1 May 1 4 , 2015

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

RE: Petition of Pinnacle Unmanned Aerial Systems , LLC, for Exemption Pursuant to

Section 333 of the FAA Modernization and Reform Act of 2012.

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

Pinnacle Unmann ed Aerial Systems, LLC , (hereinafter referred to as “Pinnacle”) hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small

- unmanned aerial system ( sUAS).

Th e exemption is based up on information outline d in this document

, Pinnacle’s enclosed Operations Manual, the DJI and Sensefly UAS manufacturer s man ual s and guides , and any other requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation s by Pi nnacle, which will use the DJI

Phantom 3

, DJI Inspire 1, and Sensefly eBee to conduct sUAS flight training, education, general photography and videography

, real estate photography and videography, film and movie production, wildlife surveys, pipeline patrols, infrastructure and industrial inspections, news gathering, agricultural surveys, d emons tration flights , and any other related entities /activities that can utilize the safe and efficient operation of sUAS aircraft . Pinnacle ’s operation under the exemption will be subject to strict operating requirements and conditions to ensure a level of

saf ety equivalent to that of currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.

Pinnacle will operate under controlled visual flight rules ( VFR ) conditions at low altitude in

ai rspace that is permitted in accordance with the approved Certificate of Authorization (COA). Pinnacle will operate the sUAS s with pilots who possess a n FAA Pilot Certificate and have met Pinnacle’s pilot requirements as detailed in the provided Operations Manual

. Finally, the FAA Air Traffic Control ( ATC ) will approve in advance the airspace in which the sUAS will operate.

Pinnacle respectfully submits this request for an exemption due to its operation of sUASs. In its

current form , the operations Pinnac le will be conducting replace comparatively hazardous operations now conducted with both fixed and rotary winged aircraft . The FAA can have

confidence that Pinnacle’s operations will be conducted at an equivalent level or greater level of safety than that of sUASs counterparts of larger manned aircraft . Approval of this exemption2 would therefore enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish require ments for the safe operation of such aircraft systems in the national airspace system.”

For your convenience, Pinnacle has organized this Exemption request as follows:

I. Petitioner's Description

................................ ................................ ................................ ................................ ..... 2

I I. Relevant Statutory Authority

................................ ................................ ................................ .......................... 3

III. Qualifications for Approval Under Section 333 of the Reform Act

................................ .................. 4

IV. Description of Proposed Operations

................................ ................................ ................................ ............. 5

V. Regulations From Which Exemption is Requested

................................ ................................ ................. 6

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in

Command

................................ ................................ ................................ ................................ ................................ . 6

B. 14 CFR § 91.103: Preflight Action

................................ ................................ ................................ ......... 7

C. 14 CFR 91.109(a): Flight Instruction

................................ ................................ ................................ .... 8

D. 14 CFR 91.113: Right

- of

- Way Rules

................................ ................................ ................................ .... 8

E. 14 CFR. § 91.119: Minimum Safe Altitudes

................................ ................................ ....................... 9

F. 14 C.F.R. § 91.121: Altimeter Setti ngs

................................ ................................ .............................. 10

G. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

................................ .... 10

H. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

................................ ................................ ................................ ................................ ............................ 11

VI. Public Interest

................................ ................................ ................................ ................................ .................... 11

VII. Privacy

................................ ................................ ................................ ................................ .......................... 13

VIII. Federal Registry Summary

................................ ................................ ................................ .................... 13

IX. Conclusion

................................ ................................ ................................ ................................ .......................... 13



### I. Petitioner's Description

Pinnacle Unmanned Aerial Systems , LLC, is headquartered in Fort Worth, Texas . Their core competencies are providing services of sUAS in flight training, education, general photography and videography, real estate photography and videography, film and movie product ion, wildlife surveys, pipeline patrols, infrastructure and industrial inspections, news gathering, agricultural surveys, and demonstration flights in a compliant and safe environment. Pinnacle plans on providing a wide range of services as the sUAS market expands.3 The executive management at P innacle has over 15 years experience in aviation and more than

five years experience working with unmanned aerial systems. The President of the company has

worked both military and civili an manned and unmanned aircraf t supporting maintenance and flight operations. The Vice President has over five years experience managing large

- scale projects and developing processes to make business operations safe and efficient. The Chief Pilot possesses a Private Pilot Rotorcraft ( Helicopter) certificate . He has flown piston and turbine powered aircraft without incident in controlled and uncontrolled airspa ce for more than 8 years.

