-· DAS 800 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) Submitted on October 9, 2015 Michael A. Klumpp Nickolas C. Houghton Detailed Aerial Solutions, LLC 1955 E Walton Rd. Shepherd, MI 48883 Tel: (989) 312-3556 .**<:~:·/:.::·::~** :;:l:-' '.. ·'**~** ·;....-

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,..., ·i-:.,:**~~:"-**:.**-~·~:**!:;:j1-**-~~**'t-.:-... ,l ·: /'"·'..' .·.. 0' 1TABLE OF CONTENTS ,., GLOSSARY OF ABBREVIATIONS ................................................................................. -' SUMMARY ......................................................................................................................... 4 INTRODUCTION AND INTERESTS OF PETITIONER ................................................ .4

BACKGROUND ................................................................................................................. 4 BASIS FOR PETITION ...................................................................................................... 5 NAME AND ADDRESS OF PETITIONER ...................................................................... 6 THE SPECIFIC SECTIONS OF14 C.F.R. FROM WHICH DETAILED AERIAL SOLUTIONS, LLC SEEKS EXEMPTION ......................................... : ...................................................... 6 THE EXTENT OF RELIEF DETAILED AERIAL SOLUTIONS, LLC SEEKS AND THE REASON DAS SEEKS THE RELIEF ............................................................................... & THE REASONS WHY GRANTING DETAILED AERIAL SOLUTIONS, LLC REQUEST WOULD BEIN THE PUBLIC INTEREST ...................................................................... !0 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ............................................................................................................................. !! SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER .................. l2 CONCLUSION ................................................................................................................... 24 2GLOSSARY OF ABBREVIATIONS AGL Above Ground Level

AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization

AV Aerial Vehicle C.F.R. Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOT AM Notice to Airman

PIC Pilot In Command Section 333 FAA Modernization and Reform Act of2012 (FMRA) Section 333 SOP Standard Operating Procedures

UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions

YO Visual Observer VTOL Vertical Takeoff and Landing 4 3SUMMARY Detailed Aerial Solutions, LLC seeks exemption from the requirements of14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b),

to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Detailed Aerial Solutions to operate an Unmanned Aircraft System (UAS) forthe commercial purpose of conducting aerial acquisitions and research over certain rural areas ofthe United States. INTRODUCTION AND INTERESTS OF THE PETITIONER Detailed Aerial Solutions, LLC (hereinafter referred toas "DAS") isan unmanned aircraft solutions provider that integrates engineering and manufacturing with services that enable the technology for

federal, state, local, and commercial clients. DAS is focused on providing solutions for utilizing unmanned aircraft to safely and efficiently collect data thatis precise, accurate, and timely. DAS's mission istouse unmanned aircraft to simplify and increase the effectiveness of data collection in: Natural Resources and Conservation, Construction and Infrastructure, Precision Agriculture, as well as Inspection and Monitoring. Asset forth inthis Petition, DAS seeks to commercially operate its DAS 800 UAS over certain rural areas ofthe United States forthe purpose of conducting aerial acquisitions and research. BACKGROUND Unmanned Aircraft System: DAS 800 DAS seeks an exemption to operate the DAS 800 UAS for compensation orhire within the National Airspace System ("NAS"). The DAS UAS is comprised ofa vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) anda transportable Ground Control Station (GCS). The DAS 800 hasa

maximum gross weight of approximately 8.1 pounds, while having a rotorspan of20.1 inches, and maximum speed of16 mph. The DAS 8000 is equipped with eight propellers, each being driven bya

Lithium Polymer battery powered electric motor. The DAS 800 that will be operated by DAS will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. Figure 1:The DAS 800. 4BASIS FOR PETITION Petitioner, Detailed Aerial Solutions, LLC., by and through undersigned counsel, pursuant tothe provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform 6Act of2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate the DAS UAS inthe NAS, and foran exemption from the requirements of14C.F.R§§ 61.113(a) &(b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)( I), 91.409(a)(l) & (a)(2), and 91.417(a) &(b). In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft andits operation, DAS's operation ofthe DAS 800 UAS meets the conditions of Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Accordingly, DAS requests relief from Sections 91.405(a), 91.407(a)( 1), 91.409(a)( I)& (a)(2), and 91.417(a) &(b),as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. DAS submits that the requested relief is proper since an equivalent level of safety will be ensured. DAS, as manufacturer ofthe DAS 800 UAS, will useits technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed inthe manufacturer's maintenance manual. Furthermore, DAS will document and

maintain all maintenance records forthe DAS 800 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by DAS tothe extent necessary to allow aPilot in

Command (PIC) holding a private pilot certificate anda third-class airman medical certificate, and who has completed the DAS 800 training and currency requirements, to conduct the proposed UAS operations. DAS submits that the conditions and limitations set forth herein will ensure the safety of the NAS, as well asthe safety of persons or property onthe ground. DAS seeks relief from Section 91. 7(a), entitled Civil aircraft ainvorthiness, because the DAS 800 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

