SANDOVAL AND

· "-
.**~IA.l"ES** ,

The Honorable Anthony R. Foxx Office of the Secretary US Department of Transportation 1200 New Jersey Ave., SE Washington, DC 20590 May 12, 2015 The Honorable Michael P. Huerta Office of the Administrator Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591 Eric Sandoval S&A CEO
Sandoval and Associates 3180 lmjin Rd, Suite 104 Marina, CA 93933 Tel (831) 818-9981

RE: Sandoval sUAS Petition for Exemption Pursuant to FMRA Sec 333 and 14 CFR Partll Gentlemen: Sandoval & Associates ('Sandoval') hereby petitions the FAA for regulatory relief pursuant to Section 333 of P.L. 112-95 and 14 C.F.R. Sec. 11.81 to conduct commercial flights using the DJI F450 sUAS for the following applications:

• Providing GIS and biological monitoring services through aerial data collection. • :tvlaintenance, management and mapping services with aerial mapping. Sandoval, therefore, seeks a request for exemption from airworthiness and the following specific Title 14 C.F.R. provisions:

• 14 C.F.R. Part 21 • 14 C.F.R. 45.23 • 14 C.F.R. 61.113(a) & (b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(a) • 14 C.F.R. 91.9 • 14 C.F.R. 91.109(a) • 14 C.F.R. 91.119

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• 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203 • 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b) The FAA has issued grants of exemption in circumstances similar in a ll material respects to those presented in this petition, specifically Exemptions No. 11157, 11114 , 11172 ; and we therefore request that our petition be granted without delay
. Sandova l has also provided supporting documentation to include, General Operations Manual ('San

doval Manual') which is composed of (I) an operations manual, (2) flight manuals for each of the Sandova l models; (3) an Oper ator Training Manual, and (4) a Maintenance and Inspection Manua l. Please note that the Sandova l Manual (including all of the above listed components) are clearly marked "Confidential" on each page and contain confidential commercial and proprietary informa

tion that Sandoval has not and will not share with others who are not subject to a "Nondisclosure Agreement" (NDA). Therefore, t he Sandoval Manual (including all components) are not available to the public and contain operating conditions, procedures and other inf ormation t hat are protected from public release or disclosure under the Freedom of Inf ormation Act 5 USC Sec
. 552 et seq . 

### 1 Company Description Sandoval, based out of California , is a team of experienced Geologists, Planners , Biologists and GIS Specialists that provide innovative and practical solutions for environmental and planning needs. Sandoval has worked on numerous projects over the past 15 years, providing Federal , State , and Local agencies the ab ility to analyze complex problems, streamline the permitting process and maximize the return of the i r Environmental & Geospatial information. This section responds to the specific requirements of 14 CFR Sec 11.81. Mailing address and other contact information such as a fax number, telephone number, or email address copy. Sandoval & Associates ATTN : Eric Sandoval 3180 Imjin Rd , Suite 104 Marina, CA 93933 Ema il: eric@saspatia l. com 

### 2 Relevant Statuatory Authority This exemption application is express l y s ubmitted to fulfill Congress' goal in passing Section 333(a) tllTough (c) of the Reform Act
. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) be

fore completion of the rulemaking required under Section 332 of the Reform Act. In making this

Doc ID: 98212bf20a069ID9c5594 c2f802ae3e4502636bf3 determination , the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS's size, weight, speed , and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles «may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. §333(c). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. 

### 3 Qualification for Approval Under Section 333 of the Reform Act The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. The requested exemption would permit Sandoval to perform commercial operations under controlled conditions in airspace that is 1) limited 2) predetermined 3) restricted, limited, or controlled as to access and 4) would provide safety enhancements to the already safe operations in these industries presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to « ... establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) of the Reform Act. Sandoval sUAS includes the DJI F450, weighing 55 lb. or less, including payload. This sUAS operates under normal conditions at a speed of no more than 87 knots and has the capability to operate in either 'Automatic' or 'Manual' mode as described in the Sandoval Manual. Generally, Sandoval sUAS operations will be below an altitude of 400ft. AGL, within specific access-restricted areas, either within Class G airspace or "vith the permission of the ATC, using sUAS operated by Sandoval