That time and exp erience has provided the knowledge and tools necessary to ensure safe operations wit hin the National Airspace System (NAS).

Pinnacle’s goal is to operate in an accident

- free environment by:

• Ensuring all employees are trained on the latest safety procedures for the sUAS they operate as well as Pinnacle’s safety procedures outlined in the Operations Manual.

• Being proactive when performing pre

- flight operations and identifying any potential safety hazards

• Demonstrating the ability to identify and appropriately eliminate hazards and risks to the aircraft as well as persons involved in the fli ght.

The contact information for Petitioner is as follows:

Pinnacle Unmanned Aerial Systems , LLC

500 Throckmorton Street #3007 Fort Worth, Texas 76102

Member Managers:

Cody Shehane

Cell: 817

- 888

- 0723

Katherine Shehane

Cell: 817

- 889

- 7413



### II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national a irspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate sa fely in the National Airspace (NAS ) before completion of the formal UAS rulemaking, based on the follow ing considerations:

• The weight, speed, and operational capability of the UASs4 • Operating the UAS in a relatively close proximity to airports or other populated areas

• UAS will be in direct visual line

- of

- sight with the observer and pilot

If the Secretary det ermines 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".

Additionally, the FAA Administrator has general authority t o grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its term s, includes exempting civil aircraft, as the term is defined in 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections.



### III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in thi s petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The prop osed operations would permit Pinnacle the use of s UAS under controlled

conditions in airspace that is: (1) predetermined; (2) exercises controlled access ; and that (3) provides an increased level of safety beyond existing comparable operations when fixed or rotary wing ed aircraft are used.

P innacle uses s UASs that are multi

- rotor, weigh ing less than 25 pounds including payload. They operate, under normal conditions, at speeds not to exceed 45 mph . They have the capability to

hover in a location and move in the vertical and horizontal plane. Pi nnacle’s s UASs will operate

in line

- of

- sight, under VFR flight conditions, and within the guidelines of a sterile environment which is outlined in the enclosed Operations Manual. P innacle will operate at or below 500 feet Above Ground Level ( AGL ) and will file a Notice to Airmen ( NOTAM ) for each flig ht operated in controlled airspace. 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 prior to operating a sUAS. G i ven the small size of the UAS s involved

and the restricted sterile environment that they will operate in , this exemption falls within the zone of safety and demonstrate s an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion of formal5 rulemaking. Al so, due to the aforementioned conditions , approval of the application presents no

hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority cont ained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest.



### IV. Description of Proposed Operations

The enclos ed Operations Manual describes the policies and procedures for Pinnacle ’s proposed sUAS operations. To assist the FAA in its safety assessment said proposal , below is a summary of operational limitations and conditions that will ensure an equival ent or higher level of safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Pinnacle Unmanned Aerial Systems will designate a Pilot in Command (PIC) for each

mission.

3. Flights will be operated within l ine

- of

- sight of the PIC and observer.

4. Maximum total flight time for each operational flight will be limited to the amount of

time the sUAS can be flown and still maintain a reserve battery power of no less than

20 %.

5. Flights will be operated at an altitude of no more than 500 feet AGL.

6. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation

. 7. Minimum crew for each operation will consist of the sUAS PIC and a Visual

Observer.

8. The sUAS PIC will be an FAA licensed airman with at least a private pilot's certificate, third class medical, and a current check required by14 CFR Part 61.56 in

an airc raft in which the PIC is rated on his or her pilot certificate.

9. The sUAS will operate only within a confined "Sterile Area" as defined in the Operations Manual.

10. A site inspection will be conducted p rior to the operations at a particular location. On

the da y of the mission

, the management person with operational control and the PIC will concur on dispatching of the mission.