As such, DAS submits thatitwill ensure that the DAS 800 UAS isinan airworthy condition, prior to every flight, by determining that the UAS isin compliance with the DAS 800 UAS Operator Manual, the DAS of Systems Operations Manual, and the DAS 800 Maintenance Manual, and that the UAis

in condition for safe flight. DAS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as

the DAS 800is equipped witha barometer and Global Positioning System (GPS) equipment, which ensures thata ground level pressure setting will be established prior to each flight. DAS's barometer and GPS equipment ensure safety by providing the PIC with adequate information concerning altitude ofthe UAS, above ground level (AGL), as shown onthe heads-up display ofthe GCS. Additionally, DAS seeks an exemption from the requirements of Section 91.151 (b), Fuel requirements for flight inVFR conditions. DAS submits that safety will notbe affected by

terminating flights ofthe battery powered DAS 800 after 15 minutes of continuous flight, which would allow for three minutes (i.e, 20 percent) of battery power remaining. 5In accordance with 14C.F.R.§ 11.81, DAS provides the following information in support ofits petition for exemption: A. Name And Address Of The Petitioner. The name and address ofthe Petitioner is: Detailed Aerial Solutions, LLC 1955 E Walton Rd Shepherd, Ml 48883 The point of contact for this Petition and specific contact information isas follows: Michael Alan Klumpp and Nickolas C. Houghton Detailed Aerial Solutions, LLC 1955 E Walton Rd. Shepherd, Ml 48883 Tel: (989) 312-3556) Email: mike@detailedaerialsolutions.com and nick@detailedaerialsolutions.com B. The Specific Sections Of14 C.F.R. From Which DAS Seeks Exemption. 1. DAS Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in part: (a) No person who holds a private pilot certificate may actasapilot in command (PIC) ofan aircraft thatis carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, actasPIC ofan aircraft. (b)A private pilot may, for compensation or hire, actasPIC ofan aircraft in connection with any business or employment if- (1) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. 2. DAS Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate acivil aircraft unless itisinan airworthy condition. 3. DAS Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in relevant part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, asthe case may be,by reference toan altimeter thatisset, when operating-- (I)

Below 18,000 feet MSL, to- (i) The current reported altimeter setting ofa station along the route and within I00 nautical miles ofthe aircraft; (ii) lfthere isno station within the area prescribed in paragraph (a)(l)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or6(iii)Inthe case ofan aircraft not equipped witha radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure; 4. DAS Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight inVFR conditions, subsection (b), states the following: (b) No person may begin a flight ina rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fueltoflytothe first point of intended landing and, assuming normal cruising speed, tofly after that forat least 20 minutes. 5. DAS Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c)ofthis section, have discrepancies repaired as prescribed inpart 43ofthis chapter[.) 6. DAS Seeks Exemption From The Requirements Of Section 91.407(a)(1). Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a)No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1)Ithas been approved for return to service bya person authorized under§ 43.7 of this chapter[.) 7. DAS Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c)ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, ithas had-- (1)An annual inspection in accordance with part 43ofthis chapter and has been approved for return to service bya person authorized by§ 43.7 ofthis chapter; or (2)An inspection forthe issuance ofan airworthiness certificate in accordance with part21ofthis chapter. 8. DAS Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records forthe periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i)A description (or reference to data acceptable tothe Administrator) ofthe work performed; and 7(ii) The date of completion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return 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 ofall items installed onthe aircraft which are required tobe overhauled ona specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required bythe inspection program under which the aircraft andits appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the ADor safety

directive number and revision date. Ifthe ADor safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration tothe airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work orforIyear after the work is performed.(2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. (3)Alistof defects furnished toa registered owner or operator under§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service. C. The Extent OfReliefDAS Seeks And The Reason DAS Seeks The Relief. 1. Extent of Relief DAS Seeks And The Reason DAS Seeks Relief From Section 61.113(a) And (b).Relief from Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested tothe extent necessary to allow aPIC holding a private pilot certificate anda third-class airman medical certificate, and who has completed the DAS 800 UAS training and

currency requirements, to conduct the proposed UAS flight operations for compensation. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state thata private pilot may, for compensation or hire, actasPIC ofan aircraft in connection with any business or employment if(I) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Asset forth more fully below, DAS submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DAS 800 unless that PIC has demonstrated, through the DAS 800 UAS training and currency requirements, that the PICisable to safely operate the DAS 800 UAS ina manner consistent with the operations specifications as described inthis exemption, 8including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, DAS submits that all flights ofthe DAS 800, conducted bythe PIC pursuant tothe grant of this Petition (I) will be incidental to DAS's business; and (2) will not carry passengers or property for compensation or hire.

2. Extent ofReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.7(a). Relief from Section 91.7(a), entitled Civil aircraft ainvorthiness, is requested tothe extent required to allow DAS to determine that the DAS 8000 UAS isinan airworthy condition prior to every flight by ensuring that the UAS isin compliance with the DAS 800 UAS Operator Manual, the DAS Family of Systems Operations Manual, and the DAS 800 UAS Maintenance Manual, and that the UA isin condition for safe flight. Copies ofthe manuals, which contain proprietary information, are attached hereto as Exhibits A,B,andC, respectively, and aretobe held ina separate file pursuant to 14 C.F.R. § 11.35(b). DAS seeks the requested relief because the DAS 800 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DAS will ensure that the DAS 8000 UAS isinan airworthy condition based upon its compliance with the operating documents prior to every flight, andas stated inthe conditions and limitations below. 3. Extent ofReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DAS 800 UAS, which utilizes a barometer and GPS equipment, to ensure thata ground level pressure setting will be established prior to each flight, in order to report altitude tothe PIC. DAS seeks the requested relief because the DAS 800 UAS does not utilize a typical barometric altimeter onboard that may besetas contemplated by Section 91.121. As more fully set forth below, an equivalent level of safety will be maintained since the DAS 800UASis equipped witha barometer and GPS equipment, which will ensure thata ground level pressure setting will be established prior

