November 6, 2014

Robert Pappas U.S. Department ofTransportation Federal AviationAdministration 800 Independence Avenue, SW Washington, DC 20951

Re: Yamaha Motor Corporation, U.S.A.'s Petition for Exemption for the RMAX RemotelyPiloted Helicopter- Docket ID - FAA-2014-0397

Dear Mr. Pappas:

This letter is submitted on behalfofYamaha 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 ofthe 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 CFRpart 137. 14 CFRpart 137 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 CFRpart 137. Per 14 CFR § 137.15, applications for an agricultural aircraft operatorcertificate is filed withthe FAA Flight Standards District Office that hasjurisdiction overthe area which the applicant's home base ofoperations is located.
As youknow, Unmanned Aircraft Systems meeting the conditions ofSection 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 CFRpart 137, such as 14 CFR § 137.19(d). Though exemptions from specific provisions of 14 CFRpart 137 may be necessary, an agricultural aircraft operator certificate will be required for your intended operations.
To assist with our evaluation ofyourpetition, please clarify the provisions of 14 CFRpart 137 from which you seek exemption, particularlythe operating requirements, andthe associated rationale as to why there would be no adverse safety impact.Mr. Robert Pappas November 6, 2014 Page 2 of4



### Response:
As indicated in the Petition (at 7, 19), Yamaha seeks an exemption from only some ofthe requirements of 14 CFRpart 137. Yamaha intends to comply withthe remaining requirements ofPart 137 for the kind ofagricultural chemical spraying and dispensing operations covered by Part 137.3. The specific Part 137 requirements for which exemptions are sought include the following:

• Part 137.19(d): This subpart requires an applicant to have at least one certificated and airworthy aircraft, equipped for agricultural operation. As explained inthe Petition, the RMAX will nothave an airworthiness certificationto satisfy this requirement but can operate safely inthe national airspace for the specific purposes, andpursuantto the operating conditions and restrictions, described in the Petition (at 5-12, 19). Accordingly, Yamaharequests an exemption from this subpart.

• Part 137.19(e)(2)(ii), (iii), and (v): These subparts require a demonstration ofskills 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 whenperforming agricultural services. Other skills requirements in this provision (i.e., subparts (iv) swathruns; and (vi) rapid deceleration (quick stops)) are applicable to the RMAX and

no exemptionis sought from these subparts. Giventhe nature and design ofthe RMAX, demonstrated compliance withthe applicable skill requirements, along with the knowledge requirements ofPart 137.19(e)(1), will provide an adequate level ofsafety for operation ofthe RMAX. (For clarity, these applicable skills tests would be performed withthe pilot using an RMAX.) There would be no adverse safety impact from granting an exemption to the inapplicable skills requirements identified above. Forthese reasons, Yamaharequests an exemption from subparts (e)(2)(ii), (iii), and (v).

• Part 137.31(a): This subpart incorporates the airworthiness requirements ofPart 137.19(d) and, for the same reasons explained above and in the Petition, Yamaha requests an exemption from subpart 137.31(a), as well.

• Part 137.31(b): This subpart requires that an aircraftbe equipped with a suitable and properly installed shoulderharness for use by eachpilot. 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. Boththe RMAX pilot and spotter are required to maintain appropriate distances (no less than 20 meters) from the RMAX at all times during operation, including takeoffand 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 ofsafety for RMAX pilots and spotters

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

### Mr. Robert Pappas November 6, 2014 Page 3 of4

• Part 137.33(a): This subpartrequires that a facsimile ofthe agricultural aircraft operator certificate be carried onthe 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 ofthe 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 exemptionto this subpart, under these circumstances, would have no adverse safety impact.

• Part 137.42: This subpart requires use ofsafety 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, boththe RMAX pilot and spotter are required to maintain appropriate distances from the RMAX during operation, including takeoffand landing, to ensure their safety while the RMAX is in t1ight. These requirements provide an equivalent level ofsafety for RMAX pilots and spotters as the requirements in this subpart. Accordingly, Yamaharequests an exemption from this subpart, as well.

FAA Information Request:

2. Your petition seeks as exemption from 14 CFR § 91.119. In support ofan equal level ofsafety, the petition states, "The successful safety record ofthe 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 ofthe RMAX at distances less than 500 feet from the pilot incommand and the designated spotter. To assist with our evaluation ofyour petition for relieffrom 14 CFR § 91.119, please provide information on RMAX failures that may result in the departure ofany component(s) and describe the potential hazards relative to the mass, velocity, and other pertinent design and failure characteristics ofeach component. Using this information, describe the safety zone required around the aircraft to ensure the safety ofpersons 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 of4

Yamaha appreciates the oppmiunity to submit this additional information in support ofits Petition. Please let me know ifyou 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.