11. In accordance with Operations Manual

, a briefing will be conducted regarding the planned sUAS operations prior to each mission . It is ma ndatory that all personnel who will be performing duties within the boundaries of the sterile area be present for this briefing.

12. Pinnacle’s crew will use the checklist and callouts required in the Operations Manual.

13. All sUAS s will be maintained in accordan ce with inspection program specified in t he

Pinnacle’s Operations Manual and in compliance with the manufacturer’s guidelines.6 14. In the event of an accident involvi ng Pinnacle ’ s sUAS, that mission’s operations will

cease and the accident reported to the NTSB and AFS

- 80.

15. PIC and Visual Observer will at all times be able to communicate by voice.

16. PIC

, Visual Observer, and any additional required operational p ersonnel will possess the required minimum skills and education outlined in Pinnacle Unmanned Aerial Syst em’s Operations Manual.

17. 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.

18. If the sUAS loses communications signal, the sUAS will have the capability to return

and land at a pre

- determined l ocation within the Sterile Area.

19. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the observer.

20. The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.

21. Pinnacle Unmanned Aerial Systems , by following procedures listed in the Operations

Manual

, will assure no individuals’ privacy is violated.

22. I n accordance with Pinnacle’s Operatio ns Manual , the PIC will c ontact the Air Traffic Control (ATC) facility or appropriate airspace controlling authority prior to operating in airspace other than Class G.



### V. Regulations F rom Which Exemption is R equested

A. 14 CFR § Part 61.113 (a) and (b) Private P ilot Privileges and Limitations; Pilot in

Command

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR § 91.109(a): Flight Instruction

D. 14 CFR § 91.113: Right

- of

- Way Rules

E. 14 CFR § 91.119 (c): Minimum Safe Altitudes

F. 14 CFR § 91.121: Altimeter Settings

G. 14 CFR § 91.151(b ): Fuel Requirements for Flight in VFR Conditions

H. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections



### A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations;

Pilot in Command

Section 61.113 (a) & (b ) limit private pilots to non

- commercial operations . C onventional

aircraft carry a pilot, passengers, and cargo during their operations. Having this rule in place ensures the skill and competency of the pilots. However, the DJI and Sensefly sUAS s are

contr olled remotely and do not carry any passengers or cargo . Pinnacle Unmanned Aerial Systems respectfully proposes that the FAA take into account the characteristics and procedures of the pa rticular UAS in reference to requirements for PIC . Pinnacle Unmanned7 Aerial Systems proposes that the ir operation s of the DJI and Sensefly sUAS in commercial

use not require the P ilot to hold a commercial pilot certificate but rather a private pilot

certificate. Pinnacle Unmanned Aerial Systems proposes the following requir ements for a

PIC :

1. The PIC must possess a Private Pilot’s Certificate and a valid third

- class medical

certificate.

2. The PIC must have accumulated and logge d a minimum of 200 flights and 25 hours of total time as a UAS pilot and at least ten hours logged as a UAS pilot with a similar UAS type (fixed wing or multi

- rotor) and five hours in type of UAS aircraft he/she will operate (DJI or Sensefly models )

. 3. The PIC must have accumulated and logged a minimum of five hours as UAS pilot

with the make and model of UAS to be utilized for operations under the exemption and three takeoffs and landings all within the preceding 90 days.

4. The PIC must successfully display the competencies as specified in the Pinnacle Unmanned Aerial Systems Operations Manual

. 5. The PIC must al so meet the flight review requirements specified in 14 CFR Part 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

Equivalent Level of Safety

Pinnacle Unmanned Aerial Systems utilizes both a PIC and a Visual Observer to increas e safety during flight operations. While the PIC is concentrating on flying the UAS

, the

Visual Observer has the ability oversee safety of the entire operation . The Visual

Observer will always remain within 10 feet of the PIC when the UAS is airborne to

qu ickly communicate any observations if an emergency should happen. Procedures developed by Pinnacle far exceed the current safety requirements esta blished by the

FAA. Pinnacle respectfully requests the option to use a PIC and Visual Observer crew and the se cond crewmember not having to possess a private pilot certificate.