to each flight, and provides the PIC with altitude information ofthe UA, above ground level (AGL), onthe heads-up display ofthe ground control station (GCS). 4. Extent OfReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.151(b). Relief from Section 91.151 (b), entitled Fuel Requirements for flight inVFR conditions, is requested tothe extent required to allow flights ofthe battery powered DAS 800 UAS, during daylight hours in visual meteorological conditions under visual flight rules (VFR), to continue foratotal duration of 15 minutes, which will ensure that the UA will land with three minutes (i.e., 20 percent) ofbattery power remaining. DAS seeks the requested relief, because without an exemption from Section 91.151 (b), the flight time duration ofthe battery powered DAS 800 UAS will severely constrain the practicality ofany aerial acquisition and research flight operations which DAS proposes to conduct pursuant tothis Petition. Significantly, asset forth below, the technical specifications ofthe DAS 800 UAS, the DAS Operations Manual, and DAS's proposed operating limitations, ensure that DAS will safely operate the battery powered DAS 800 UAS during daylight hours in VFR conditions foratotal flight duration of15 minutes, landing with three minutes (i.e., 20 percent) ofbattery power remaining. 5. Extent Of Relief DAS Seeks And The Reason DAS Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) &(b). 9Since Sections 91.405(a), 91.407(a)( I), 91.409(a)( I)& (a)(2), and 91.417(a) &(b) only apply to aircraft with an airworthiness certificate, DAS requests relief from these Sections because DAS 800 UAS does not require an airworthiness certificate. Asset forth more fully below, the DAS 800 UAS meets the conditions of Section 333 ofthe FMRA for operation without an airworthiness certificate. Accordingly, DAS, which manufactures the DAS 800 UAS, will use DAS technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed inthe manufacturer's maintenance manual. Furthermore, DAS will document and maintain all maintenance records for the DAS 800 UAS.

D. The Reasons Why Granting DAS's Request Would BeIn The Public Interest; That Is, How It Would Benefit The Public AsA Whole. Granting the present Petition will further the public interest by allowing DAS to safely, efficiently, and economically perform aerial acquisitions and research over rural areas ofthe United States, commercially, in support of government entities, agriculture, scientific studies, wildlife monitoring, forestry operations, and theoil and gas industries. Additionally, use ofthe DAS 800 UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits tothe economy. Notably, the benefits ofDAS's proposed operation ofthe DAS 800 UAS will be realized without implicating any privacy issues. 1.The Public Will Benefit From The Aerial Acquisition And Research Performed. DAS submits this Petition to commercially operate the DAS 800 UAS and perform aerial acquisition

and research throughout rural areas ofthe United States, in support of government entities, agriculture, scientific studies, wildlife monitoring, forestry operations, mining, and theoil and gas

industries. The DAS 800 UAS will provide safe, efficient, and economical aerial acquisition and

research operations to further each ofthese fields, allof which are critical tothe well-being ofthe

general public. The specific operations that DAS will perform with the DAS 800 UAS demonstrate how the requested exemption will directly benefit the above-referenced industries and the public. In agriculture, the aerial acquisition performed bythe DAS 800 UAS will be used to predict and increase crop yields, as well as research forthe prevention of crop disease. Intheoil and gas industry, the DAS 800 UAS will be used toaidin facility inspections, survey and plan new worksites, conduct volumetric analysis, and perform right of way analysis. The DAS 800 UAS will also further environmental management by researching invasive species, mapping deforestation, and surveying point source pollution. 2.The Public Will Benefit From Decreased Congestion Of The NAS. The DAS 800 UAS is battery powered and serves asasafe, efficient, and economical alternative to

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the useofa DAS 800 UAS

would reduce the amount of manned aircraft inthe NAS, reduce noise and air pollution, as well as increase the safety oflife and property intheair and onthe ground. Furthermore, by reducing the number of manned aircraft operating inthe NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DAS 800 UAS does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial survey missions would result in fewer aircraft that must be handled byair traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 103.The Public Will Benefit From The Safety And Efficiency Of THE DAS 800 UAS. Conducting aerial acquisitions with the DAS 800 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial survey flight operations. By using battery power and electric motors, the DAS 800 UAS produces noair pollution, andisthe most viable environmentally conscious alternative tothe cabin class, six cylinder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of leaded aviation fuel. DAS 800 UAS, while reducing the carbon footprint of aerial acquisitions, also reduces noise pollution, asthe

UAis propelled by battery powered electric motors, rather than an internal combustion engine. By using the DAS 800 UAS to perform aerial acquisitions, the substantial risktolife and property in theair and onthe 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 DAS 800 UAS (weighing approximately 8.1 pounds atits maximum gross weight witha rotorspan of 20.1 inches, and with no fuel on board), has less physical

potential for collateral damage tolife and property onthe ground, andinthe air, compared tothe manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds witha wingspan of approximately 40 feet,a length of34 feet, andafuel capacity of180 gallons). 4. Performing Aerial Acquisition Operations With The DAS 800 UAS Will Benefit The Economy.In addition to being safe and efficient, the DAS 800 UAS isalso an economical alternative to using manned aircraft to conduct aerial acquisitions. As such, operation ofthe DAS 800 UAS will allow

United States based companies, like DAS, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency

("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 powered DAS 800 UAS isone such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft.

By operating the DAS 800 UAS companies such as DAS can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial useofthe DAS 800 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 inthe United States and abroad. 5. There Are No Privacy Issues. Similar tothe manned aerial acquisition flight operations that have been conducted for decades, DAS's proposed operation ofthe DAS 800 UAS will not implicate any privacy issues. Specifically, the DAS 800 UAS will be operated only in rural areas, andin accordance with all Federal Aviation Regulations, including the minimum altitude requirements of14 C.F.R. § 91.119. Most significantly, the DAS 8000 UAS will notbe operated closer than 500 feettoany person, vessel, vehicle, or structure, which isnot directly involved inthe operation. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which DAS Seeks Exemption. 111. Reasons Why The DAS 800 UAS Meets The Conditions Of The FAA Modernization and Reform Actof 2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft andits operation, DAS's operation ofthe DAS 800 UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14C.F.R. Part 21, Subpart H. Section 333 provides authority foraUAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise posea threat to national security. Specifically, FMRA Section 333 states the following, in part: (a)In General.--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days after the date of enactment ofthis Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely inthe national airspace system before completion ofthe plan and rulemaking required by section 332 ofthis Actor the guidance required by section 334 ofthis Act. (b) Assessment of Unmanned Aircraft Systems.--ln making the determination under subsection (a), the Secretary shall determine, ata minimum-- (1) which types of unmanned aircraft systems, ifany, asa result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight donot create a hazard to users ofthe national

