1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Unmanned Eagle Eye, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OP ERATION OF DJI S900 , DJI S1000 +, DJI PHANTOM 3 , DJI INSPIRE 1 V ERSION 2.0 , 3DR SOLO, TAYZU ROBOTICS QUADRA UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112
- 95)

Submitted on January 4, 2016
Christian Michael Peters Unmanned Eagle Eye, LLC 203 Lago Circle Drive N. Santa Fe, Texas 77517 Phone : 281

- 299

- 6490 Email: cpeters@UnmannedEagleEye.com2 TABLE OF CONTENTS PAGE GLOSSARY OF ABBREVIATIONS

................................ ................................ ............................ 3 SUMMARY

................................ ................................ ................................ ................................ .... 4 INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ .................... 4 BACKGROUND

................................ ................................ ................................ ............................ 5 BASIS FOR PETITION

................................ ................................ ................................ ................. 5 A. Name And Address Of The Petitioner.

................................ ................................ .................. 7 B. The Specific Sections Of 14 C.F.R. From Which Unmanned Eagle Eye, LLC Seeks Exemption.

................................ ................................ ................................ ................................ .. 8 C. The Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks The Relief.

................................ ................................ ................................ ..... 12 D. The Reasons Why Granting Unmanned Eagle Eye, LLC Request Would Be In The Public Interest; That Is, How It Would Ben efit The Public As A Whole.

................................ ........... 16 E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Unmanned Eagle Eye. LLC Seeks Exemption.

................................ .......... 19 F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Unmanned Eagle Eye, LLC Seeks Exemption:

................................ ............................ 34 G. Any Additional Information, Views, Or Arguments Available To Support Unmanned Eagle Eye, LLC Request.

................................ ................................ ................................ .................... 35 CONCLUSION

................................ ................................ ................................ ............................. 35 APPENDICIES

................................ ................................ ................................ ............................. 373 GLOSSARY OF ABBREVIA TIONS

AGL Above Ground Level AOI Area of Interest ATC A ir Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System UEE Unmanned Eagle Eye, LLC VFR Visual Flight Rules VLOS Visual Line of S ite VMC Visual Meteorological Conditions VO Visual Observer VTOL Vertical Takeoff and Landing4 SUMMARY

Christian Michael Peters seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Unmanned Eagle Eye, LLC ( h ereinafter “ UEE ” or “ Unmanned Eagle Eye ” ) to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of landscape over certain areas of the United States.

INTRODUCTION AND INT ERESTS OF THE PETITI ONER

Unmanned Eagle Eye, LLC provides its cl ients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. UEE has established itself as a technological innovator in experiential multimedia and is recognized as a leader in providing a qualit y serivice . The objective of UEE’s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

 Agriculture; Crop Health, Insuranc e Claims, Cattle Health, and S ilo I nspections

 Industry; Inspecting power lines and pipelines, surveying and mapping of mines and oil refineries

 Videography & Photography; Real

- Estate, Marketing, and any special event

 Hazardous Operations; Oil spills, hazmat spills, and search & rescue operations

 Security; Provide video surveillance and intelligence for an event5 BACKGROUND Unmanned Aircraft Systems: DJI S900, DJI S1000 + , DJI PHANTOM 3, DJI INSPIRE 1

V ERSION 2.0, 3DR SOLO, TAYZU ROBOTICS QUADRA UAS
Unmanned Eagle Eye, LLC seeks an exem ption to operate UASs for compensation or hire within the NAS. The DJI S900, DJI S1000+, DJI PHANTOM 3, DJI INSPIRE 1 VERSION 2.0, 3DR SOLO, and TAYZU ROBOTICS QUADRA UAS (hereinafter “UEE’s Aircrafts”) are vertical takeoff and landing (VTOL) Unmanned Airc raft ’s (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. UEE’s Aircrafts have a maximum gross weight of ap proximately 9 pounds 15 ounces , a maximum diagonal wheelbase of 35.5 inches, and a maximum speed of approximately 29 knots. UEE’s Aircrafts are equipped with a maximum of 8 rotors; powered by Lithium Polymer batteries.