### B. 14 CFR § 91.103: Preflight Action

Pinnacle requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may oper ate:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, altern atives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following8 takeoff and landing distance i nformation:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those spe cified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Equivalent L evel of Safety

Pinnac le will only operate under VFR conditions within line of sight of its designated takeoff and landing zones. Located in Pinnacle’s Operations Manual are procedures describing steps the PIC and additional personnel must follow to assur e that the weather will be adequate to complete the mis sion under VFR condition s

. In addition, the PIC will adhere to all manufacture required preflight checks of the aircraft, review aircraft performance data, and

become familiarized with their sterilized area of operations prior to conducting any flights.



### C. 14 CFR 91.109(a): Flight Instruction

Pinnacle requests an exemption from 14 CFR 91.109(a) Flight Instruction

, in which “no person may operate a civil aircraft (except a manned free balloon) that is bein g used for flight instruction unless that aircraft has fully functioning dual controls”. Small

- unmanned aerial
systems by design allow only a single remote to control the aircraft during flight. Should control need to be passed from one pil ot to another d uring sUAS flight instruction , it would take place by p hysically handi ng off the remote control

. Pinnacle respectfully requests to conduct flight instruction with the use of a single handheld remote control.

Equivalent Level of Safety

Unlike manned airc raft that are used for pilot instruction, sUAS have an added level of safety due to their size, weight, and speed while not having to carry fuel or passengers. The flight of a sUAS will only take place within the confines of a sterilized area of operation . During times of flight training, the sterilized area will contain no personnel other than the instructor pilot and student who will remain vigilant and side

- by

- side during all portions of flight. The sterilized area will be open and free of buildings o r obstacles that could present hazards during times of instruction. Should the student begin to lose control, the instructor will be

within reach to promptly take the remote control and right the aircraft. For an additional measure of safety, e ach aircra ft Pinnacle operates for flight instruction possesses a RTH (Return To Home) fu nction that, when commanded, will instruct the aircraft to safely return to its takeoff point and land under its own control.9 

### D. 14 CFR 91.113: Right

- of

- Way Rules

Pinnacle reques t s an exemption from 14 CFR 91.11 3 Right

- of

- W ay rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way, the pilot shall give way to that air craft and may not pass over, under, or ahead of it unless well clear. Pinnacle operates pilotless s UASs and cannot comply with these rules as they have been written.

Equivalent Level of Safety

Pinnacle Unmanned Aerial Systems operates sUA S s at or below a n altitude of 500 feet AGL ; well below the normal operating altitude of other, larger aircraft. Pinnacle ’s Operations Manual specifies that a PIC with experience will oversee each mission and has knowledge of

the see

- and

- avoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the operations area. It i s the responsibility of the PIC to cease operations and land the s UAS immediately whene ver an aircraft comes into the vicinity creating a potential threat. Operations cannot resume u ntil the threat is clear.



### E. 14 CFR. § 91.119: Minimum Safe Altitudes

Pinnacle requests an exemption from the minimum safe altitude requirements of 14 CFR

91.119 that details the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the s urface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." With Pinnacle’s intend ed operations, the s UAS is normally operated at or below 500 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, a nd from people not associated with the operation.

Equivalent Level of Safety

Compared to the flight of normal aircraft, Pinnacle ’ s sUAS aircraft weigh less than 2 5 pounds, and

, given the lack of flammable fuel, pose far less risk to persons or property tha n with conventional aircraft . An equivalent level of safety will be achieved given the size,10 weight, and speed of the s UAS, as well as the location where it is operated. As set forth in the Operations Manual, the sUAS will be operated in a sterile area, wh ere buildings and people

will not be exposed to operations without their pre

- obtained consent. Because of the advance notice to the property owners and participants, all knowingly affected individuals will be well aware of the planned flight operations as set forth in the Operations Manual. Furthermore, by

o perating at low altitudes , the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the sUAS that Pinnacle operates has safeguards

built into its desi gn that warn s pilots when approach ing areas designated by the manufacture as “no fly zones” . This cause s the sUAS to initiate a descent to safe altitude or landing.



