April 2 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Aerial Robotics LLP 3115 US Hwy 421 N Frankfort, KY 40601 Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Aerial Robotics seeks an exemption from the Federal Aviation Regulations (“FARs”) liste d below to allow operation of unmanned aircraft system s ( UAS ) for commercial use.

. Aerial Robotics anticipates that the majority of the work can be accomplished within the “blanket” sub 200 foot COA recently granted to Section 333 civil exemption holders

. Aerial Robotics will apply for a new or amended COA for all flights not allowed under the blanket COA. Aerial Robotics intends to utilize the proposed unmanned aircraft systems in the following applications : Real Estate and Marketing Building , Construction Progress and Structure I nspection Aerial Mapping Environmental and Precision Agriculture Flight Training Research and Development Utilizing a UAS provides a higher level of safety for the pilot and people and property on the ground. Unmanned aircraft weighing a few pounds can accomplish many of the same tasks as a full size aircraf t that weighs thousands of pounds and carries combustible fuel

. A UAS reduces emissions and congestion in the National Air Space (NAS). Utilizing a UAS benefits the p ublic by providing a more efficient, safe and environmentally responsible tool for acquiring the customer’s imagery as compared to flying a manned aircraft. Grant of exemption would further benefit the public by allowing experienced UAS operators to provide services and training in a new UAS industry which is in desperate need of experienced people

.Due to the small size, light weight, slow flying speed and unmanned aspect of the

proposed UAS Aerial Robotics requests relief from the following sections in 14 C.F.R 14 C.F.R. Part 21, subpart H 14 C.F.R. Part 27 14 C.F.R 45.23 (b) 14 C.F.R. §§ 61.113 (a) & (b) 14 C.F.R. §§ 61.1 33 (a) 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. 91.417 (a) & (b) 

### 14 CFR **Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1)** The characteristics of the proposed UAS operating in a controlled environment provide a greater degree of safety to the public, operators and property owners than conventional operation s conducted with airworthiness certificates issued under this section.
Aerial Robotics will utilize checklists for preflight inspections as well as procedures for routine maintenance to ensure that the UAS is in an airworthy condition prior to each flight

. **14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft** Relief this section is requested for the same reasons as in the exemption request from 14 CFR Part 21, Subpart H **14 C.F.R. 45.23(b): Marking of the Aircraft** A small UAS cannot meet the marking requirements for a full size aircraft. Aerial Robotics will provide markings on the aircraft with the contact information and registered identification “N

- number” . Markings will be as large as practical and visible to the pilot, observer an d others working with the UAS.

### 14 CFR 61.113 (a) & (b)**; 61.133(a) : Private pilot privileges and limitations: Pilot** 

**in command ; Commercial pilot privileges and limitations**  Relief from these s ections is requested to allow an operator with a sp ort pilot certificate or higher to conduct commercial UAS operations. The skill set required to operate a UAS is significantly different from that of a manned aircraft. Aerial Robotics proposes that a higher level of safety and airmanship skills can be obtained w ith the requirement that the PIC successfully complete UAS flight training as detailed in the operator’s manual in addition to possession of a current sport pilot certificate or higher and valid US drivers license. **14 C.F.R. 91.7 (a): Civil aircraft airw orthiness**  An equivalent level of safety will be provided using the proposed procedures, manuals and checklists . Without an airworthiness certificate for the aircraft, relief from this section is also requested. **14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard**  **requirements** Aerial Robotics proposes that the operator’s manual for the UAS be kept at the control point where the pilot flying the UAS will have immediate access to it. **14 C.F.R. 91.103: Preflight Action** Aerial Robotics prop oses that the preflight procedures documented in the operator’s manual substitute for the preflight actions in this section. **14 C.F.R. 91.109: Flight Instruction** A higher level of safety than conventional full scale flight instr uction can be achieved with the proposed UAS operating in a closed flight training area. No pilot or passengers will be carried in the aircraft. Dual flight controls would not provide additional safety for the operators.
**14 C.F. R. 91.119: Minimum Safe Altitudes** Due to the nature of the proposed work, Aerial Robotics’ UAS operations will require the aircraft to be positioned less than 5 00 feet away from the operators and structures, and operated at altitudes less than 500 feet AGL

. The light weight and slow speed of the UAS negate the safety concerns associated with operations of full scale aircraft, when the UAS operations are performed in accordance with the proposed operating procedures.

### 14 C.F.R. 91.121: Altimeter Settings

The proposed UAS employs altitude control utilizing b arometric and GPS sensors. Altitude is automatically referenced to the current ground level when the flight controller is powered up. This can provide a method of altitude calibration equivalent to conventional aircraft altimeter s etting procedures

. The proposed UAS will operate under the “blanket” 200

-foot COA and when necessary will obtain a separate COA specific to the airspace required for that operation. The separate COA specific flights will be flown at an altitude less than 400 feet AGL

. The comb ination of operating procedures, visual cues, automatic altimeter calibration, telemetry, altitude and range geofencing and hear

