight operations. By using battery powered andelectric motors, the 3DR Y6 UAS produce no air pollution, and is the mostviable environmentallyconscious alternative to the cabin class, four or six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burningapproximately 10-15 gallons per hour of leaded aviation fuel. The 3DR Y6 UA,while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, asthe UA is propelled by battery powered electric motors, rather than
an internal combustion engine.

By using the 3DR Y6 UAS to perform aerial image acquisitions, the substantial riskto lifeand property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 3DRY6 UA (weightapproximately 2 pounds 13 ounces at its maximum gross weight with length a 23.3 inches diagonal, and with no fuel on board), has less physical potential for collateral damage to life and property onthe ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weight approximately 3000 pounds with
a wingspan of approximately 32 feet, a length of34feet,and a fuel capacity of80 gallons).



### 3. **Performing Ae** **rial Video**  **and Photography**  **Operations With**  **The 3DR Y6 UA** **S Will Benefit The Economy.** 

In addition to being safe and efficient, the 3DR Y6 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 3DR Y6 UAS will allow United States based companies, like 

### Systems Engineering and Laboratories, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental ProtectionAgency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery 3DR Y6 UAS is one such technology that not only allows companies greater operationalflexibility compared to manned aircraft, butprovides such flexibilitywithoutthe high operational costofa traditional manned aircraft.By operating the 3DR Y6 UAS companies, such as 

### Systems Engineering and Laboratories, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the 3DR Y6 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.



### 4. **There A re No Privacy Issues.** 

Similar to the manned aerial acquisition flight operations that have been conductedfor decades, Systems Engineering and Laboratories’ proposed operations ofthe 3DR Y6 UASwill not implicate any privacy issues. Specifically the 3DR Y6 UAS will be operated in compliance with operating documents (i.e. Monthly Maintenance Log, and 3DRY6 Instruction Manual) additionally requiring property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations)


### E. **The Reason**  **Why Granting**  **The Exemption**  **Would Not** **Ad versely** **Af fect**  **Safety, Or**  **How The**  **Exemption Would**  **Provide A**  **Level Of**  **Safety Equal**  **To That**  **Provided By**  **The Rule**  **From Which Systems Engineering and Laboratories Seeks Exemption.** 

**1. Reasons**  **Why the** **3DR Y6 UA** **Me et** **The Conditions** **Of The** **FA A M** **odernization and Reform A** **ct of 2012 (FMRA ) Section 333.** 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Systems Engineering and Laboratories’ operation of the 3DRY6 UAS meets the conditions of FAA Modernization and Reform Act of 2012 (FMRA) Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part21,Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security. Specifically, FAA Modernization and Reform Act of 2012 (FMRA) Section 333 states the following, in part: 

### (a) In General.--Notwithstanding anyotherrequirementofthissubtitle, andnotlaterthan 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine i

fcertain unmanned aircraft systems may operate safely in the national airspace system before completion oftheplan andrulemakingrequiredbysection 332 of this Act or the guidance required by section 334of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports andpopulatedareas,

### and operation within visual line ofsight do not create a hazardto users ofthe national airspace system or the public or pose a threat to national security ; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--Ifthe Secretarydetermines underthis section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraftsystems in the national airspacesystem.

In seeking this exemption, Systems Engineering and Laboratories submits that the 3DR Y6 UAS can operate safely in the NAS pursuant to FAA Modernization and Reform Act of 2012 (FMRA) Section 333, as demonstrated by: (a) the characteristics of the 3DR Y6 UA; (b) the pilot certification requirement; and (c) the specific operating limitations.



### a. **The Specifications** **Of The** **3DR Y6 UA** **S Demonstrate** **Its Safe**  **Characteristics**The 3DR Y6 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to the national security considering its size, weight, speed, and operational capability.



### i. **Technical Specifications Of The 3DR Y6 UA S.** 

The technical specifications ofthe 3DR Y6 UAS are set forth bythe 3DR Y6 Build Manual

-vA herein attached as Appendix A.The 3DR Y6 UAS is controlled by a Pixhawk autopilot system, which is programmed using Mission Planner software.



