Request for exemption from multiple regulatory provisions to

allow the use of small unmanned aerial systems on land controlled by clients of Islandtime Farms, LLC to assist in the safe evaluation of infrastructure and operations for our clients. Islandtime Farms, LLC respectfully requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of unmanned aerial systems ( UAS ) to assist in the evaluation of infrastructure and operations for our clients. This request is motivated primarily by the desire to maximize safety in infrastructure and operations. While an exemption would not eliminate the current need for in

- person visual inspection required by various federal regulatory departments, it would allow ISLANDTIME FARMS, LLC to broadly evaluate assets and operations with UAS, resulting in a safer and more efficient infrastructure network. Accordingly, the grant of an exemption is consistent with Congress’ intent,
reflected in Section 333 of th e FAA Modernization and Reform Act of 2012 (Modernization Act),1 that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of these systems.2 A summary of this request suitable for publication in the Federal Register is provided as Appendix A. Appendix B provides the manufacturers information regarding the design, aircraft performance, and fail

- safe features. We have provided manufacturer information related to operating limitations,
normal and emergency procedures, and maintenance and inspection procedures. As we add aircraft designs, we willupdate this appendix appropriately. Appendix C provides the

Drone Fleet & Aerospace Management Operations Manual for flights covered under this Exemption R equest. 1 P.L. 112

- 95, 126 Stat 11, February 14, 2012. 2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security. Background Information ISLANDTIME FARMS, LLC is in the business of video capture of real estate, i nfrastructure and industrial plants for our clients

. ISLANDTIME FARMS, LLC is requesting FAA Exemption for UAS operations for inspection s and video capture usage. Regulatory Basis for Exemption Request In addition to the waiver authority

prov ided in §333 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety or how the exemption would provide at least an equivalent level of safety as compliance with the underlying regulation. In this case, approval of this exemption would advance the public interest by significantly enhancing the safety and efficiency of infrastructure operations and by providing the FAA with valuable user experience on UAS in a context with appreciableeconomic and societal benefits. As described more ful ly below,

the requested exemption would permit the operation of UAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary, as explained below, ISLANDTIME FARMS, LLC anticipates that us e of UAS will enhance safety in infrastructure operations. Granting an Exemption is in the Public Interest. The safety and efficiency of infrastructure operations is heavily dependent upon constant analysis of assets, right

- of

-way, infrastructure and other assets/facilities. There are a wide variety of factors that can affect conditions and cause problems for infrastructure. Even relatively small objects or minor failures can lead to accidents or other incidents causing downtime of
infrastructure. Extreme weather events can lead to flooding or overheating infrastructure. For example earthquakes, landslides, and abandoned vehicles at grade crossings can block infrastructure. The potential for sabotage and terrorism

– or even just trespassing

– are also among the many risks that modern infrastructure faces. As a result, pursuant to federal regulations and company policy, our client’s maintenance employees routinely inspect the infrastructure, such as bridges, tunnels, support structures, and signals. At present, this work is done primarily by company personnel in motor vehicles, on foot, in specialized equipment. This is often a labor

- intensive and sometimes arduous job. While our clients do all they can to make these inspections as safe as possible, there is an irreducible element of risk involved whenever employees arerequired to go out on structures. Employees may need to climb

over or onto structures, which can be slippery, rough, and/or exposed to the elements. Some structures, such as bridges, are high above the ground. Equipment moving through inspection zones can increase risk as well, especially in high

-traffic areas.
While the use of UAS for supplemental infrastructure and general asset evaluation would not eliminate these risks entirely (as it is an ad ditive safety measure), it would reduce the risks to employees by allowing for remote aerial review. Additionally, the sheer amount of assets and the widely dispersed locations

– in many instances far from sizeable population centers

– means that visual in spection in all instances by company personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical because the required altitudes for safe flight reduce visibility below meaningful levels

– it is simply not possible to see all asset anomalies from such heights. Helicopters present better vantage points; however manned helicopters are much more costly, subject to human safety and carry highly explosive jet fuel making them impractical for deployment. By using UAS for supplem ental asset evaluation, ISLANDTIME FARMS, LLC will be able to substantially upgrade its capacity to detect and address issues with the right