- see - avoid capability will ensure separation between the UAS and manned aircraft. **14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions**  The proposed UAS have flight time s of less than 30 minutes and therefore cannot meet the 30 minute reserve requirement of this section. An equivalent level of safety can be achieved by operating the UAS in accordance with the operator’s manual . Voltage monitoring via telemetry as well as transmitter alarms will help ensure that adequate power will always be available for a controlled landing. Automatic battery failsafe settings provide an additional level of safety to help ensure that the UAS has adequate power to safely land

. **14 CFR 91.203 (a) & (b)**  **Civil aircraft: Certifications required**  Documents will be kept at the ground flight control point where the PIC and others can have immediate access to them. **14 CFR 91.405 (a); 40 7 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections**  An equivalent level of safety will be achieved by performing the maintenance inspections in the operator’s manual

. Because the UAS will not have an airworthiness certificate, relief from this se ction is requested.Summary of operating procedures

It is the view of Aerial Robotics that operating an unmanned aircraft system (UAS) in accordance with the restrictions and procedures below and in accordance with the instructions and recommendations in the operator’s manual s will provide a public benefit and not pose a risk to the NAS or people and property on the ground. The proposed UAS are small , lightweight, slow flying , aircraft conforming to the specifications in the attached operator’s manual s

. All proposed aircraft weigh less than 1 5 lbs. All flights will be flown from and over property with prior written authorization from the property owners. Flight areas include construction zones not open to the public , areas surrounding structures closed to traffic , and roads closed to public traffic. Construction areas may be occupied by Aerial Robotics personnel, construction workers , and owners

. All personnel on the ground will be briefed prior to any UAS flight. Ground personnel will be advis ed as to the hazards and be advised to remain “heads up” when the UAS is operating

. The UAS will be operated by a Pilot in Command (PIC) maintaining visual line

-of

-sight (VLOS) and under visual flight rules (VFR) conditions. The PIC will possess a FAA issued sport pilot certificate or higher. The PIC will be responsible for the safe operation of the flight including autonomous modes. The PIC will use human vision unaided by any device other than corrective lenses, as specified on the PIC’s airman medical certificate or U.S. driver’s license. A visual Observer (VO) will be located next to the PIC to serve as a safety spotter for other aircraft and to assist with verbal relay of telemetry data. The VO will communicate solely by voice with the PIC

. Only one VO will communicate with the PIC for the duration of the flight. Electronic messaging or texting will not be used during the flight. The UAS will take off and land from an area directly next to the PIC and VO. The PIC and VO will not operate t he UAS from a moving land or air based vehicle. UAS operat ions will be limited to ranges that permit the PIC to comprehend aircraft orientation and direction at all times. The proposed UAS will operate under the “blanket” 200

-foot COA at flight speeds le ss than 100 mph . If applications require altitudes greater than 200 feet, Aerial Robotics will obtain a separate COA specific to the airspace required for that operation. The separate COA specific flights will be flown at an altitude less than 400 feet AGL and at flight speeds less than 100 mph. All flights will be conducted in compliance with the airspace restrictions specified in the “blanket” 200

-foot COA . If operation in other airspace is desired, Aerial Robotics willobtain all required authorizations from the FAA and controlling agencies prior to

conducting those operations. All flights will be conducted during daylight hours under VFR conditions

. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles

. The PIC will immediately yield the right of way to all manned aircraft. The agility and vertical descent capabilit ies of the UAS combined with the ability of the PIC and VO to both hear and see full size aircraft approaching from all directions facilitates “hear, see and avoid ” operation s that are far more effective than can be achieved in a full size aircraft cockpit. Flights will be performed using the procedures and recommendations in the attached operator’s manual s

. The UAS mission will be terminated to allow for at least 5 minutes of battery power for return to the launch area and landing procedures. Aerial Robotics will n ot use the UAS for closed

-set motion picture or television filming. Staff resources Wi lliam A Dickerson is the proposed PIC. Experience includes 31 years of building and recreationally flying fixed wing, rotary wing, seaplan e and multirotor model aircraft , 22 years experience with recreationally flying full scale land based single engine aircraft with possession of a private pilot certificate and current third class medical certificate. Glenn W Anderson is the proposed VO and i s a registered professional electrical engineer wi th 39 years experience building and flying fixed wing, rotary wing, seaplane , ducted fan and multirotor RC aircraft

. He has 15 years building and flying RC aircraft using some of the first RC autopiloting systems and has 5 years experience in configuration and use of the proposed 3D Robotics flight control systems

. Mr. Dickerson and Mr. Anderson were the owners of New Perspective Aerial Photography. New Perspective Aerial Photography operated from 1994 until 2009. This company provided ae rial imagery to a variety of clients including Oak Ridge National Labs and the University of Kentucky. A history of New Perspective Aerial Photography is available at www.aerialrobotics.com. In summary Aerial Robotics has procedures, staff and resources to safely assemble, operate and maintain the proposed unmanned aircraft systems. Aerial Robotics is committed to a safe and responsible utilization of this technology

.If additional information is needed or if there are an y questions regarding this petition for

exemption please contact the applicant at: The name and address of the applicant are: Aerial Robotics, LLP 3115 US HWY

421 N Frankfort, KY 406 01 ATTN: W illiam A Dickerson

Cell: 502

-418

-0969 Email: bill@aerialrobotics.com www.aerialrobotics.com