airspace system orthe public or posea threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or ainvorthiness certification under section 44704 oftitle 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (b) Requirements for Safe Operation.--!fthe Secretary determines under this section that certain unmanned aircraft systems may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems

inthe national airspace system. In seeking this exemption, DAS submits that the DAS 800 UAS can operate safely inthe NAS pursuant to FMRA Section 333, as demonstrated by:(a)the characteristics ofthe DAS 800 UAS; (b) the pilot certification requirement; and (c)the specific operating limitations.

a.The Specifications Of The DAS 800 UAS Demonstrate Its Safe Characteristics. The DAS 800 UAS does not create a hazard to users ofthe NAS orthe public, or otherwise posea threat to national security considering its size, weight, speed, and operational capability: i.Technical Specifications Of DAS 800 UAS. Unmanned Aircraft System Unmanned Aircraft Dimensions The DAS 800 UAS isan Unmanned Aircraft System thatis comprised of vertical takeoff and landing (VTOL) unmanned aircraft anda transportable ground control station. Rotorspan: 20.1 inches 12Engine (Propulsive Unit) Fuel Engine (Propulsive Unit) Limits Propeller and Propeller Limits Engine (Propulsive Unit) (8) SunnySky V2216-12 kVII (Electric) fAA Engine Type Cert: None Propulsive Unit Type: 16.8V, 22 Amp Hour

capacity, Lithium ion battery powered, direct drive electric motor Motor, Electric Sub-Assembly: Manufacturer: SunnySky Model: V2216-12Battery: Manufacturer: MultiStar

Type: l(one) x Lithium Ion I0 Amp hour each 16.8V (nominal)

Not Applicable.NOTE: The DAS 800is powered bya Lithium Polymer rechargeable battery, DAS PIN 30142.Maximum Power Output: 1.6HP Maximum RPM: 8,316 RPM Maximum Motor Temperature: 170°f(77 oq NOTE: The motor temperature isnot displayed tothe operator. Maximum motor, controller sub-assembly temperature: 194Of(90 °C) Power On (Engine and Rotor Tach, neither visible to operator)Maximum 8316 RPM Minimum 3742 RPM (4) DAS. PIN 30490 fAA Propeller Type Certificate: None Propeller Type: 2-blade, plastic, fixed pitch, tractor Propeller Sub-Assembly:Manufacturer: APC Propeller Model: CAM 16x5.5MPR Diameter (Nominal): 16in. (4) DAS PIN 30488 fAA Propeller Type Certificate: None Propeller Type: 2-blade, plastic, fixed pitch, tractor Propeller Sub-Assembly:Manufacturer: APC Propeller 13Battery Command & Control Airspeed Limits Empty Weight C.G. Range Datum Maximum Weights Empty WeightFrequencies Computer Software Minimum Crew

Number of Seats Fuel Capacity

Oil Capacity Model: CAM 16x5.5MR Diameter (Nominal): 16in. I (one) DAS Air Vehicle Batteries PIN 30142 power the motors, and battery command and control.Vne (Never Exceed Speed) 14.5 knots (7.5 m/s)-Ito1 inches of datum Centroid of Vehicle Ramp 8.4 lbs. Takeoff 8.4 lbs. Landing 21.4 lbs.

7.7lbs. NOTE: Empty Weight Excludes weight of batteries and payload modules. 902-928 MHz (ISM Band) 2.4 GHz (ISM Band) NOTE: FCC license isnot required to utilize the above frequencies; uplink and downlink areonthe 900Mhz band. If video is utilized, uplink, downlink, and video areallon2.4

Ghz. Avionics embedded processor, PIN 30306 (I) The DAS 800 canbe operated bya single operator.(0) Not Applicable. Not Applicable. Not Applicable. 14Max. Operating Altitude Rotor Blade and Control Movements Nominal Endurance Ambient Outside Air Temperature (OAT) Wind Limitation Maintenance I ,200ft. AGL Fixed Rotor Control. Vehicle control is achieved through varying thrust of each motor individually25 minutes above 32°F(0°C) 12 minutes below 32°F(0°C) Maximum OAT: 120°F(49 °C) Minimum OAT At Altitude: -20°F (-29 °C) 9.7 knotsThis DAS 800 UAS must be maintained in accordance with the manufacturer's maintenance manual, or later FAA accepted revision. ii.The DAS 800 Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. A complete description ofthe autonomous modes and methods of navigation for the DAS 800is provided inthe DAS 800 Operator Manual. 3.A copy ofthe DAS 800 Operator Manual, which contains proprietary information, is attached hereto as Exhibit A, andistobe held ina separate file pursuant to14 C.F.R. § 11.35 (b)I .I Exhibits tothis Petition contain proprietary infonnarion. andin accordance "ith 14 C.F.R. §I 1.35(b), arenottobe included inthe Federal Docket Management System (FDMS).iii. The DAS 800Is Designed For Complete Autonomy From Launch To Landing Even In The Unlikely Event Of Loss Of The Control Link Or Navigation. Although a degradation orloss ofthe control link, and/or degradation or loss ofthe source of navigation is unlikely, itisa situation thatiswell planned for and therefore, isa benign event. The DAS 800is designed for complete autonomy from launch to landing withaline of sight operator in

the loop monitoring the airframe. The DAS 800 usesa two-stage failsafe approach forall avionics failure conditions, including the event ofaloss of communications ("Lost Link"). Upon loss ofthe communication signal, the DAS