- of

-way and other assets before they become a problem for safe operations. Thus, the use of UAS has the potential to improve efficiency, resulting in faster and safer delivery of goods, energy & natural resources vital to the U.S. economy. Granting an Exemption will not Adversely AffectSafety ISLANDTIME FARMS, LLC notes that there is no

applicable standard for an equivalency determination. Some have argued that the appropriate standard is that for model aircraft, noting that their operations, if conducted for recreational purposes, would fall completely within the allowable operations for model aircraft. We believe it i s difficult to argue that there is sufficient correlation between model operations controlled by the Academy of Model Aeronautics and the ones contemplated by ISLANDTIME FARMS, LLC . At the same time, it is clear that equivalency cannot be established for

t raditional, manned civil aircraft because the design and use profiles between traditional aircraft and UAS are simply too different. As such, we believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, whic h is all that §11.81(e) requires. Granting an exemption will not adversely affect safety. ISLANDTIME FARMS,
LLC contemplates conducting UAS operations over client owned or controlled land, solely during daylight hours, at altitudes well
below that which wo uld pose a risk to other aircraft. In general,
UAS operations are intended to be conducted in areas distant from both congested areas and airports. Moreover, because of the inherent risks presented by standard infrastructure operations, our clients have al ready taken steps to secure property aga inst unauthorized public access . The nature of operations anticipated by ISLANDTIME FARMS, LLC requires that the UAS be flown at relatively low altitudes and relatively low speeds. ISLANDTIME FARMS, LLC expects that in mostinstances, the UAS will be flown less than 75 feet from the

highest structure along the path of the UAS . Accordingly, the
risk of interference with another aircraft is minimal. ISLANDTIME FARMS, LLC also plans to conduct UAS operations at least three miles from any public airports (including heliports ) Approval of exemptions allowing commercial operations of UAS s in the infrastructure aerial inspection industry will enhance safety by reducing risk. Conventional operations, using jet or piston power a ircraft, operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the inspection site. In contrast, a UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible
fuel carried on board. The UAS is carried to the inspection site.
The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weighing less tha n 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft

req uirements and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground,and in a controlled environment and, as a result, are far safer

than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. The safety of those on the ground is protected by the
fact that no one will be allowed into the area without the permission of the company. Security will be established for the flight area as part of the pre

-fli ght control. Each individual within the secure area will be briefed prior to flight and will consent to being in the area. All others will be excluded from
the area. ISLANDTIME FARMS, LLC initially intends to use a
dedicated staff for UAS operations. All o perations will be within
visual line

- of

- sight (i.e., no more than approximately 0.5 miles from the manipulator of the controls, or pilot in command (PIC)). Each PIC will conduct at least three take

- offs and landings with the UAS on which he or she is train ed every 90 days. PIC’s will establish their qualifications thru a combination of aeronautical knowledge, UAS airmanship skills, and verification through testing of flight ability before infrastructures operations have commenced. Depending on the type of o peration, additional ground

- based visual observers may be employed as well. These observers will be within constant visual line of sight and in constant contact with the PIC. The visual observers will assist the PIC in avoiding objects
near the UAS . There are no standards for either Private or
Commercial UAS pilot certificates. The safe operation and control of the UAS as described in this application does not depend on the type of FAA license held by the PIC. Given therestricted and controlled airspace wi thin which operations will

take place, the key factors needed by the PIC are knowledge of the airspace within which the operation will take place and how that airspace fits into the National Airspace System (NAS). That knowledge can be and is gained primar ily through ground school and not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the factors and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial vehicle, ope rating at 400 AGL or lower, within strictly controlled pre

- approved airspace. Besides knowledge of airspace regulations, dexterity in the control and operation of the UAS acquired from actual operation of the aircraft is the most important factor in establishing an equivalent level of safety. If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are (1) where the aircraft will be flo wn, (2) the size of the aircraft relative to what is being used today to accomplish the same mission, and (3) what precautions will be taken to ensure the safety of those in the area of operation. We propose that the PIC has at least an FAA Private Pilots Certificate and a Class III medical; the aircraft be operated within a secure environment; and that no one be allowed to enter the secure environment unless they are part of theoperation, have been fully briefed of the risks prior to

operation of the UAS

, and have consented to the risks associated with being in the operating area. Should there be a mishap, the UAS being flown pose significantly less of a threat than the helicopters and fixed wing aircraft now being employed because they are a fraction of t he size, carry no flammable fuel, do not carry crew or passengers, and pose an
infinitesimal risk to others. This is in stark contrast to conventional aircraft that are flown to the site, carry explosive fuel, carry passengers and crew, and operate in a mu ch larger area. From a practical standpoint, there are relatively few
licensed full