### ii. **The 3DR Y6**  **UA S**  **Autonomous Flight** **An d**  **Navigation Mode**  **Enable The UA S to Remain Within A** **Defined Operational A rea.** 

The 3DR Y6 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the 3DR Y6 UAS is provided in the Mission Planner user manual, found at http://planner.ardupilot.com/wiki/mission

-planner

-overview,and Pixhawk Manual Rev 7 herein attached as Appendix B



### iii. **The 3DR**  **Y6 UA** **S Is**  **Designed For**  **Au tomatic**  **Return To**  **Home Point**  **Or Hover In The Event Of Loss Of The Control Link Or Navigation.**

When the Control Link is lost, the 3DRY6 UASwill continue its programmed flight plan or Return to Land (RTL), depending on usersettings andflight mode.Atthe end ofthe mission oratthe end ofthe RTL process, the craft will descend to the takeoff position, shut down, and disarm the motors. Additional failsafe features include geofencing, battery alarms, and automated triggering of RTL or auto land in case of low GPS signals or loss of controller or ground station communication.A complete description of the Failsafe Functions of the 3DR Y6 are set forth at

http://planner.ardupilot.com/wiki/mission

-planner

-overview



### iv. **The 3DR Y6 GCS And Its Operation.**

A complete description ofthe operation and specifications ofthe 3DRY6 GCSandflight control software is provided athttp://planner.ardupilot.com/wiki/mission

-planner

-overview



### b. **Flight Operations**  **Of 3DR Y6**  **UA S**  **Is Limited**  **To The**  **Line Of Sight Of A**

**Certified Pilot in Command With A Safety**  **Observer(SO).**
Systems Engineering and Laboratories will be the only company to authorize PICs for the 3DR Y6. Additionally, a safety observer and photographer will assist the PIC during flight time.



### c. **Flights Of** **3DR Y6 UAS** **Will Be** **Conducted Pursuant** **To Specific Operating Limitations.** 

In seeking this exemption, Systems Engineering and Laboratories proposes to commercially operate 3DR Y6 UAS for the special purpose of conducting aerial video and photography
over certain areas of the United States, pursuant to the following specific operating limitations1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weight less than 55 pounds maximum gross weight: 3DR Y6 Unmanned Aircraft System. Proposed operations ofany other aircraft will require a new petition ora petition to amend this grant.
2. UAS operations under this exemption will be limited to conducting operationsfor the purpose ofaerial surveying,video, and photography. 3. The UA may not be flown at an indicated airspeed exceeding 50 knots. 4

. The UA must be operated at an altitude of no more than 400feetAGL, as indicated bythe procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported to ATC must be in feetAGL. 5

. The UA must be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s State issued Driver’s License 6

. The use ofthe first person view bythe PIC orSO is not permitted. 7. All operations must utilize an SO. The SO may be used to satisfy the VLOS requirement as long asthe P ICalways maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents

. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding otherairtraffic and otherground based obstacles/obstructions and is not permittedto operate the camera orother instruments

. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and theprocedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifitpetitions forextensionor amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in acondition forsafe flight. If the inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The GCS must be included in the preflight inspection. All maintenance and alterations must be properly document in the aircraft records. 11. Any UAs that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.ge replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperablecomponents, items, or equipment, not already covered in the relevant sections of theoperating documents.
13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacture Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess a private, sport, recreational, or higher pilot certificate, at leasta current Driver’s License, and a current physical from an approved practitioner. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures not involved in an investigation. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b) Flights for the purposes of training the operator’s PIC are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must beconducted underVMC. Ifflight atnight is required, aspecial requestwill be made at the FAA office closet to proposed area ofoperations. Flights under SVFR are not authorized. 20. The UA may not operate within 5 nautical miles ofan airport reference point asdenoted on current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter ofagreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feethorizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it must return toa pre-determined location within the planned operating area and land orbe recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning aflight unless (considering wind and forecastweather conditions) there is enough power to fly at normal cruising speed tothe intended pointand land the UAwith 25% battery power remaining. 25. The operator must obtain an ATO issued Certificate ofWaiverorAuthorization (COA) priorto conducting any operations under the grant of exemption. This COA will also require theoperator to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to operation. All operations shall be conducted in accordance with airspace requirements in theATO issued COA including class ofairspace, altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemption must be identified byserial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be made as large as practical 27. Before conducting operations, the radio frequency spectrum used foroperation and controlof the UA must complywith the FCC or otherappropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the GCS of the UAS any time the UAS in operating. These documents must be made available to the Administrator orany law enforcement official upon request. 29. The UA must remain clear and yield the right ofwaytoall manned aviation operations and activities atthe time. 30. The UAS may not be operated bythe PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operatortrainees oressential persons), vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If situation arises where nonparticipating persons leave such protection and arewithin 500feetofthe U, flight operations must cease immediately and/or;b. The aircraft is operated near vessels, vehicles, or structures wherethe owner/controller of such vessels, vehicles, or structures has granted permission and the PIC has made a safety assessment ofthe riskofoperating closertothose objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, So, operator trainees, or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32. All operations shall beconducted overprivate orcontrolled-access propertywith permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundariesof the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported tothe NTSB per instructions contained on the NTSB website: www.ntsb.gov

. 