### F. 14 C.F.R. § 91.121: Altimeter Settings

Pinnacle is seeking an exemption from 14 CFR 91.12 1, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required

because the sUAS s have GPS al titude readouts as opposed to barometric altimeter s

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in

Pinnacle’s Operations Manual during the pre

- flight routine . Prior to operations, Pinnacle will

confirm the altitude of the launch site shown on t he GPS altitude indicator . Moreover, the

PIC will use the GPS altitude indicator to constantly monitor the sUASs height, thus ensuring operation at safe altitudes.



### G. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

Pinnacle requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

–

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering Pinnacle’s sUASs provide approximately 18 minutes of powered flight for the DJI airframes and approximately 30 minutes of powered flight for Sensefly’s

airframe . To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS fligh ts could

not be conducted. Gi ven the limitations on the sUAS s proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve11 amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on

site without significant transit time by the sUAS. All flights will be planned to terminate with

no less than 20 % reserve battery power still available. This restrictio n would be more than adequate to safely return the sUAS to its planned landing zone from anywhere in the area of operation

. The fuel requirement guidelines of Section 91.151(a) were intended to alleviate risks for large r manned aircraft that could operate great distances from suitable landing areas

. Due to the limited distance the sUASs can fly, the small size of the operations area, and all operations being conducted within visual line

- of

- site, the sUAS s maintain the ability to quickly return to their poi nt

- of

- origin when necessary.



### H. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b) : Maintenance Inspections

Pinnacle is seeking an exemption from the maintenance inspection requirements contained in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2 ), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a)

states that each owner or operator of an ai rcraft "shall have the aircraft inspected as prescribed in subpart E of this pa rt and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"

. Part 43 and these sections only apply to aircraft with an airworthiness certificate; therefore an exemption to these regulations is needed, as the sUASs Pinnacle operates will not posses an airworthiness

certificate.

Equivalent Level of Safety

M aintenance and inspections will be perf ormed in accordance with the enclosed Pinnacle Operations Manual and the sUASs User’s Manuals , therefore ensuring an equivalent level of safety

. As provided in the Operations Manual, Pinnacle will perform required maintenance, keep a log of any maintenance performed, and the operator will confirm that the sUAS is in working o rder prior to initiating flight . The operat or is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Due to the sUAS s size and carrying capacity, and the fact that flight operations will only take p lace in restricted areas fo r limited periods of time

, if a

mechanical issue arises it creates less risk than that associated with conventional aircraft performing the same operation.



### VI. Public Interest

Public interest is furthered with granting Pinnacle’s exe mption request

. Congress’s n ational12 policy favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose d in this petition. Pinnacle’s goals are to help facilitate and promote the safe integration of sUASs into the NAS, while providing education and awareness of sUAS operations and capabilities. The following is not an exhaustive list of areas of interest:

• Movies and Videography

Small

- unmanned aerial systems provide unparalleled capability in thei r ability to quickly adapt to any situation. Unlike traditional filming methods that can require excessive amounts of time to change camera angles for different views , sUASs are light, stabilized platforms that can quickly maneuver through the air into po sition for capturing every angle in high definition video

.

• Newsg athering

Helicopters have been utilized in n ews gathering for many years

. They have provided the ability to easily maneuver into positions that allow for multiple viewing angles of a

scene. H owever, the t echnology has now progressed to allow for much smaller, cost

effective sUAS ai rcraft to capture breaking news with much less risk to person s or property

. Since sUAS are dramatically smaller in size and weight in comparison to manned aircraft, carry no fuel, and operate within steriliz ed areas, they provide an increased margin of safety that is unrivaled

.