- scale aircraft pilots who are also qualified to fly the type of UAS that are utilized for infrastructure image

- capture operations. There are even fewer commercial pilots th at can fly
these UAS

– to the point that to do both is considered rare. Assuming that it is unlikely for a company to find a pilot that has both qualifications that company would either have to source a qualified UAS pilot to train and obtain a commercial certificate, or find a commercial certificated pilot who would be willing to learn to fly a UAS to the competency level required for professional use. ISLANDTIME FARMS, LLC intends to use commercially available UAS Components for UAS . These UAS systems wil l be tested for quality & safety in our test facility before being deployed to the field. The UAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. We have a routine
maintenance schedu le to verify that the UAS will remain in safeand operational condition. Please see Appendix B, for Specific

Types of UAS . Notes Regarding: 14 C.F.R. Part 21, Subpart H In accordance with the statutory criteria provided in Section 333
of PL 112

- 95 in reference to 49 USC 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, we request that this aircraft exemption meets the conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary. Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft Given the size of the sUAV, two

- inch lettering will be impossible. UA w ill be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. Notes Regarding: 14 CFR § 91.7(a) Civil Ai rcraft Airworthiness ISLANDTIME FARMS, LLC’s request is based on the fact that no
airworthiness certificate will be issued for the UAS. ISLANDTIME FARMS, LLC’s UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary. Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard Certifications required, the original intent of these re gulations was to display an aircraft’s airworthiness, certification, and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandumsubject “Interpretation regarding whether certain required

documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary. Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests S mall UASs, by their design, do not have fully functional dual controls. Flight control is accomplished through
the use of a control box that communicates with the aircraft via radio communications. Aircraft being considered for use by ISLANDTIME FARMS, LLC allow the UAS pilot to place the aircraft into ‘loiter’ mode (fixed altitude stationary ho ld). In the event of the pilot losing control, the UAS Instructor can quickly and via alternate equipment (equipment not in the hands of the student) place the aircraft into a mode that then allows the instructor to bring the aircraft back into control and back to the predetermined and/or safe landing location. ISLANDTIME FARMS, LLC does not describe training scenarios in which a dual
set of controls would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other company

designated individual, that would require that individual to have fully functioning dual controls. Rather, ISLANDTIME FARMS, LLC evaluates the qualification of its PICs based on their experience with the UAS to be operated and verifies through testing, in lieu of formalized training. As such, ISLANDTIME FARMS, LLC does not seek relief from 14 CFR § 91.109. Notes Regarding § 14 CFR 91.119(b) Relief from § 14 CFR 91.1 19(b), operation over congested areas, is not applicable, because theISLANDTIME FARMS, LLC’s operations will only be conducted

within the secured area described herein. ISLANDTIME FARMS,
LLC Safety Operations & Procedures Overview: Technology
Consideratio ns: Best

- in

- class, tried and proven technologies that are in advanced iterations. Software from highly

- reputable industry partners will include features

- 1. Auto descent (landing) if communication signal were to be severed. If the
UAS loses communications, the UAS will have capability to return to a pre

- determined location within the Security Perimeter and land. 2. Auto descent (landing) if battery were to drop lower than nominal level. 3. Flights will be terminated at 25% battery power reserve. 4. Live vi deo for operator gives
real

-time positioning feedback. In other words, we can monitor the scene from the vehicle's perspective for collision avoidance, and to maintain spatial orientation. 5. The UAS will have the capability to abort a flight in case of un predicted obstacles or emergencies. 6. On

-Screen

- Display (OSD) contains operating information to ascertain vehicle health at all times: speed, altitude, number of GPS satellites (when available), heading and voltage. 7. GPS lock supplies for return

-to

- home (RTH). Should Command and Control (C2) link failures occur (highly improbable), vehicle returns automatically to the point of launch. 8. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, which downlinks
from the aircraft to a ground

- based on

- screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitallyencoded barometric altimeter, or radio altimeter, or any

combination there of. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot. Mechanical/Physical: 1. We will fly line

- of

- sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminatin g the concern of signal severance (flying behind objects/walls). 2. The UAS will weigh less than 55 lbs
and travel at less than 50 knots. 3. Batteries should far exceed the capacity required for actual flight time. 4. Flights will be operated at an altitud e of no more than 400 feet AGL. 5. Fireproof bags for storage and charging of high capacity Lipo
batteries on

