November 6, 2014 

Robert Pappas 

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20951 

Re: Yamaha Motor Corporation, U.S.A.'s Petition for Exemption for the RMAX RemotelyPiloted Helicopter- Docket ID - F AA-20 14-0397 

Dear Mr. Pappas: 

This letter is submitted on behalf of Yam aha Motor Corporation, U.S .A. ("Yamaha"), in 

response to the Federal Aviation Administration's ("FAA") October 23, 2014 request for additional 

information from Yamaha in support of the above-referenced petition for exemption ("Petition"). Set 

forth below are the FAA's additional information requests and Yamaha's responses to same. 

FAA Information Request: 

1. Your petition seeks an exemption from 14 CFR part 13 7. 14 CFR part 13 7 prescribes rules 

governing agricultural aircraft operations within the United States. Per 14 CFR § 137.11(a), no 

person may conduct agricultural aircraft operations without, or in violation of, an agricultural 

aircraft operator certificate issued under 14 CFR part 13 7. Per 14 CFR § 13 7.15, applications 

for an agricultural aircraft operator certificate is filed with the FAA Flight Standards District 

Office that has jurisdiction over the area which the applicant's home base of operations is 

located. 

As you know, Unmanned Aircraft Systems meeting the conditions of Section 333 do not 

require an FAA issued airworthiness certificate to operate in the NAS. Therefore, under 

Section 333, the RMAX cannot comply with certain provisions of 14 CFR part 137, such as 14 

CFR § 13 7 .19( d). Though exemptions from specific provisions of 14 CFR part 13 7 may be 

necessary, an agricultural aircraft operator certificate will be required for your intended 

operations. 

To assist with our evaluation of your petition, please clarify the provisions of 14 CFR part 137 

from which you seek exemption, particularly the operating requirements, and the associated 

rationale as to why there would be no adverse safety impact. 
Mr. Robert Pappas 

November 6, 2014 

Page 2 of 4 

Response: 

As indicated in the Petition (at 7, 19), Yamaha seeks an exemption from only some of the 

requirements of 14 CFR part 137. Yamaha intends to comply with the remaining requirements 

of Part 13 7 for the kind of agricultural chemical spraying and dispensing operations covered by 

Part 13 7.3. The specific Part 13 7 requirements for which exemptions are sought include the 

following: 

• Part 13 7 .19( d): This subpart requires an applicant to have at least one certificated and 

airworthy aircraft, equipped for agricultural operation. As explained in the Petition, the 

RMAX will not have an airworthiness certification to satisfy this requirement but can 

operate safely in the national airspace for the specific purposes, and pursuant to the 

operating conditions and restrictions, described in the Petition (at 5-12, 19). 

Accordingly, Yamaha requests an exemption from this subpart. 

• Part 137.19(e)(2)(ii), (iii), and (v): These subparts require a demonstration of skills to 

perform certain maneuvers intended for manned aircraft, including (i) short field and 

soft field takeoffs; (ii) approaches to the working area; (iii) flare-outs; and (v) pull-ups 

and turnarounds. These maneuvers are inapplicable to the RMAX when performing 

agricultural services. Other skills requirements in this provision (i.e., subparts (iv) 

swath runs; and (vi) rapid deceleration (quick stops)) are applicable to the RMAX and 

no exemption is sought from these subparts. Given the nature and design of the 

RMAX, demonstrated compliance with the applicable skill requirements, along with the 

knowledge requirements of Part 13 7 .19( e )(1 ), will provide an adequate level of safety 

for operation of the RMAX. (For clarity, these applicable skills tests would be 

performed with the pilot using an RMAX.) There would be no adverse safety impact 

from granting an exemption to the inapplicable skills requirements identified above. 

For these reasons, Yamaha requests an exemption from subparts (e)(2)(ii), (iii), and (v). 

• Part 137.31(a): This subpart incorporates the airworthiness requirements ofPart 

13 7 .19( d) and, for the same reasons explained above and in the Petition, Yamaha 

requests an exemption from subpart 13 7.31 (a), as well. 

• Part 13 7.31 (b): This subpart requires that an aircraft be equipped with a suitable and 

properly installed shoulder harness for use by each pilot. Because the RMAX is an 

unmanned aircraft, these requirements are inapplicable to the RMAX. Instead, as more 

fully described in the Petition, the RMAX is remotely piloted by a trained operator 

along with a trained spotter. Both the RMAX pilot and spotter are required to maintain 

appropriate distances (no less than 20 meters) from the RMAX at all times during 

operation, including takeoff and landing, to ensure their safety while the RMAX is in 

flight. See Petition, Exhibit 6 at 52, 187-88; Exhibit 7 at B2-5, 01-21, and 01-49. 

These requirements provide an equivalent level of safety for RMAX pilots and spotters 

as the requirements in this subpart. Accordingly, Yamaha requests an exemption from 

this subpart. 
Mr. Robert Pappas 

November 6, 2014 

Page 3 of 4 

• Part 137.33(a): This subpart requires that a facsimile of the agricultural aircraft 

operator certificate be carried on the aircraft and presented for inspection as requested. 

Because the RMAX is an unmanned aircraft, this requirement is inapplicable. Yamaha 

instead would require RMAX pilots to have copies of the required certificate with them 

and available for inspection at all locations where and while the RMAX is being used to 

perform agricultural chemical spray application and dispensing services. Granting an 

exemption to this subpart, under these circumstances, would have no adverse safety 

impact. 

• Part 137.42: This subpart requires use of safety belts and shoulder harnesses by pilots. 

Because the RMAX is an unmanned aircraft, these requirements (like those in Part 

137.31(b)) are inapplicable. Instead, as discussed above, both the RMAX pilot and 

spotter are required to maintain appropriate distances from the RMAX during operation, 

including takeoff and landing, to ensure their safety while the RMAX is in t1ight. These 

requirements provide an equivalent level of safety for RMAX pilots and spotters as the 

requirements in this subpart. Accordingly, Yamaha requests an exemption from this 

subpart, as well. 

FAA Information Request: 

2. Your petition seeks as exemption from 14 CFR § 91.119. In support of an equal level of safety, 

the petition states, "The successful safety record of the RMAX, involving more than two 

million t1ight hours, demonstrates that the RMAX can be safety used at these lower altitudes 

and closer operating environments." In part, this is intended to address your proposed 

operation of the RMAX at distances less than 500 feet from the pilot in command and the 

designated spotter. 

To assist with our evaluation of your petition for relief from 14 CFR § 91.119, please provide 

information on RMAX failures that may result in the departure of any component(s) and 

describe the potential hazards relative to the mass, velocity, and other pertinent design and 

failure characteristics of each component. Using this information, describe the safety zone 

required around the aircraft to ensure the safety of persons and property on the ground. 

Response: 

Information in response to this request constitutes confidential business information and, 

therefore, is being separately submitted by Yamaha on a confidential basis. 
Mr. Robert Pappas 

November 6, 2014 

Page 4 of 4 

Yamaha appreciates the oppmiunity to submit this additional information in support of its 

Petition. Please let me know if you have any further questions or need any other information from 

Yamaha. 

Respectfully submitted, 

David P. Murray 

cc: Robert Trester 

Yamaha Motor Corporation, U.S.A.