Planck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 1 21 April 2015

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

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Planck Aerosystems Inc requests an exempti on from several provisions of the the Federal Aviation Regulations ("FARs") identified below, to allow commercial operations of RDASS small unmanned aerial system (sUAS) for aerial imaging of objects on or below the surface of the ocean or
other water ways , so long as such operations are conducted within and under conditions outlined herein or as may be established by the FAA as required by Section 333.

The RDASS is an all

- weather, electric powered, quad rotor, vertical takeoff and landing (VTOL) sUAS that is capable of capturing and transmitting live airborne video and still photographs as well as health and status information to a ground control station (GCS ). The RDASS has a maximum weight of 3.5 pounds fully loaded, can fly for up to 45 minute s with extended battery pack, and comes equipped with dual redundant radios for command and control that operate at 900 MHz and 2.4 GHz.

The RDASS is built by Leptron of Denver, Colorado, and is distributed by HSE

- UAV of Illinois. It was developed for mi litary and first responder applications, but has been repurposed for commercial and
civil uses. The RDASS sUAS was selected for its ability to fly in moderate and gusty winds and rain, as well as general weatherproofness so that it can survive occasional s plashes that may be encountered, thereby improving its overall reliability and safety. It also has an established maintenance schedule provided by the manufacturer.

This exemption would apply to oper ation of the sUAS by a pilot who hold a commercial pilot license

, have a valid medical certification, and have thoroughly reviewed all manuals and documentation provided by the aircraft manufacturer. In addition, aircraft maintenance will be performed at regular intervals according to the manufacturer’s ma intenance plan.

The RDASS’s capabilities, along with Planck Aerosystems’ pilots experience, make it ideally suited to conduct aerial surveying and identification of surface and subsurface objects in water, including boats, logs, fish, rocks, kelp, reefs, marine mammals, etc. The aircraft will be operated with the following

restrictions:Planck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 2  All operations will occur i n the field within Visual Line of Sight (VLOS) in Class G airspace with both a Pilot in Command (PIC) as well as a nearby Visual Observer (VO) who will be within voice
distance of the PIC at all times

.

 Operation would occur at no more than 400 ’ AGL, typically over water, except for take

- off and landing procedures.

 The aircraft will not operate over populated areas

 The aircraft will not be operated over assemblies of people

 The aircraft will not operate within 5NM of an airport

 The aircraft will only be operated in good weather with light winds predicted

As a result of the RDASS’s size, weight, speed, range, capabilities, and reliability, as well as the limited operation over water and far from populated areas detailed in this petition, it does not pose a hazard to the public or any users of the national airspace. In addition, it does not pose a threat to national security. In fact, granting this exemption would be in the public’s interest and benefit the public as a whole by permitting the detailed mapping of subsurface obstacles, and enabling applicatio ns for marine science and maritime security.

The name and contact information of the application are:

Planck Aerosystems, Inc Attn: David Twining Address: 3106 Maple Street, San Diego, CA 92014 Phone: (510) 292

- 6235
Email: dave@planckaero.com

Planck A erosystem’s exemption request in cludes the following regulations , with additional details
below :

14 CFR Part 21

14 CFR 45.23

14 CFR 45.27
14 CFR 45.29

14 CFR 91.119
14 CFR 91.121
14 CFR 91.151

14 CFR 91.405
14 CFR 91.407

14 CFR 91.409
14 CFR 91.417Planck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 3 14 CFR Part 21 , Subpart H: Airworthiness Certificates The RDASS aircraft is safe and fit for operation under the conditions listed in this petition. In particular,
the aircraft will be flown for research and development purposes exclusively over water, far from people
or other vessels , in Class G airspace . The aircraft will not c arry persons or fuel, is small and light weight

, and is at least as safe as manned aircraft performing the same operation. Subject to the conditions and limitations listed in this petition, the aircraft meets the requiremen ts for an equiva lent level of safety.