- site. 6. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or as otherwise authorized by the FAA. Personnel: 1. Sp otters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal op, director) 2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication. 3. A briefing will be conducted in regard to the planned UAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 4. The operator will obtain the consent of all p ersons involved in the UAS operations and ensure that only consenting persons will be allowed within 100 feet of the flight operations. 5. Observer and pilot will at all times be able to communicate by voice. 6. Written and/or oral permission from the rele vant propertyholders will be obtained. 7. Pilot and observer will have been

trained in operation of UAS generally and received up

-to

- date information on the particular UAS to be operated. Operations: 1. The unmanned aircraft (UA) must weigh less than 55 p ounds (25 Kg), including energy source(s) and equipment. Operations authorized by this petition of exemption are limited to the following aircraft described in Appendix B. Proposed operations of any other aircraft will require a new petition or a petition amendment to this request. 2. The UA may not be flown at a ground speed exceeding 50 knots. 3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL. 4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued medical certificate. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. The operator’s manual included as Appendix C and this petition of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the proc edures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operatormust follow the procedures as outlined in its operator’s

manual. The operator may update or revise its operator’s manual. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or
amendment. If the operator determines that any update or revision would affect the basis for which the FAA grants this petition for exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if qu estions arise regarding updates or revisions to the operator’s manual. 7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, th e aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional t est flight in accordance with the operator’s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must b e added tothe operator’s manual. 9. The operator must follow the

manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, an d inspection/maintenance requirements must be established and identified in the operator’s manual. At a minimum, requirements for the following must be included in the operator’s manual: a. Actuators / Servos; b. Transmission (single rotor); c. Powerplant (motors); d. Propellers; e. Electronic speed controller; f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control; i. Ground control station (if used); and j. Any other components as determined by the operator; 10. The P ilot In Command (PIC) must possess at least a private pilot certificate and at least a
current third

- class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an
aircraft in which the PIC is rated on hi s or her sport pilot license

. 11. Prior to operations conducted for the purpose of infrastructure inspections, the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 20 flight cycles and 10 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement.
Traini ng, proficiency, and experience

- building flights can also be conducted under this petition of exemption to accomplish therequired flight cycles and flight time. During training,

proficiency, and experience

- building flights, all persons not
essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 12. Prior to operations conducted for the purpose of infrastructure inspection, the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience building, and take

- off and landing currency flights can be conducted under this petition of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

- building, and
take

- off and landing currency flights all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 13. Prior to any fl ight operations authorized by this petition of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and imp lemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request. 14.Prior to operations conducted for the purpos e of infrastructure

inspection, a flight demonstration, administered by an operator

- approved and

- qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator.
Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will cond uct these tests in accordance with the operator’s manual. 15. The UA may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on
the surface in the event of a UAS failure or emergency. 16. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting personnel. At all times, those persons must be essential to the operations. 17. Regarding distance from

n onparticipating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the infrastructure inspection operations. This provision may be reduced to no less
than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the infrastructure inspection area to note terrain features, obstructions, buildings, safety barriers, etc. Suchbarriers may protect nonparticipating persons (observers, the

public, news media, etc.) from debris in the event of an
accident. 18. If the UAS loses communications or loses its GPS signal, the UA must retur n to a pre

- determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 20. Each UAS operation must be completed with 25% battery power remaining. 21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this petition of exempti on. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. The operator must develop procedures to
document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator’s manual. 24. Each UAS operated under this exempti on must comply with all manufacturer Safety Bulletins. 25. The operator must develop UAS technician qualificationcriteria. These criteria must be added to the operator’s manual.

26. The preflight inspection section in the operator’s manual
must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual. 27. Before conducting o perations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. At least three days before scheduled infrastructure inspection, the operator of the UAS affected by this exemption
must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed infrastructure inspection.
The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS infrastructure inspection operations conducted under this petition of exemption; c. Name and p hone number of the person responsible for the on

scene operation of the UAS; d. Make, model, and serial or N

number of UAS to be used; e. Name and certificate number of UAS PICs involved in the infrastructure inspection event; f. A statement that the opera tor has obtained permission from property owners and/or local officials to conduct the infrastructure inspection event; the list of those who gave permission must be made available to the inspector uponrequest; g. Signature of exemption