800 will attempt to reacquire the link. If afterI0 seconds the link has not been reacquired, the DAS 800 will continue to attempt to reacquire the link while maintaining the current altitude and navigating tothe home waypoint, which isthe same asthe location ofthe ground control station. Once atthe home waypoint, the DAS 800 will hover while continuing its attempt to reacquire the

link for30 seconds (to allow for rebooting ofthe ground control station, if needed). The DAS 800 will then continue to attempt to re-acquire the link while it navigates through the landing procedure. The landing procedure for Lost Link is identical toa normal landing procedure. The DAS 800 will enter intoa hover-land procedure; descending while reducing speed until contact with the ground. During this decent and touchdown, the DAS 800 will remain in controlled flight. 15Loss ofGPS signal will result ina two-tiered recovery approach. Upon loss ofaGPS signal, the DAS 800 will immediately hover inan attempt to reacquire a signal. If after 15 seconds, aGPS signal isnot reacquired, the UA will enter tier-two recovery. At any time during either tier-one or tier-two recovery, the operator can take over with augmented control and utilize its onboard magnetometer to navigate back tothe home waypoint through dead-reckoning. During this failure mode, the observer will call out UA position and movement back tothe operator. Once the UAis

close enough to resolve orientation, orif operating withalive video payload, the operator can engage manual control and perform a manual landing atthe pre-decided landing site. Ifa cascade of failures has occurred and Lost-Link has also occurred during tier-two recovery, the DAS 800 will enter intoa hover-land procedure; descending while reducing speed until contacting

the ground. Throughout this decent and touchdown, the DAS 800 will remain in controlled flight. The DAS 800 Operator Manual at Chapter 8 "Emergency Procedures" fully describes the features of

the DAS 800, and sets forth the UA's operation inthe event ofa power loss, loss of communications, loss ofGPS signal, loss of video link, or software crash. A copy ofDAS 800 Operator Manual, which contains proprietary information, is attached hereto as Exhibit A,andistobe held ina separate file pursuant to14 C.F.R. § 11.35(b). iv. The DAS 800 Ground Control Station And Its Operation. The DAS 800 Ground Control Station is identical tothe GCS utilized bythe DAS UAS, which has been granted exemptions to operate commercially inthe NAS. See Exemption Nos. IIIII and 11114. A complete description ofthe operation and specifications ofthe ground control station (GCS) and flight control software forthe DAS 800is provided inthe DAS 800 Operator Manual. A complete overview ofthe features and operation ofthe GCS software isalso provided. A copy ofthe DAS 800 Operator Manual, which contains proprietary information, is attached hereto as Exhibit A,

andistobe held ina separate file pursuant to14 C.F.R. § 11.35(b).

v. Safe Mobile Operation Of The DAS 800. The DAS 800 may be safely operated bya Pilot-in-Command (PIC) and safety observer co-located withaGCS ona mobile vehicle, in order to efficiently perform aerial acquisition operations of large areas. Asset forth inthe DAS Family of Systems Operations Manual, additional limitations and requirements apply to mobile operations ofthe DAS 800, including the following: The driver/operator ofthe mobile vehicle must be licensed and fully understand his/her roleinthe operation.The mobile vehicle must be organized and clear ofany unnecessary debris prior tothe operation. Equipment and personnel positioning within the vehicle must be predetermined and agreed upon by the team. Each team member must use appropriate safety restraint equipment, and such equipment should not interfere with safe flight. The PIC must have ready communication with the driver/operator ofthe mobile vehicle, as well as

the safety observer. GCS software must be configured for constant updating ofGCS position onthe map overlay, and the

PIC must be kept aware of mobile vehicle position. The GCS must be mounted or fixed tothe mobile vehicle to ensure that no excess movement will shift the GCS during operations. 16The route ofthe mobile vehicle must be determined prior to operation. The PIC must ensure that no part ofthe route will obscure the safety observer's view or cause any physical obstacles or obstructions toany member ofthe flight team. The Area of Interest (AOI) must be large enough to warrant mobile operations, and the UA cannot be allowed toexit the AOI under any circumstance. The only change tothe standard operating procedures (SOP's) with mobile operations must bean update ofthe LOL (Loss of Link) site. Mobile operations are only permitted if suitable LOL sites are within 500ft. ofthe PICatall times. A copy ofthe DAS Family of Systems Operations Manual, which contains proprietary information, is attached hereto as Exhibit B,andistobe held ina separate file pursuant to14 C.F.R. §I I .35(b). b. Flight Operations Of The DAS 800 Are Limited To The Line Of Sight OfA Certificated Pilot in Command With A Safety Observer. DAS will only utilize certificated pilots who possess a valid airman medical certificate toactasa pilot in command (PIC) ofthe DAS 800. Additionally, a safety observer will assist all pilots. Both

the PIC and safety observer must complete the DAS Operators Course and meet the experience requirements asset forth inthe DAS Family of Systems Operations Manual. A copy ofthe DAS Family of Systems Operations Manual, which contains proprietary information, is attached hereto as Exhibit B,andistobe held ina separate file pursuant to14 C.F.R. § 11.35(b). c. Flights Of The DAS 800 Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, DAS proposes to commercially operate the DAS 800 forthe special purpose of conducting aerial acquisitions over rural areas ofthe United States, pursuant tothe following specific operating limitations: I) Operations authorized bythe grant of exemption will be limited tothe following aircraft described inthe operating documents, which isan eight-rotor, vertical takeoff and landing, unmanned aircraft weighing less than 15 pounds (maximum weight: 8.4 pounds): DAS 800.

Proposed operations ofany other aircraft will require anew petition ora petition to amend the grant.