UEE’s Aircrafts operated by UEE will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Unmanned Eagle Eye, LLC pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitio ns the Administrator to commercially operate UEE’s Aircrafts in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b).6

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, UEE operation of UEE’s Aircrafts meets the conditions of FMRA Section 333 and therefore, will not require an a irworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Accordingly, Unmanned Eagle Eye, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements
for m aintenance that only apply to aircraft with an airworthiness certificate.
Unmanned Eagle Eye, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. UEE will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and UEE’s Aircrafts Instruction Manual s ). Furthermore, UEE will document and maintain all maintenance
records for UEE’s Aircrafts

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Unmanned Eagle Eye, LLC to the extent necessary to all ow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate UEE’s
Air crafts in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Unmanned Eagle Eye, LLC seeks relief from Section 91.7(a), entitled Civil airc raft airworthiness, because UEE’s Aircrafts do not require an airworthiness certificate in accordance7

with 14 C.F.R. Part 21, Subpart H. As such, UEE submits that it will ensure that UEE’s Aircrafts are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and UEE’s Aircrafts
Instruction Manual s ), and that the aircraft are in a condition for safe flight.
Unmanned Eagle Eye, LLC also seeks an exemption fro m the requirements of Section 91.121, entitled Altimeter Settings , as UEE’s Aircrafts will not have a typical barometric altimeter onboard. However, altitude information of UEE’s Aircrafts will be provided to the PIC via Global Positioning System (GPS) equ ipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with UEE’s operation of UEE’s Aircrafts within visual line of sight, at or below 500 f

eet AGL, will ensure a level of safety equivalent to Section 91.121.
Additionally, Unmanned Eagle Eye, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. UEE submits that safety will not be affected by operation of UEE’s Aircrafts during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13 minutes to the first point of intend ed landing and, assuming normal cruising speed, to fly after that for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, Unmanned Eagle Eye, LLC provides the following information in support of its petition for exemption:

A. Name And Address Of The Pet itioner. The name and address of the Petitioner and point of contact is:

Christian Michael Peters8

Unmanned Eagle Eye, LLC 203 Lago Circle Drive N. Santa Fe, Texas 77517 Phone : 281

- 299

- 6490 Email: cpeters@UnmannedEagleEye.com

B. The Specific Sections Of 14 C.F.R. From Which Unmanned Eagle Eye, LLC Seeks Exemption. 1. Unmanned Eagle Eye, LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113m entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passe ngers or property for compensation or hire. 2. Unmanned Eagle Eye. LLC Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition

. 3. Unmanned Eagle Eye, LLC Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:9 (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and withi n 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equippe d with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
4. Unmanned Eagle Eye , LLC Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (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, assum ing normal cruising speed, to fly after that for at least 20 minutes. 5. Unmanned Eagle Eye, LLC Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

—10 (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[.] 6. Unmanned Eagle Eye, LLC From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. Unmanned Eagle Eye, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unl ess, 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.
8. Unmanned Eagle Eye, LLC Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state t he following:11 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The recor ds must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, a nd appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety12 directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently instal led engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or supersed ed by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
C. The Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks The Relief. 1. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to t he extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.13

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The fl ight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Unmanned Eagle Eye, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate UEE’s Aircrafts unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate UEE’s Aircrafts in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and stru ctures.
Further, Unmanned Eagle Eye, LLC submits that all flights of UEE’s Aircrafts , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Unmanned Eagle Eye, LLC business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief U nmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Unmanned Eagle Eye, LLC to determine that UEE’s Aircrafts are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Unmanned Eagle Eye, LLC Aerial Operations Manual, Monthly Maintenance Log, and UEE’s A ircrafts Instruction Manual s ).
Unmanned Eagle Eye, LLC seeks the requested relief because UEE’s Aircrafts do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,14