- holder or represen tative;

and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which infrastructure inspection will be conducted and the altitudes essential to accomplish the operation. 29. The
documents required under 14 CFR §§ 91.9 and 91.203 must be
available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 30. The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 31. UAS operations may n ot be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 32. The UAS may not be operated by the PIC from an y moving device or vehicle. 33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 34. The UA may not operate in Class B, C, or D airspace with out written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

-towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obta ined, and the operation is conducted inaccordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to the Administrator upon request. 35. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety B oard (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

80 and authorization to resume operations is provided. Support
for P etition for Exemption In accordance with the procedural requirements of 14 C.F.R. §11.81, ISLANDTIME FARMS, LLC provides the following information: Contact Information: Paul Gryce Owner Islandtime Farms, LLC

. 2112 Blakemore Lane, La Grange, KY 40031 (502) 310

- 9572 Paul@islandtimefarms.com Regulatory Provisions from which ISLANDTIME FARMS, LLC seeks an Exemption

, ISLANDTIME FARMS, LLC believes it may need an exemption from the following provisions to conduct the contemplated operations. In some instances, re lief is needed because relief from another provision renders compliance with the regulation at hand infeasible. 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F. R. §91.407(a) 14 C.F.R. §91.409(a)(1)&(2) 14 C.F.R. §91.417(a)&(b) ISLANDTIME FARMS, LLC believes anexemption is only needed from the above

- listed regulatory

provisions. To the extent that the FAA believes that additional relief is required for ISLANDTIME FARMS, LLC to conduct the operations described here, we request an exemption from any such regulatory provisions as well.3 3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. Since none of the under lying requirements (e.g., inspection intervals) can be met and will require an exemption, ISLANDTIME FARMS, LLC believes a separate exemption should not be required for §91.417(a). The Extent of Requested Relief and the Reasons Relief is Needed
Section 333 Aircraft Exemption Status: Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports and populated areas. An analysis of these criteria demonstrates
that the UAS operated without an airworthiness certificate in the areas and under the conditions contemplated by ISLANDTIME FARMS, LLC will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the conditions proposed in this request. The UAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and observer. Operations will be conducted incompliance with the FAA and with local public safety

requirements to provide security for the area of operation as is now done with conventional equipment, infrastructure, bridge and out building evaluation. These safety enhancements provide an expanded degree of safety to the inspectors over conventional operations. Lastly, application of these same
criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials and
inabi lity to carry a substantial external load. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular
UAS . In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will
be at l east as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 14 C.F.R. §61.113(a) and (b) §61.113 Private pilot privileges and
limitations: Pil ot in command. (a) Except as provided in paragraphs (b) through (h) of this section, no person who holdsa private pilot certificate may act as pilot in command of an

aircraft that is carrying passengers or property for compensation or hire; nor may that p erson, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that b usiness or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. ***** ISLANDTIME FARMS, LLC anticipates initially using a cadre of specially trained staff to
conduct the UAS operations. While these individuals wi ll not hold commercial pilot licenses. The UAS will not carry property for compensation or hire since they will be used solely to assist in evaluation of the infrastructure, equipment, right

- of

-way, assets, bridges, tunnels and out

- buildings in furtherance of ISLANDTIME FARMS, LLC’s client’s primary business, the successful operation of a infrastructure; however, the employees’ operation of the UAS will not be incidental to their employment with ISLANDTIME FARMS, LLC, and they will be compensated for such w ork. Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft.
The UAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole control of ISLANDTIME FARMS, LLC clients. Accordingly, the risk would belimited to ISLANDTIME FARMS, LLC personnel, who will be

appropriately outfitted in safety gear, and ISLANDTIME FARMS,
LLC client’s property on the ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on IS LANDTIME FARMS, LLC . Because the contemplated operations would not comply with §61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b). 14 C.F.R. 91.119(c) §91.119 Minimum safe altitudes:
Gen eral. Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: *** (c) Over other than congested areas. An altitude of 500 feet above the surface, 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. ***** ISLANDTIME FARMS, LLC submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk of
collision with another aircraft, safety can only be assured through the grant of an exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because an emergency landing of the airc raft due to a power failure will not create an undue hazard to persons orproperty on the surface. As noted in the explanation of why an

exemption will not adversely affect safety, ISLANDTIME FARMS,
LLC clients has exclusive use of the land over which the UAS will be operated, and public access is restricted. It also has exclusive use of significant portions of land adjacent to the infrastructure and structures that will be the objects of evaluation and analysis. ISLANDTIME FARMS, LLC’s Clients tightly cont rol access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk of injury is minimal. ISLANDTIME FARMS,
LLC does not contemplate conducting operations over congested areas, so relief is not requested from paragraph (b). 14 C.F.R. 91.121 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is
set “...to the elevatio n of the departure airport or an appropriate altimeter setting available before departure.” ***** As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieve d by the operator, pursuant to the Manual and Safety Check list, confirming the
altitude of the launch site shown on the GPS altitude indicator before flight. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data fe ed, which downlinks from the aircraft to a ground