2) The DAS 800 may notbe flown atan indicated airspeed exceeding 14.5 knots. 3)The DAS 800 must be operated atan altitude ofno more than 1,200 feet above ground level (AGL). All altitudes reported to ATC must bein feet. 4) The DAS 800 must be operated within visual line of sight (VLOS) ofthe Pilot in Command (PIC) atall times. This requires the PlCtobe able touse human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate.5)All operations must utilize a Visual Observer (YO). The YO may be used to satisfy the VLOS requirement, as long asthe PIC always maintains VLOS capability. The YO and PIC

must be able to communicate verbally atall times. The PIC must be designated before the flight and cannot transfer hisorher designation forthe duration ofthe flight. The PIC must ensure that the YO can perform the functions prescribed inthe operating documents. 6)The operating documents and the grant of exemption must be maintained and made available tothe Administrator upon request. Ifa discrepancy exists between the conditions and limitations inthe exemption and the procedures outlined inthe operating documents, the conditions and limitations inthe grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined inits operating documents. The operator may update or revise its operating documents. Itisthe operator's responsibility 17to track such revisions and present updated and revised documents tothe Administrator upon request. The operator must also present updated and revised documents if_it petitions for extension or amendment tothe grant of exemption. Ifthe operator determmes that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment toits grant of exemption. The FAA's UAS Integration

Office (AFS-80) may be contacted if questions arise regarding updates or revisions tothe operating documents. 7) Prior to each flight, the PIC must inspect the DAS 800to ensure itisina condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe DAS 800, the

DAS 800is prohibited from operating until the necessary maintenance has been performed

and the DAS 800is found tobeina condition for safe flight. The DAS 800 Ground Control Station must be included inthe preflight inspection. All maintenance and alterations must be properly documented inthe aircraft records. 8) Any DAS 800 maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement ofa flight critical component), must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry inthe DAS 800 aircraft record ofthe flight.

9)In addition tothe pre-flight inspection section inthe operating documents, the preflight inspection must also account forall discrepancies, i.e. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operating documents. I0) The operator must follow the DAS 800 manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. II) The operator must carry outits maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted inthe aircraft logbook, including total flight hours, description of work accomplished, and the signature ofthe authorized DAS 800 maintenance personnel or

PIC returning the DAS 800to service. 12) The operator's DAS 800 authorized maintenance personnel or PIC must make a record entry inthe UAS logbook or equivalent document ofthe corrective action taken against discrepancies discovered between inspections. 13) The operator's DAS 800 authorized maintenance personnel, PIC, and YO must receive and document training referenced inthe operating documents. 14) The UAS operated under the exemption must comply with all manufacturer System and Safety Bulletins. 15) The PIC must possess at leasta FAA-issued private pilot certificate anda valid FAAissued airman medical certificate. The PIC must also meet the flight review requirements specified in14C.F.R. 61.56 inan aircraft in which the PICis rated onhisorher pilot certificate.16) Prior to operating for hire, the PIC, and YO must have successfully completed DAS 's training syllabus as outlined inthe operating documents. In addition, the PIC and YO must also have successfully completed annual (recurrent) training in accordance with the operating documents. A record of training must be documented and made available upon request bythe Administrator. Training, proficiency, and experience-building flights forthe purpose of training pilots and YOs to conduct flights authorized bythe exemption are permitted under the terms ofthe exemption. 17)Ifthe DAS 800 loses communications or loses its GPS signal, it must return toapredetermined location within the planned operating area and land, orbe recovered in accordance with the operating documents. 1818) The PIC must abort the flight inthe event of unpredicted obstacles or emergencies in accordance with the operating documents. 19) The operator must obtain anAir Traffic Organization (A TO) issued Certificate of_ Waiver

or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior tothe operation.

20) The DAS 800 operated in accordance with the exemption must be identified by serial 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. 21) Before conducting flight operations, the radio frequency spectrum used for operation and control ofthe DAS 800 must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 22) The documents required under 14 C.F.R §§ 91.9 and 91.203 must be available tothe PIC

atthe Ground Control Station ofthe DAS 8000 any time the aircraft is operating. These documents must be made available tothe Administrator, orany law enforcement official, upon request.

23) The DAS 800 must remain clear and yield the right of waytoall other aircraft operations and activities atall times. 24)Ifthe DAS 800is operated froma moving device or vehicle, the operation must bein accordance with the operating documents. 25) DAS 800 operations may notbe conducted during night, as defined in14C.F.R.§1.1. 26) All operations must be conducted under visual meteorological conditions (VMC). The DAS 800 may notbe operated less than 500 feet below orless than 2,000 feet horizontally froma cloud or when visibility isless than3 statute miles from the PIC.

27) During operations inthe National Airspace System, the UA may not operate within 5 nautical miles ofthe geographic center ofan airport as denoted ona current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance witha NOT AM as required bythe operator's COA. The letter of agreement with the airport management must be made available tothe Administrator upon request. 28) The DAS 800 may notbe operated over congested or densely populated areas. These areas include, but are not limited, tothe yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, itisthe PIC's responsibility to maintain the minimum safe altitudes required by14 C.F.R. § 91.119. 29) Operation ofthe DAS 800 must be conducted at least 500 feet from all persons, vessels, vehicles, and structures not directly involved inthe operation. 30) Operations ofthe UA may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with the special purpose operations. Operations closer than 500 feet from the30 PIC, VO, operator trainees and essential persons, are permitted when operationally necessary; but never so close asto present an undue hazard, per14 C.F.R. § 91.119(a). 31) Operations ofthe UA may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned bythe land owner/controller when the land owner/controller grants such permission and the PIC makes a safety assessment ofthe risk from operations closer to these objects.