### 2. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§ 61.23(a)**  **Would Not**  **Ad versely A** 

**ffect Safety.**
Systems Engineering and Laboratories submits that the equivalent level ofsafety established by § 61.23(a) will be maintained because no PIC will be allowed to operate the 3DR Y6 unless that PIC has a current physical on filewith Systems Engineering and Laboratories and avalid Driver’s License
The FAA has previously granted relieffrom § 61.23(a) & (c)specificto UAS, in circumstances similar, in all material respects to those presented herein (e.g. Exemption Nos. 11410, 11553, 11257, 11213, 11437, 11150A).



### 3. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§§ 61.101(e)(4)**  **& (5),**  **61.113(a), A nd 61.315(a) Would Not A** **dversely A ffect Safety.** 
Systems Engineering and Laboratories submits that the equivalent level of safety established by §§ 61.101(e)(4) & (5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to operate the 3DR Y6 unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 3DR Y6 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.
Considering Systems Engineering and Laboratories’ proposed area of operations, and the operating limitations set forth above; the parallel nature of private, recreational, or sport pilot aeronautical knowledge requirements to those of commercial pilot requirements; and the airmanshipskills necessary to safely operate the 3DR Y6 UAS, Systems Engineering and Laboratories submits that the additional manned airmanship skills unnecessary for Systems Engineering and Laboratories’ specific proposed flight operations.
Systems Engineering and Laboratories will notallowany PICtooperate the 3DR Y6 UAS unless that PIC has demonstrated, by meeting minimum flight hour requirements or the 3DR Y6 UAS training and currency requirements, that the PIC is able to safelyoperate the 3DR Y6 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people,vessels, vehicles, and structures.Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours
as a UAS pilot operating the same make and model of UAS to be used foroperations underthe exemption). In addition to the hour requirements, the PIC must accomplish 3takeoffs and landings in the preceding 90 days (forcurrency purposes).
Accordingly, Systems Engineering and Laboratories will ensure safe operations by notallowing any PIC tooperate the 3DR Y6 Professional UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the 3DR Y6 UAS in a manner consistent with the exemption, including evasive andemergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

The FAA has previously granted relieffrom § 61.113(a) & (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161.)


### 4. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§ 91.7(a)**  **Would Not**  **Ad versely A** 

**ffect Safety.**

The equivalent level of safety established by § 91.7(a) will be maintained because prior to every flight, Systems Engineering and Laboratories will ensure that the 3DR Y6 UAS is in anairworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.
Additionally, the FAA has previously granted relief from § 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 1116, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 5. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§ 91.119(c)**  **Would Not**  **Ad versely A** 

**ffect Safety.**

The equivalent level ofsafetyestablished by§91.119(c) will be maintained because 3DR Y6 will not be flown closer to any Vessel, Structure, orVehicle without priorauthorizationfrom the owner. Additionally, the 3DR Y6 has automated hover capabilities which allow the 3DR Y6 to maintain position within ± 0.2m vertically and ± 1.5m horizontally.

The FAA has previously granted relief from § 91.119(c) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11111, 11112, 11136, 11188, 11208, 11213, 11437, 11508, 11671)



### 6. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§ 91.121**  **Would Not**  **Ad versely A** 

**ffect Safety.**The equivalent level of safety established by § 91.121 will be maintained because the altitude information of the 3DR Y6 UA will be provided to the PIC via GPS equipmentand a radio communications telemetry data link, which downlinks from the UAtothe GCS foractive monitoring of the flight path and altitude. This altitude information, combined with 

### Systems Engineering and Laboratories’ operation of the 3DR Y6 UA within visual line ofsight, at orbelow 400 feetAGL, will
ensure a level ofsafetyequivalent to§91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiation point is automatically established bythe UAS at ground level.

The FAA has previously granted relief from § 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 7. **Reasons Why**  **An Exemption**  **From The**  **Requirements Of**  **§ 91.151(b)**  **Would Not**  **Ad versely**  **Af**

**fect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by § 91.151(b) as a result (1) the technical specifications of the 3DR Y6 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Systems Engineering and Laboratories will ensure that it will safely operate the battery powered 3DR Y6 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, tofly afterthatforat least 5 minutes

..

The technical specifications of the 3DR Y6 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level ofsafety established by § 91.151(b). Furthermore, safety will be ensured as the 3DR Y6 UAS provide audible and visual warnings tothe PIC atthe GCS when the UA experiences low battery voltage, the firstwarning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery power, the 3DR Y6 UAS will descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning § 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in § 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from § 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 1158, 11159, 11160, 11161).