- based on

- screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPStriangulation, or digitally encoded barometric altimeter, or

radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot. 14 C.F.R. 91.151 §91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an air plane under VFR conditions unless (considering wind and forecast 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 30 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at le ast 20 minutes. ***** Operating
the UAS in a pre

- defined area with less than 30 minutes of reserve fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it
has to be flown to an alternate ai rport or circle the planned airport in the event of unanticipated conditions. ISLANDTIME FARMS, LLC does not intend to use the UAS for point

-to

- point flights and will not operate the UAS beyond visual line of sight.
Nor will the UAS require an airport in o rder to land. Rather, ISLANDTIME FARMS, LLC will operate the UAS using pre

planned flight paths (taking into account weather conditions) designed to allow the UAS to fly to the point of intended landing. As such, there is no need for a timebased excess fue l requirement. Rather it should be sufficient to require only asmuch additional excess flight capacity as necessary to safely

land the UAS . We believe that a 25% battery reserve is more than sufficient to meet this objective. 14 C.F.R. 91.405(a), 91.407(a ) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) §91.405 Maintenance required. Each owner or operator of an aircraft

– (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; ***** §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft th at has undergone maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; ***** §91.409 Inspections. (a) Except as provided in paragraph (c) of this section, no perso n may operate an aircraft unless, within the preceding 12 calendar months, it has had __ (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ***** §91.417 (a) & (b) ***** ISLANDTIME FARMS, LLC believes that an exemption from these three maintenance requirements is appropriate
because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individuals authorizedby the FAA to approve a UAS for return to service under

§91.407(a) or to conduct the i nitial airworthiness and annual return to service inspections required by §91.409(a). ISLANDTIME FARMS, LLC will maintain the aircraft as instructed in the owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft until it has reas onably determined that any needed repairs have been made. However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate. Please do not hesitate to contact me at the phone number or via the e

- mail address provided above should you have any questions or concerns. Respectfully submitted, Simon Nielsen CEO, Drone Fleet & Aerospace Management, Inc. Appendix A Summary for Federal Register Publ ication Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determine that publication is needed. Petitioner: Drone Fleet & Aerospace Management, Inc. ( ISLANDTIME FARMS, LLC ) Sections of 1 4 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Description of Relief Sought: Pet itioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct UAS operations over ISLANDTIME FARMS, LLC Client’s owned orcon trolled land, solely during daylight hours, to assist in the

safe evaluation and analysis of infrastructure and operations. In general, UAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature of operat ions anticipated by ISLANDTIME FARMS, LLC requires that the UAS be flown at relatively low altitudes. ISLANDTIME FARMS, LLC expects that in most instances, the UAS will be flown less than 75 feet from the highest structure along the path of the UAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of interference
with other aircraft is minimal.

Appendix B Specific type(s), make, and model #1

–
RCT 800 Chassis RTC APM ArduFlyer V2.5.2 Flight Controller (Not sure)

RCT CN06 Plus GPS Receiver

RCT HP4215

- 630KV motors x6

RCT HVSK

-40A ESC x6

RCT 12x4.5 Carbon Fiber Blades x6

RCT Anti Vibration Dome Kit
RCT Beeper RCT Power Conditioning Capacitor

RCT USB cable to Connect with "Mission Planner" software RCT 915 MHZ Telemetry Air Module and Ground StationRCT Battery Voltage Tester/Alarm x2

RCT Removable Battery Tray x2 RCT Carbon Fiber Landing Gear

RCT Black ASP 3 Axis Nex

- GH5 Brushless Gimbal with BaseCam Simple BGC 32bit Brushless Gim bal Controller Alum case
Version RCT 5v/5a SBEC Conditioned power supply

Thunderbolt 5.8G 32CH 2000mW TS5832 Transmitter ELGAE 32CH/5.8G Wireless Receiver Zippy 8000mah 4s 14.8v 30c Lipo Battery x3 Walkera Devo 7 Transmitter & Devo AX701 7 Channel
Re ceiver