32) All operations shall be conducted with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight tobe conducted. 1933) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA must be reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents meeting the requirements of49 C.F.R. Part 830 must be reported tothe National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. DAS submits that an equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DAS 800 unless that PIC has demonstrated, through the DAS 800 training and currency requirements, that the PICisable to safely operate the DAS 800ina manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering DAS 's proposed area of operations and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. II 062); and the airmanship skills necessary to safely operate the DAS 800, DAS submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate tothe airmanship skills necessary for DAS 's specific proposed flight operations. Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, inall material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). Asin Exemption No. Ill 09, DAS will not allow any PICto operate the DAS 800 unless that PIC has demonstrated through the DAS 800 training and currency requirements that the PICisable to safely operate the DAS 800ina manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. A complete description ofthe DAS 800 Training and Qualification requirements isset forth inthe DAS Family of Systems Operations Manual, attached hereto as Exhibit B. Exhibit B contains proprietary information andistobe held ina separate file pursuant to14C.F .R.§I 1.35(b ). 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The level of safety established by Section 91. 7(a) will be maintained because prior to every flight, DAS will ensure that the DAS 800isinan airworthy condition and safe for flight based upon the DAS 800's compliance with its operating documents (i.e., the DAS 800 Operator Manual, the DAS Family of Systems Operations Manual, and the DAS 800 Maintenance Manual) andas stated inthe conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a), specific to UAS, in circumstances similar, inall material respects, to those presented herein (e.g. Exemption Nos. II 062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. 20The equivalent level of safety established by Section 91.121 will be maintained because the DAS 800 is equipped witha digitally encoded barometric altimeter and GPS triangulation equipment, witha zero altitude initiation point being established prior to each flight. As such, the PIC onthe DAS 800 is provided the altitude ofthe UA above ground level (AGL) viaa heads-up display ofthe ground control station (GCS). Specifically, the PIC ofthe DAS 800is provided three different types of altitude information:(I) Desired Altitude, indicating the commanded altitude, located atthe top right corner of HUD as well as above the HUD; (2) Altitude Above Ground Level (AGL), indicating actual altitude relative to height above launch level onthe ground, located inthe center ofthe right side ofthe HUD; and (3) Climb Rate, indicating the current rate of climb, located inthe center ofthe right side ofthe HUD. Accordingly, the PIC ofthe DAS 800 will be provided

with all ofthe necessary altitude information necessary to maintain safe operation ofthe UA inthe NAS. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, inall material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11.065, 11066, 11067, 11080, 11109, 11112, 11136, 11138). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure the equivalent level of safety established by14 C.F.R. Section 91.151 (b) because the technical specifications ofthe DAS 800, the DAS Operations Manual, and DAS 's proposed operating limitations will ensure that DAS may safely operate the battery powered DAS 800 during daylight hours in VFR conditions foratotal flight duration of15 minutes, which will ensure a landing with three minutes (i.e., 20 percent) battery power remaining. Furthermore, previous exemptions granted bythe FAA concerning Section 91.151 (b) establish that safety isnot adversely affected when the technical characteristics and operating limitations ofa UAS are considered.The DAS 800is powered by one Lithium Ion11 Amp hour, 16.8V batteries, andis protected by two low battery failsafes. The ground control station (GCS) provides a battery indicator onthe heads-up display, which indicates the DAS 800's current remaining battery power measured in volts, and thus provides the PIC with constant awareness ofthe real-time battery voltage during a flight. The two low battery failsafes that protect the DAS 800 area "Low AY2 battery" failsafe anda "Critically lowAV battery" failsafe. The "Low A V battery" failsafe flies the UAtothe location of the ground control station (GCS), or identified Rally point, when the UA batteries reach a certain threshold of time as configured bythe operator, or 16.8V. The "Critically lowAV battery" failsafe lands the UAatits current location. This failsafe is triggered ifa battery drops below the critical battery voltage as configured bythe operator, or 14.2V. The DAS 800 Operator Manual defines "AV"as "Aerial Vehicle." Furthermore, an exemption from the requirements of Section 91.151 (b) would not adversely affect safety because DAS will only conduct flights during daylight hours in VMC, with the duration of

each flight notto exceed 15 minutes, with three minutes (i.e., 20 percent) battery power remaining. Likewise, asset forth above, DAS has proposed specific operating limitations inthis Petition that will maintain the equivalent level of safety established by Section 91.151 (b), including the following: (I)the DAS 800 will only be operated during daylight hours (i.e. between the end of morning civil twilight and the beginning of evening civil twilight, as published inthe American Air21Almanac, converted to local time); (2) DAS 800 will only be operated pursuant to visual flight rules (VFR) in visual meteorological conditions (VMC); and (3)the duration of each flight shall not exceed 15 minutes. Significantly, previous exemptions granted bythe FAA concerning Section 91.151 establish that safety isnot adversely affected when the technical characteristics and operating limitations ofthe

UAS are considered. Relief has been granted for manned aircraft to operate atless than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, andI 0650. Moreover, the FAA has previously granted relief from Section 91.151, specific to UAS in circumstances similar, inall 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).6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) &(b) Would Not Adversely Affect Safety. In seeking this exemption, DAS submits that an equivalent level of safety with regard tothe regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)( I), 91.409(a)(l) & (a)(2), and 91.417(a) &(b) will be met because DAS, the manufacturer ofthe DAS 800, will useits trained technicians to perform maintenance, alterations, or preventive maintenance

onthe unmanned·aircraft system using the methods, techniques, and practices prescribed inthe manufacturer's maintenance manual. Furthermore, DAS will document and maintain all maintenance records forthe DAS 800.

