03/25/2015

Aerial Impact Southeast, Inc.

414 Yellow River Walk Lawrenceville, Ga 30043 (407)782-8578

Dave Cullens

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the Reform Act), Aerial Impact Southeast (applicant), planned opera tor of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photograp hy and survey for various industries hereby applies for exemptions to severa l Federal Aviation Regulations (FARs) to allow commercial operation of their sUAS, so long as such operations are

conducted within and under the conditions outlined herein or as may be established by the FAA. We ask that the Secretary of Transportatio n consider whether the applicants' systems may operate safely in the national airspace system (NAS) before finalization of the sUAS rulemaking required under Section 332 of t he Reform Act. In making this determination, we ask the Secretary to consider the following:

• The UAS’s size, weight, speed, limited flight dur ations and operational capability • Operation of the UAS below 200' agl • Operation of the UAS within visual line of sight of the operator at all times. • PIC is a FAA Certified Commercial Pilot (#2155023 28) with current 2nd class medical • Operations will be limited to the areas being fil med as outlined in Flight Ops manual

Regulations from which the exemption is requested:

14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)

14 C.F. R. 91.119

14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b)

14 CFR 91.215 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a)(1) & (2) 14 CFR 417 (a) & (b)14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 C.F.R. §91.203 (a) (1)

Relief not necessary (reference Exemption No. 11195 )

14 C.F.R. § 45.23 (b). Marking of the Aircraft

Relief not necessary (reference Exemption No. 11195 )

14 C.F.R. §91.7(a) & (b): Civil aircraft airworthin ess.

Petitioner's Preflight Checklists will satisfy the airworthiness requirement. Pre-flight checks will be performed prior to each flight. The PIC will determine if the aircraft is suitable for safe flight. See attached flight opera tion manual.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Man ual in the Aircraft.

the FAA has previously determined in Grant of Exemp tion 11062, that relief from these sections is not necessary. Relevant materials may b e kept in a location accessible to the PIC in compliance with the regulations.

14 C.F.R. §91.109: Flight instruction :

Relief not necessary (reference Exemption No. 11195 )

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with a ny route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitude s up to 200 AGL, an exemption may be needed to allow such operations. As set forth he rein, the UAS will never operate at higher than 200 AGL. It will be operated in a restr icted area, where buildings and people will not be exposed to operations without their pre -obtained consent. See petitioner's flight operations manual(s) for proposed operationa l boundaries.

14 C.F.R. §91.121 Altimeter Settings

Applicant requests exemption to allow a GPS referen ced altitude be used in lieu of a pressure based altimeter. Considering the low altit udes the proposed operations will be taking place, the GPS altitude information will be at least as accurate as the mechanical pressure altimeters used in full scale aircraft. Al titude information AGL (from takeoff point) will be displayed to the pilot & observer at all times during the flight with On Screen Display telemetry information overlaid on a live video feed from the aircraft.14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Due to the very close operational distances and lim ited flight times that the proposed operations will take place, landing with 30 minutes reserve fuel is not a reasonable requirement. Applicant submits that flight times wi ll be limited to 20 minutes or when battery capacity reaches 20%, whichever comes first . Aircraft will never be flown more than 1 minute away from the takeoff/ landing site.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircr aft Certification and Registration

Relief not necessary (reference Exemption No. 11195 )

14 C.F.R. §91.215 ATC transponder & altitude report ing equipment & use

As applicant's aircraft will not be transponder equ ipped, we submit that the associated COA will satisfy this requirement and afford a leve l of safety at least equivalent to what is afforded by the FAR.

Summary of proposed operations

• The sUAS will weigh less than 30 lbs.

• Maximum speed will be no more than 50 kts.

• Flights will be operated within line of sight of P ilot and Observer.

• Flights will only be conducted under Day Visual Me teorological Conditions.

• Maximum total flight time for each operational fli ght will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

• Flights will be operated at an altitude of no more than 200 feet AGL.

• Minimum crew for each operation will consist of th e sUAS Pilot and Visual Observer.

• sUAS Pilot will be an FAA licensed airman with a C ommercial Pilot certificate and 2nd

class medical.

• sUAS Pilot will be Pilot in Command (PIC).

• The UAS will only be operated within the confines of the property being filmed/photographed.

• A briefing will be conducted in regard to the plan ned sUAS operations prior to each flight.

• Pilot and observer have been trained in operation of UAS generally and receive up-todate information on the particular UAS to be operat ed

• Observer and Pilot will at all times be able to co mmunicate by voice.

• Written and/or oral permission from the relevant p roperty holders will be obtained.

• If the sUAS loses communications or loses its GPS signal, the UAS has capability to return to a pre-determined location and land.

• The PIC will have the ability to abort a flight at any time.The applicants' sUAS are multirotor craft, weightin g 30 or fewer lbs. including payload.

They operate, under normal conditions at a speed of no more than 50 knots and are able to hover, and move in the vertical and horizon tal plane simultaneously by remote control. They will operate only within line of sigh t and will operate only within the confines as described in the operators' procedural manual. Given the small size of the

sUASs involved and the restricted areas within whic h they will operate, the applicant feels that its' operations will afford an equivalen t or higher level of safety which the FAR's afford manned aircraft operations performing similar operations. Due to the size of the sUAS's applicant plans on using and the area s in which they will operate, applicants' operations will present no national sec urity issue. As a Commercial Pilot, with 3000+ total flight hours, performing Aerial Ph otography using full scale Cessna aircraft for 16+ years and over 2500 hours, applica nt feels strongly that its' operations will not be in conflict with manned aircraft operat ions as most of the proposed work will take place at altitudes below 100' agl, with no ope rations above 200' agl. This operation

would in fact be an add-on service to the manned ai rcraft operation to get shots that would not be possible with manned aircraft, without compromising safety. In addition to the strong level of safety surrounding the proposed operations, there are also significant public benefits, including enhanced saf ety and reduction in environmental impacts, including reduced emissions and noise when compared to manned aircraft operations. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption.

Sincerely,

e-sign David W. Cullens

David W. Cullens, President/Owner
Aerial Impact Southeast, Incorporated

Attachments:

• Aerial Impact Flight Operations manual