- qualified sUAS pilots, and within the visual line of sight of the operator a.nd observer. Such operations will insure that the sUAS will "not create a hazard to users of the National Airspace System or the public" as per the FMRA 2012 Section 333. Given the size of the sUAS and the operating environment, this petition for exemption meets an equivalent level of safety, in which Congress envisioned that the FAA must, by exemption allow commercial operations of UASs to commence immediately. Also due to the size and environment , approval of the application presents no national security issue. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operaDoc ID : 98212bf20a069ID9c5594c2f802ae3e4502636bf4 tions, and the significant public benefit described herein, the grant of the requested exemptions is also in the public interest. 

### 4 Description of Proposed Operations Sandoval operations will provide a level of safety that is equivalent to current aviation standards. Sandoval's safety procedures, risk assessments, and flight operations standards are described in detail in the accompanying Sandoval Manual. In brief, the following procedures that apply during operations conducted under this exemption request, establish an equivalent level of safety (ELOS) as follows: 1. The sUAS will weigh less than 55 lb. 2. Flights will be operated within line of sight of a pilot and/ or observer. 3. Flights will occur during daylight hours
. 4. Flights will occm during Visual Flight Rules Meteorological Conditions (VMC). 5. Flights will generally be operated at an altitude of no more than 400 feet AGL and within Class G airspace. Operations in controlled B , C, or D airspace will be conducted in coordination with the proper FSDO and ATC with prior permission. 6. Flights will be terminated at 25% battery power reserve should that occur during the operation. 7. All Sandoval sUAS will be U.S. registered and display marks either in accordance with 14 C.F.R. Part 45, Subpart Cor approved alternative markings. 8. Operations will be conducted in defined regions and over property authorized for this use by the landowner. All operations will remain within the geographic boundaries of the operating area. Most operat ions may be conducted within the limitations of the b lank et COA authorization provided with 333 grants as of 3

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- 2015. 9. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions , including local law enforcement , fire, or other appropriate governmental agencies
. 10. The operator will obtain the consent of all persons involved and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. 11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 12. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer , and/ or the Camera Operator. 13. sUAS operations under this exemption will be conducted under the supervision of a designated pilot in command (PIC) who has final responsibility for the operation and in accordance with 14 C.F.R. 91.3. All sUAS operators must have completed training on the normal, abnormal , and emergency procedures in the Sandoval Manual and demonstrated proficiency with the sUAS being operated. The PIC must have passed at least a sport pilot certificate and hold a valid U.S. driver's license unless changed by future sUAS FAA Regulations
..

Doc ID: 98212bf20a069ID9c5594c2f802ae3e4502636bf5 14. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot , who possess the necessary PIC quali fications, is also present (i.e. the Visual Observer), that person can also be designated as the PIC
. 15. Observer and pilot will at all times be ab le to maintain verbal communication , either directly or through electronic means . 16. Operators and engineers will maintain the sUAS system in a condition for safe operation according to the Sandoval Manual and assoc iated manufacturer 's maintenance manuals, including pre-flight and post-flight inspections
. 1 7. The PIC and observers will maintain situational awareness and perceive, process, and per f orm risk management prior to and during ead1 operation as described in the Sandoval Manual. The PIC will terminate the operation in accordance with the Sandoval Manual if hazards that cannot be acceptab ly mitigated are observed. 18. sUAS will safely stop operating and either return home or auto-land at a safet location along the flight path if the control link is lost. 19. For each sUAS, the PIC will have the ability to force a controlled landing at any time. In addition to the above , Sandoval has implemented a Safety Management System. T he Sandoval Safety Manager is responsible for conducting safety audits, investigations , and inspections and is authorized to stop or prohibit any activity or operations which is considered unsafe. Full details are available in the Sandoval Manual. 