Unmanned Eagle Eye, LLC will ensure that UEE’ s Aircrafts are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and UEE’s Aircrafts Instruction Manual s ) prior to every flight, and further, determine that the aircraft are in
condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of UEE’s Aircrafts , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FA A requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Unmanned Eagle Eye, LLC seeks the requested relief because UEE’s Aircrafts altimeter may be set on the ground to z ero feet AGL, rather than the local barometric pressure or field altitude, before each flight.
Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained UEE’s Aircrafts are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setti ng will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks Relief From Section 91.151 (b).15

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent r equired to allow flights of UEE’s Aircrafts which utilize battery power during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Unmanned Eagle Eye, LLC seeks the requested relief because withou t an exemption from Section 91.151(b), the flight time duration of UEE’s Aircrafts which utilize battery power will severely constrain the practicality of any aerial video or still photo flight operations that UEE proposes to conduct pursuant to this
Petit ion.
Significantly, as set forth below, the technical specifications of UEE’s Aircrafts operating documents, and Unmanned Eagle Eye, LLC ’s proposed operating limitations, ensure that UEE will safely operate UEE’s Aircrafts (battery powered) during dayligh t hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at l east 4.5 minutes.

5. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle Eye, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Unmanned Eagle Eye, LLC requests relief from these Sections because UEE’s Aircrafts do not require airworthiness certificates. As set forth more fully below, UEE’s Aircrafts meet the conditions of FMRA Section 333 for operation16

without an airworthiness certificate. Accordingly, Unmanned Eagle Eye, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the met hods, techniques, and practices prescribed in the UAS operating documents (i.e., the UEE Aerial Operations Manual, Monthly Maintenance Log, and UEE’s Aircrafts Instruction Manual s ). Furthermore, UEE will document and maintain all maintenance records for UE E’s
Aircrafts

.

D. The Reasons Why Granting Unmanned Eagle Eye, LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing Unmanned Eagle Eye, LLC to safely, efficiently, and economically perform aerial video and photography of special events, film sets, and landscape over certain areas of the United States.
Additionally, use of UEE’s Aircrafts will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Unmanned Eagle Eye, LLC’s proposed operation of UEE’s Aircrafts will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

UEE’s Aircrafts are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of UEE’s Aircrafts would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.17

Furthermore, by reducing the number of m anned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. UEE’s Aircrafts do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and ph otography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of UEE’s Aircrafts . Conducting aerial acquisitions with UEE’s Aircrafts , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operatio ns. By using battery power and electric motors, UEE’s Aircrafts produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aeri al video and photography, while burning approximately
20

- 30 gallons per hour of leaded aviation fuel. UEE’s Aircrafts , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.
By using UEE’s Aircrafts to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft fligh t operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, UEE’s Aircrafts (weighing max 9 pounds 1 5 ounces, at their maximum gross weights with max diagonal wheelbase of 3 5.5 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life18

and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,0 00 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With UEE’s Aircrafts Will Benefit The Economy.
In addition to being safe and efficient, UEE’s Aircrafts are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of UEE’s Aircrafts will allow United States based companies, like Unmanned Eagle Eye, LLC, to remain competitive and contribute t o growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technol ogy in order to remain competitive. Operating UEE’s Aircrafts is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditiona l manned aircraft.
By operating UEE’s Aircrafts , companies such as Unmanned Eagle Eye, LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through the commercial use of UEE’s Aircrafts , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.19

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Unmanned Eagle Eye, LLC proposed op eration of UEE’s Aircrafts will not implicate any privacy issues. Specifically, UEE’s Aircrafts will be operated only in compliance with operating documents (i.e., the UEE Aerial Operations Manual, Monthly Maintenance Log, and UEE’s Aircrafts Instruction M anual s ) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exempt ion Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Unmanned Eagle Eye. LLC Seeks Exemption. 1. Reasons Wh y UEE’s Aircrafts Meet The Conditions Of The FAA Moderniza tion and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Unmanned Eagle Eye, LLC operation of UEE’s Aircrafts meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:
(a) In General.