Since the DAS 800 will be inspected as prescribed bythe manufacturer's maintenance manual, DAS

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)( I),and 91.409(a)(2). The DAS 800 Maintenance Manual sets forth Scheduled Maintenance Inspection

Procedures for each system and component. Inspection intervals forthe DAS 800 include preflight and post flight inspections, as well as scheduled inspections every 25 hours, 50 hours, 75 hours, and I00 hours of operation. Likewise, the exemption sought will not adversely affect safety because DAS will perform maintenance, alterations or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed bythe manufacturer's maintenance manual. The DAS 800 Maintenance Manual details procedures for each component ofthe UA, including the components ofthe propulsion system, legs/arms, avionics system, and payload system. A copy ofthe DAS 800 Maintenance Manual, which contains proprietary information, is attached hereto as Exhibit C,andistobe held ina separate file pursuant to14C.F.R.§ 11.35(b ). Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b) because all maintenance ofthe DAS 800 will be performed by DAS trained technicians, who will document and maintain maintenance records forthe DAS 800. DAS trained technicians are qualified to conduct any and all maintenance to ensure the safe operation ofthe DAS family of UAS, conduct all service inspections, and authorize the useof each vehicle in the DAS family ofUAS based upon completion of appropriate inspections. See DAS Family of Systems Operations Manual, Exhibit B,at page 3-4. Pursuant tothe DAS Family of Systems Operations Manual and the DAS 800 Maintenance Manual, a Maintenance Action Form must be completed and saved inthe maintenance logs forall maintenance thatis performed onthe UAS. The procedures for maintaining the maintenance logs forthe UAS are fully set forth inthe DAS Family of Systems Operations Manual, Exhibit B,and the DAS 800 Maintenance Manual, Exhibit C. 22< Significantly, previous exemptions granted bythe FAA concerning Sections 91.405(a), 91.407(a)( 1), 91.409(a)(l) & (a)(2), 91.417(a) &(b) establish that safety isnot adversely affected when the technical characteristics and operating limitations ofa UAS are considered. The FAA has previously

granted relief specific to UAS in circumstances similar, inall material respects, to those presented

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). 7.The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R.§ 21.16 entitled Special Conditions, DAS requests that the FAA prescribe special conditions forthe intended operation ofthe DAS 800, which contain such safety standards that the Administrator finds necessary to establish alevel of safety equivalent tothat established by14C.F.R. Part 21, Subpart H,and 14C.F.R§§ 61.113(a) &(b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)( I), 91.409(a)( 1)& (a)(2), and 91.417(a) &(b). Such special conditions will permit safe

operation ofthe UA forthe limited purpose of conducting aerial acquisitions over certain rural areas ofthe United States. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise posea 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 inthe NAS. Likewise, the Administrator may prescribe special conditions pursuant to14 C.F.R. § 21.16, for operation ofthe DAS 800, since the airworthiness regulations of14 C.F.R. Part21donot contain adequate or appropriate safety standards, duetothe novel or unusual design features ofthe aircraft.

Section 21.16, entitled Special Conditions, states the following:

lfthe FAA finds that the airworthiness regulations ofthis subchapter donot contain adequate or appropriate safety standards foran aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto forthe product. The special conditions are issued in accordance with Part IIof this chapter and contain such safety standards forthe aircraft, aircraft engine or propeller asthe FAA finds necessary to establish alevel of safety equivalent tothat established inthe regulations.

See14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14C.F.R.§ 21.16, the FAA may prescribe special conditions for DAS 's intended operation ofthe DAS 800, which contain such safety standards that the Administrator finds necessary to establish alevel of safety equivalent tothat established by14 C.F.R. Part 21, Subpart H,and 14 C.F.R Sections 61.113(a) &(b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)( I), 91.409(a)( I)& (a)(2), and 91.417(a) &(b). F.A Summary That Can Be Published In The Federal Register, stating: The Rules From Which DAS Seeks Exemption: DAS, Inc. seeks exemption from the requirements of14 C.F.R Sections 61.113(a) &(b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).A Brief Description OfThe Nature OfThe Exemption DAS Seeks: 23**~** This exemption will permit DAS, Inc.to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions and research over certain rural areas ofthe United States. G. Any Additional Information, Views, Or Arguments Available To Support DAS 's Request. This Petition is made pursuant tothe FAA Modernization and Reform Act of20 12 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in

the NAS. As such, DAS 's request for exemption may be granted pursuant tothe authority of FMRA Section 333 and14C.F.R. Part II,asset forth above. FMRA Section 333 sets forth the requirements for considering whether aUAS will create a hazard to

users ofthe NAS orthe public, or otherwise posea threat to national security; and further, provides

the authority for such UAS to operate without airworthiness certification. As discussed in detail above, DAS will operate the DAS 800 safely inthe NAS without creating a hazard to users ofthe NAS, orthe public, or otherwise posea threat to national security. CONCLUSIONAsset forth herein, DAS seeks an exemption pursuant to14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DAS.

800 commercially, without an airworthiness certificate, forthe limited purpose of conducting aerial acquisitions over certain rural areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing DAS to safely, efficiently, and economically operate the DAS 800 commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of20 12, Section 333, DAS respectfully requests that the Administrator grant this Petition foran exemption from the requirements of14 C.F.R Sections 61.113(a) &(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) &(b), and permit DAS to operate the DAS 800 forthe purpose of conducting aerial acquisitions and research over certain rural areas ofthe United States. Dated: October 9, 2015 Respectfully submitted, Detailed Aerial Solutions, LLC Is/ Nickolas C. Houghton & Michael A. Klumpp Michael Alan Klumpp and Nickolas C. Houghton Detailed Aerial Solutions, LLC 1955 E Walton Rd. Shepherd, Ml 48883 Tel: (989) 312-3556) Email: mike@detailedaerialsolutions.com and nick@detailedaerialsolutions.com 24