14 CFR 45.23 Display of marks; general ; 14 CFR 45.27 Location of marks; nonfixed

- wing aircraft ; 14 CFR
45.29 Size of marks The small UAS included in this petition does not include certain features, such as cabin or cockpit, to mark according to this r egulation. In addition, t he aircraft is too small to legibly accommodate the lettering size listed in the regulation. I n lieu of this, we propose marking the a ircraft with the word

“ Experimental ” and/or other identifying numbers in as large of letter s as p ossible such that the PIC and VO may be suitably able to identify the aircraft. In addition, the ground control station will also be clearly marked to mak e it clear to observers that it is associated with the sUAS.

14 CFR 91.119 Minimum safe altitudes: Gener al This regulation establishes safe alitudes for operation of aircraft, and requires that the aircraft may not operate closer than 5 00 feet to any person, vessel, vehicle, or structure. Since the aircraft listed in this

pe tition will operate at a maximum of 400 feet AGL, it cannot meet the requirements of the regulation. However, it wi ll not be operated in congested or populated areas, nor will it operate directly above people at any time. If power fails for any reason duri ng flight, the aircraft will fall safely into water
without risk to people or property.

14 CFR 91.121 Altimeter settings An exemption to this regulation is requested because the sUAS is not equipped with a barometric
altimeter . Instead, it is equipped with a GPS device that determines and displays alt itude based on the
GPS satellite network. The ensure an equivalent level of safety, the PIC will confirm the readings and function of the GPS device prior to each flight , and continue to monitor it throughout the flight.

14 CFR 91.151 (b) Fuel requiremen ts for flight in VFR conditions This regulation requires that there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes . The sUAS in cluded in this petition is battery powered and has a maximum endurance of less than 60 minutes. Given the small size and weight, along with proposed operating environment

, a n exemption from t his regulation poses no additional risks. We propose reducing the regulation to 10 minutes of re serve, which w ould be adequate for the sUAS to safely return to the planned landing zone from anywhere in its operating area.

14 CFR 91.405 Maintenance required ; 14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration ; 14 CFR 91.409 Inspections ; 14 CFR 91.417 Mainten ance records
We feel that we can provide and equivalent level of safety with an exemption from these regulations, provided that the PIC perform regular inspectio ns, log details of usage and any maint en ance that is performed, and complies with the manufacturers maintenance schedule. The PIC is the person mostPlanck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 4 familiar with the aircraft and is best suited to ensure that the aircraft is in an airworthy condition prior to every flight. Given the overall small size and simplicity of the aircraft, we feel that the PIC can ensure an equivalent level of safety.

Federal Register Summary The following summary is provided for publication in the Federal Register. Exemptions sought: 14 CFR Sections 21, 45.23, 45.27, 45.29, 91.119, 91.121, 91.151, 91.405, 91.407, 91.409, 91.417 Description of the nature of the exemption: Planck Aerosystems is seeking an exemption to conduct aerial surveying operations using small aerial unmanned vehicles over bodies of water.

We are prepared to amend this request for exemption to satisfy the FAA’s recommendation on providing equivalent level of safety. Please contact us for any addi tional information or clarification.

Sincerely,

David Twining Chief Operating Officer Planck AerosystemsPlanck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 5 Appendix A
Additional Aircraft Information

Figure 1 : The RDASS Shown in Flight

Figure 2 : RDASS Shown Packed into its Case for Safe Transportation

There are many videos on YouTube, published by the RDASS manufacturer and distributor, that show
the typical RDASS deployment and operat ion. Several examples include: https://youtu.be/AJ4TI2L8oFA https:// youtu.be/82Gtait3M

- M https://youtu.be/8MAmpCr7mjIPlanck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph : (619) 770

- 8150 www.planckaero.com
P age 6 Appendix B
Link to Maintenace Schedule I nformation

http://www.hse

- uav.com/products_maintenance.htm