### 5 R e gulations From Which Exemption i s R e que st e d 5. 1 Pa r t 6 1 , Cert ific a ti on: Pilots, F lig ht Ins truct o rs, and Ground In struc t o rs Extent of Relief Part 61 , aU sections. 

### R eas on fo r R e lief Because the UAS will not carry a pilot or passengers, the proposed operat ions can achieve the equivalent level of safety of current operations by requ iring the P IC operating the aircraft to have at least a sport pilot's license rather than a commercial pilot's license to operate these sUAS. 

### Equi val ent Level of S a fe ty Unlike a conventiona l aircraft that carr ies the p ilot and passengers , the sUAS is remotel y controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the GOM
. The level of safety provided by the requirements included in the GOM exceeds that provided by a single individual holding a commerci al pilot's certificate operating a convent i onal aircraft
. The risks associated with the operat i on of the sUAS are so diminished from the level of risk associated with commercia l operations contemplated by Part 61 when drafted , that allowing operations of the sUAS as requested with a sport pilot certificate as the PIC exceeds the present level of safety achieved by 14 C.F.R. 61.113 (a) & (b).

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### 5.2 61.113 Private pilot privileges and limitations: Pilot in command. Extent of Relief Relief from requirement to possess a private or commercial pilot's license f or aerial work such as aerial survey and mapping. Reason for Relief §61.113 (a) stipulates that a holder of a private pilot certificate may not act as a pilot in command of an a ircraft f or comp ensat ion or hire; (b) states that a private pilot may act as PIC if the flight is incidental to business and does not carry passengers or property. Furthermore, N

- 8900 .227 "Unmanned Aircraft Systems (UAS) Op erational Approval" paragraph 16(c)(2)(c) " Operat ions without a pilot certificate" states that a operations which conform to said paragraph may be performed by a PIC that does not possess a private pilots license but that has completed FAA private pilot ground instruction and passed the FAA Private Pilot written test. In add ition , t here is no means currently of obtaining a commercial r ating for UAS. Thus , we require relief in order to perform aerial work. Public Benefit As described above, the public benefit includes exponentia l economic growth, enhanced safety, and improved precision agric ulture capabilities. Equivalent Level of Safety Our operations fullfill all the requirements in N-8900
. 227 16(c) (2) (c) for operations without a private pilots license. 

### 5.3 91.7 Civil aircraft airworthiness. Ext e nt of Relief 91.7 , a ll provis ions. Reason for Relief Should the exemption be granted allowing commercial operation of the sUAS without an airwor

thiness certificate, no standard will exist for airworthiness of t he sUAS. Equivalent Level of Safety Given the size and weight of these aircraft and the requirements contained in the GO M, an equivalent level of safety will be achieved by insuring compli ance with the sUAS user manuals prior to each flight. 

### 5.4 91.119, Minimum safe altitudes: General. Extent of Relief Section 91.119 establishes safe altitudes for operation of civil aircraft
. 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open

Doc ID: 98212bt20a069ID9c5594c2f802ae3e4502636bf7 water or sparsely populated areas, and the aircraft may not be operated closer than 500 feet to any person, vessel , vehicle , or structure. 

### R eas on for R e lie f To provide for these operations, the sUAS are normally operated at or below 400 feet AGL. In addition, due to the nature of the proposed operations , the PIC and the observer may at times be less than 500 feet away from structures during the operation. 

### Equivale nt Leve l o f S a fet y The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required permission of the property owner or local officia ls. Because of the advance notice to the property owner and participants in the aerial act i vity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. described above and the lack of flammable fuel , any risk associated with these operat ions is far less than those presently conducted with conventional a ircraft operating at or below 500 AGL in other industri es. In addition, the low-altitude operations of the sUAS wi ll ensure separation between these sUAS operat i ons and the operations of conventional aircraft that must comply with Section 91.119. 