• Real Estate

R eal estate is an area that sUAS platforms have grown in popularity. Whether the real estate professional is listing commercial or residential properties, the sUAS enables them to capture dramatic shots for each property that would otherwise require costly and noisy helicopter operations . In addition to being able to capture spectacular exterior photos and

video , Pinnacle’s sUAS platforms possess internal sensors for stabilizati on while operating in areas where a GPS signal is not available. This adaptability gives real estate professionals a high quality, cost effective , safe, and simple solution to an otherwise costly and neigh borhood

- disrupting endeavor

.

• Search and Rescue /First Responders

Search and rescue/first responder personnel will also benefit from sUASs capabilities of

real

- time video and surveys that Pinnacle provides. The sUASs ability to inspect dangerous or unstable areas without placing personnel at risk is monumental in saving lives. In addition, the sUASs can survey large areas of land to identify areas of interest at an expedited rate when compared to search and rescue personnel on foot. The sUAS

excels over tr aditional manned aircraft during these instances in both cost and the safety of personnel on the ground.13 • Law Enforcement

Small

- unmanned aerial systems are designed for rapid deployment and covering spec ific areas of interest; these are key components fo r l aw enforcement officers

. Recent developments in sUAS platforms are allowing for easy transition between HD photos and

video. Utilizing a sUAS would prove useful by increasing officer safety when identifying areas of interests with potential threats as well as accident scene investigations and monitoring undercover operations from greater distances.

• Agriculture and Conservation

Pinnacle will demonstrate to farmers the advancements in agriculture analy sis that a sUAS can provide in soil property and moist ure analysis, plant counting, crop stress analysis, erosion analysis, 3D mapping, and othe r areas of agricultural land management. The sUAS can fly pre

- programmed missions that allow the operator to gather precise data.

While the sUAS i s in flight, the pi lot can assume full control to inspect areas of interest. Once it has been examined, the sUAS will resume its flight plan from the last point analyzed. Equipped with an IR camera, the sUAS can also provide farmers with real time

video of locations of wil dlife that potentially threaten their crops.



### VII. Privacy

All flights will be conducted in accordance with any state, federal, or local laws regarding privacy. Pinnacle has inserted a section into its Operations Manual to protect the public privacy.

There is great concern to maintain an expected level of public privacy during the use of sUASs. Guidelines in the Operations M anual outline Pinnacle’s policy in notification of residential property owners, businesses, and other organizations when sUAS operations w ill be conducted in

their area.



### VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be deemed that publication is needed:

Pinnacle Unmanned Aerial Systems, LLC, see ks an exemption from the following rules:

14 CFR Part 61.113 (a) and (b); 14 CFR 91.103; 14 CFR 109(a); 14 CFR 91.113; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b)

.14 

### IX. Conclusion

In meeting the criteria provided in Section 333 of the Reform Act of 2012, considering the size, speed, c apabilities, utilization of visual line

- of

- sight , and operating constraints around controlled airspace and populated areas, Pinnacle has d emonstrated justification for the grant of the requested exemptions to operate sUASs in the defined areas. Approval of this exemption request will allow Pinnacle Unmanned Aerial Systems, LLC, to conduct commercial operations with

small

- unmanned aerial syst ems. Due to each of the sUAS s size

, weight, lack of flammable fue l,

and lack of passengers or crew on board, the risk to the general public and property owners are virtually eliminated.

If you have any questions or require any additional information, pl ease do not hesitate to call.

Regards,

__________________________________________ _____________________________________________________________________________________________________________________________ ___ ____________________________________________ Cody Shehane, President Pinnacle Unmanned Aerial Systems, LLC

Cell Phone: 817

- 888

- 0723

Email: Cody@PinnacleUAS.com

Attachments:

Pinnacle Unmanned Aerial Systems Oper ations Manual DJI Inspire 1 Quick Start Guide V1.2 DJI Inspire 1 User Manual V1.2

DJI Phantom 3 Quic k Start Guide V1.0

DJI Phantom 3 Professional User Manual V1.0 eBee Sensefly Technical Specifications

The above are submitted as Confidential Documents un der 14 C.F.R. § 11.35(b) and exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA pursuant to Section 333 of the Reform Act.