-- Notwithstanding any other req uirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.20

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) w hich types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmann ed aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establi sh requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Unmanned Eagle Eye, LLC submits that UEE’s Aircrafts can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of UEE’s Aircrafts ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The UEE’s Aircrafts Demonstrate Its Safe Characteristics. UEE’s Aircrafts do not create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The UEE’s Aircrafts . The technical specifications of UEE’s Aircrafts are set forth by U EE’s Aircrafts Specifications and Data Sheet, attached hereto as Exhibit A , Exhibit B, Exhibit C, Exhibit D, Exhibit E, and Exhibit F

.

ii. UEE’s Aircrafts Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.21

UEE’s Aircrafts may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of UEE’s Aircrafts are provided in UEE’s Aircrafts User Manual s .

iii. UEE’s Aircrafts Are Designed For Automatic Return To H ome Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost UEE’s Aircrafts will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, UEE’s Aircrafts does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.
A complete description of the Failsafe Functions of UEE’s Aircr afts are set forth in UEE’s Aircrafts User Manual s .

iv. UEE’s Aircrafts GCS And Its Operation. A complete description of the operation and specifications of UEE’s Aircrafts GCS and flight control software is provided in UEE’s Aircrafts User Manual s .

b. Flight Ope rations Of UEE’s Aircrafts Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Unmanned Eagle Eye, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilo t in command (PIC) of UEE’s Aircrafts

. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of UEE’s Aircrafts Will Be Conducted Pursuant To Specific Operating Limitations.22

In seeking this exemption, proposes to commercially o perate UEE’s Aircrafts for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: UEE’s Aircrafts Unmanned Aircraft System s . Proposed operations of any other aircraft will require a new petition or a petition to a mend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of n o more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visu al 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 airman medical certificate.
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbal ly at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or ot her instruments.23

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exem ption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents . The operator may update or revise its operating documents. 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 documen ts if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of e xemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 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 m ust be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacemen t of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.24

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft record s, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergenc y maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are p ermitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. 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 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under v isual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate with in 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a25

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. 21. 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. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal crui sing speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identi fication (N

Number) markings in accordance with 14 C.F.R. part 45,Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communi cations Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These26

d ocuments must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC fro m any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or struc tures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating pe rsons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. 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 Int egration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov27

2. Reasons Why An Exemption From The Requiremen ts Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Unmanned Eagle Eye, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate UEE’s Aircrafts unl ess that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate UEE’s Aircrafts in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Considering Unmanned Eagle Eye, LLC proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of c ommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate UEE’s Aircrafts , Unmanned Eagle Eye, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not c orrelate to the airmanship skills necessary for Unmanned Eagle Eye, LLC specific proposed flight operations.
The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Unmanned Eagle Eye, LLC will not allow any PIC to operate UEE’s Aircrafts unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or UEE’s Aircrafts UAS training and currency requirements, that the PIC is able to safely operate UEE’s Aircrafts in a28

manner consistent with this exemption, including evasive a nd emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Unmanned Eagle Eye, LLC proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting o perations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clar ification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also29

finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tra ining, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropri ate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Unmanned Eagle Eye will ensure safe operations by not allowing any PIC to operate UEE’s Aircrafts unless that PIC has demonstrated, by meeting minimum flight

- hou r and currency requirements, that the PIC is able to safely operate UEE’s Aircrafts in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Re asons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Unmanned Eagle Eye, LLC will ensure that UEE’ s Aircrafts are in an airworthy condition based upon the UAS’s compliance with its operating documents and as
stated in the conditions and limitations herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in cir cumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exempti on From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.30

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of UEE’s Aircrafts will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Unmanned Eagle Eye, LLC ’s operation of UEE’s Aircrafts within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatic ally established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 1 1067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of UEE’s Aircrafts ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Unmanned Eagle Eye will ensure that it will safely operate the battery powered UEE’s Aircrafts during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.
Here, as in Exemption No. 11109, the technical specifications of UEE’s Aircrafts ; the limitations on the proposed flight operations; and t he location of the proposed operations, will31

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as UEE’s Aircrafts provide audible and visual warnings to the PIC at the GCS when the UAs expe riences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, UEE’s Aircrafts will descend and land automatically.
Signifi cantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to thos e presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Secti ons 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Unmanned Eagle Eye, LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alterati on requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Unmanned Eagle Eye, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS u sing the methods, techniques, and practices prescribed in the operating documents (i.e., the Unmanned Eagle Eye Aerial Operations Manual, Monthly32