### 5. 5 91.121 Altime t e r S ettings E x t e n t of R e lief §91.121 

### R eas o n for R e lie f As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemp tion may be needed. 

### Equivalent Leve l of S afety An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

### 5.6 91.151 , Fue l requireme nt s for flight in VFR condition s . E xtent o f R e lief §91.151, all provisions
. 

### Reas on for R e lief The provision requires fue l sufficient for one half hour flight beyond the destinat ion. These sUAS, includ ing today ' s longest endurance platforms, are unab le to meet this requirement because of limited max flight t imes.

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### Equivalent Level of Safety An equivalent level of safety can be achieved by limiting flights for the sUAS according to the safety limitations described in the GOM. This restriction would be more than adequate to return the sUAS to i ts planned l anding zone from anywhere in its limited op erating area. 

### 5.7 91.405, 91.407, 91.409, 91.417 Inspection and Maintenance Programs Extent of Relief 

### §§ 9 1. 405, Maintenance required; 91.407, Operation after maintenance, preventive maintenance , rebuilding, or alteration; 91.409 , Inspections; and 91.417 , Maintenance records. 

### Reason for R e lief The part 91 provisions are no t applicable to a sUAS of the described weight class. Furthermore, FAA cert ified mechanics for sUAS do not at this present t ime exist, so full compliance is not possible. The sUAS flown are modular and as such entire components including engines and propellers are minor rep lacements rather than ma j or repairs. Finally, continuous minor alterations and payload reconfigurations of sUAS are designed and required for the operation of sUAS and do not negatively impact a irworthiness. 

### Equivalent Level of Safety Inspection and maintenance manuals are used to maintain the sUAS in airworthy condition. E ach sUAS is maintained accordin g to the manufacturer standard or higher by technicians proficient in the building, repair , and maintenance of the sUAS
. Inspection and Maintenance manuals utilized contain all aircraft

-relevant items as described in (43 Appendix D (Scope and Detail of Items)
. Maintenance records are maintained in SkyWard Operations Database Appendix B (Recording of Major Repairs and Major Alterations) and are therefore immed iately auditab l e by regulators on demand. Finally, SkyWard manuals will be submitte d to the local FS DO ASI or other appropriate FAA division directly. 

### 6 Public Interest Sandoval believes that the enhanced saf ety achieved using a sUAS with the specifications described in this petition and supporting documents and by carrying no passengers or crew, rather than a manned a ircraft of si gnificantly greater proportions carrying crew in addition to flammable fuel , gives the FAA good cause to find that the UAS operat ions en abled by this exemption a re in the public interest. The outputs of safe, reliable, and regulatory compliant operations of sUAS provide economic benefits historically unparalleled since the invention of fl i ght, benefitting stakeholders at every level , both public and private. Lawful , safe aerial robotics operations will create new high-tech employment that will stimulate city and state governments; improve industries, create new small and large

Doc ID: 98212bf20a069ID9c5594c2f802ae3e4502636bf9 businesses; infuse new interest in STEM for children; and increase the safety of citizens through enhanced first-responder capabilities. 

### 7 Privacy All flights will occur over private , limited, or restricted-access areas with the property owner's prior consent and knowledge. Operations will be conducted by trained crew and all other individuals will either be a part of the operation or consent to be present at the time of operations. 

### 8 Federal Register Summary Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register , should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21 , subpart H ; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b), 61.133(a); 91.7 (a); 91.9 (b) (2); 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a.) (2) and 91.417 (a) & (b) to operate sU AS for commercial use. 

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### Conclusion Sandoval seeks this exemption to conduct commercial operations using sUAS within restrictedaccess areas in the NAS
. Without this exemption, sUAS innovation will be suppressed , the public economic benefits derived from increased sUAS development will be denied, and the Congressional directive to accelerate the integration of UAS into the NAS will be impeded. The sUAS physical and operational characteristics are compliant with those described in the FMRA and FAA's guidance for Sec 333 exemptions. Sandoval respectfully requests that the FAA grant its petition for exemption from airworthiness. Please do not hesitate to contact Andrew McCollough, the Regulatory Services POC, via email at exemption @skyward.io if you have any questions or concerns. Very Respectfully Yours ,
Eric Sandoval S&A CEO

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