### 8. **Reasons Why** **An Exemption**  **From The**  **Requirements Of** **§§ 91.405(a),** **91.407(a )(1),**  **91.409(a), A nd 91.417(a) & (b) Would Not A** **dversely A ffect Safety.** 

In seeking this exemption, Systems Engineering and Laboratories submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by §§ 91.405(a),91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) will be met because Systems Engineering and Laboratories will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents(i.e. Monthly Maintenance Log and 3DRY6 Instruction Manual). Furthermore, Systems Engineering and Laboratories will document and maintain all maintenance records for the 3DR Y6 UAS.

Since the 3DR Y6 UAS will be inspected as prescribed bytheoperating documents,

### Systems Engineering and Laboratories will maintain the equivalent level of safety established by §§91.405(a), 91.409(a)(1) &(2). Acopy ofthe 3DR Y6 User Manual isattached hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because 

### Systems Engineering and Laboratories will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed bytheoperating documents

. Furthermore, the exemption sought would maintain an equivalent level of safety established by §§91.407(a) and 91.407(b), because maintenance of the 3DR Y6 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the Monthly Maintenance Log.

Significantly, previous exemptions granted by the FAA concerning §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered.

In consideration of Systems Engineering and Laboratories’ proposed operating limitations, the operating documents, and the technical aspects of the 3DR Y6 UAS, Systems Engineering and Laboratories submits that safety will not be adversely affected by granting exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 1106, 11067, 11080, 11109, 11110, 11112, 1113, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 9. **The FAA**

**May Prescribe A** **ny Other Conditions For Safe Operation.** 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled 

### Special Conditions, Systems Engineering and Laboratories requests that the FAA prescribe special conditions for the intended operation of the 3DR Y6 UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a), & (c), 61.101(e)(4) & (5), 61.113(a) & (b), 61.315(c)(2) & (3), 91.7 (a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial video and photography over certain areas ofthe United States for compensation or hire. FAA Modernization and Reform Actof 2012 (FMRA) Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established forthe safe operation ofthe UAS in the NAS.Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.16, for operation of the 3DRY6 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do notcontain adequate orappropriate safetystandards, duetothe novel orunusual designfeatures ofthe aircraft. § 21.16, entitled 

### Special Conditions, stated the following:



### If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofnovelorunusualdesign feature ofthe aircraft, aircraftengine, orpropeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapterandcontain such safety standards for the aircraft, aircraft engine, or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.
Therefore, in accordance with FAA Modernization and Reform Actof2012 (FMRA) Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Systems Engineering and Laboratories intended operation ofthe 3DR Y6 UAS, which contains such safety standardsthat the Administrator finds necessary toestablish a level ofsafetyequivalent tothatestablished by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b).



### F. **A Summary**  **That Can**  **Be Published**  **In The**  **Federal Register,**  **stating: The**  **Rules From**  **Which Systems Engineering and Laboratories Seeks Exemption.**
Systems Engineering and Laboratories seeks exemption from the requirements of14C.F.R. §§61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b).


### G. **A Brief**  **Description Of**  **The Nature**  **Of The**  **Exemption Systems Engineering and**  **Laboratories Seeks.** 

This exemption will permit Systems Engineering and Laboratories to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography
over certainareas ofthe United States forforensic inspections.



### H. **An y** **Ad ditional**  **Information, Views,**  **Or Arguments**  **Av ailable**  **To Support** **Systems Engineering** **and Laboratories Request.**

This petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NS. As such, Systems Engineering and Laboratories’ request forexemption may be granted pursuant tothe authority ofFAA Modernization and Reform Actof2012 (FMRA) Section 333 and 14 C.F.R. Part 11, as setforth above.

The FAA Modernization and Reform Act of 2012 (FMRA) Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, orotherwise pose athreat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Systems Engineering and Laboratories will operate the 3DR Y6 UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, orotherwise pose a threat to national security.



### CONCLUSION

As set forth herein, Systems Engineering and Laboratories seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3DR Y6 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012 (FMRA), while also advancing the interests of the public, by allowing Systems Engineering and Laboratories to safely, efficiently, and economically operate the 3DR Y6 UAS commercially within the NAS



### WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Systems Engineering and Laboratories respectfully requests that theAdministrator grant this Petition for an exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c) , 61.101(e)(4) & (5), 61.113(a), 61.315(c)(2) & (3), 91.7(a), 91.119(c), 91.121, 91.151(b),91.405(a), 91.407(a)(1), 91.409(a), 91.417(a) & (b), and permit Systems Engineering and Laboratories to operate the 3DR Y6 UAS commercially for the purpose of conducting aerial video and photography over certain areas ofthe United States forforensic inspections

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Dated December 9, 2015

Respectfully submitted,
Frank Johnson Systems Engineering and Laboratories 12785 State Hwy 64 E Tyler TX, 75707 903

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