Maintenance Log, and UEE’s Aircrafts Instruction Manual s ). Furthermore, Unmanned Eagle Eye, LLC will document and maintain all maintenance records for UEE’s Aircrafts

.
Since UEE’s Aircrafts will be inspected as prescribed by the operating documents, Unmanned Eagle Eye, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of UEE’s Aircrafts User Manuals and
Mai ntenance L og is attached hereto.
Likewise, the exemption sought will not adversely affect safety because Unmanned Eagle Eye, LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.
Furthermore, the exemption sought woul d maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of UEE’s Aircrafts will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maint enance log.
Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limi tations of the UAS are considered.

In consideration of Unmanned Eagle Eye, LLC proposed operating limitations, the operating documents, and the technical aspects of UEE’s Aircrafts , Unmanned Eagle Eye, LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those33

presented herein (e.g . Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.
In accordance with Section 333 of t he FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Unmanned Eagle Eye, LLC requests that the FAA prescribe special conditions for the intended operation of UEE’s Aircrafts , which contain such safety standa rds that the Administrator finds necessary 32 to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any re quirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of UEE’s Aircrafts , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:
If the FAA finds that the airworthiness regulations of this sub chapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller34

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments there to for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that e stablished in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Unmanned Eagle Eye’s intended operation of UEE’s Aircrafts , which contain such safety s tandards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) , and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Unmanned Eagle Eye, LLC Seeks Exemption: Unmanned Eagle Eye, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Unmanned Eagle Eye, LLC Seeks: This exemption will permit Unmanned Eagle Eye, LLC to commercially oper ate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.35

G. Any Additional Information, Views, Or Arguments Available To Support Unmanned Eagle Eye, LLC Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Unmanned Eagle Eye, LLC request for exemption may be grante d pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to nati onal security; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Unmanned Eagle Eye, LLC will operate UEE’s Aircrafts safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Unmanned Eagle Eye, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which wil l permit safe operation of UEE’s Aircrafts commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also36

advancing the interests of the public, by allowing Unmanned Eagle Eye, LLC to safely, efficiently, and economically operate UEE’s Aircrafts commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Unmanned Eagle Eye, LLC respectfully requests that the Administrator grant this Petition for an exem ption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Unmanned Eagle Eye to operate UEE’s Aircrafts commercially for the purpose of cond ucting aerial video and photography over certain areas of the United States.

Dated: July 1, 2015
Respectfully Submitted.

Christian Michael Peters

_______________________________ Christian Michael Peters Unmanned Eagle Eye, LLC 203 Lago Circle Drive N. Santa Fe, Texas 77517 Phone: (281)

- 299

- 6490 Email: cpeters@UnmannedEagleEye.com37 APPENDICIES

A

– DJI S900 Manufacturer’s User Manual B

– DJI S1000 + Manufacturer’s User Manual C

– DJI Phantom 3 Manufacturer’s User Manual D

– DJI Inspire 1 Version 2.0 Manufacturer’s User Manual E

– 3DR Solo Manufacturer’s User Manual F

– Tayzu Robotics Quadra Manufacturer’s User Manual G

– Monthly Maintenance Log

APPENDIX

- A DJI S900 Manufacturer’s User Manual

APPENDIX

- B DJI S1000 + Manufacturer’s User Manual

APPENDIX

- C DJI Phantom 3 Manufacturer’s User Manual

APPENDIX

- D DJI Inspire 1 Version 2.0 Manufacturer’s User Manual

APPENDIX

- E 3DR Solo Manufacturer’s User Manual

APPENDIX

- F Tayzu Robotics Quadra Manufacturer’s User Manual38 APPENDIX

- G Monthly Maintenance Log

Christian Michael Peters Unmanned Eagle Eye, LLC 203 Lago Circle Drive N. Santa Fe, Texas 77517 Phone: 281

- 299

- 6490 Email: cpeters@UnmannedEagleEye.com39