519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

1 | P a g e April 12 , 2015

To : US Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 From : Paul Ramirez, President & COO
Unmanned Ad

- Hoc Industries, Inc.
519 E Oak Hill Drive Spring, TX 77386

- 1282 ( Submitted electronically to the Federal Docket Management System

- FDMS )

Re : Request for Exemption under section 333 of the FAA Reform Act

Summary of Exemption R equest

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and the Federal Aviation Administration’s general exemption authority under Title 49, United States Code, Section 44701(f),

Unman ned Ad

- Hoc Industries , Inc. (“UAI”) hereby petitions for e xemptions from the following Federal Aviation Regulations specified in Title 14 of the Code of Federal Regulations :

14 CFR Part 21 , Subpart H 14 CFR 45.23(a)

14 CFR 61.113(a)(b)

14 CFR 61.133 (a)

14 CFR 91.7(a)

14 CFR 91.109(a)

14 CFR 91.119(c) 14 CFR 91.9(b)(2)

14 CFR 91.121

14 CFR 91.151(a)(1) 14 CFR 91.203(a)(b) 14 CFR 91.319(a)(1)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

14 CFR 9 1.409(a)(1) (2)

14 CFR 91.417(a)(b)

These proposed exemptions, if granted, will allow UAI to operate their High Endurance Folding Frame (“HEFF”) Unmanned Aircraft System (“UAS”) and will benefit the following commercial ap p lications :

Agriculture, Oil, Gas, and Mineral Survey/ Scan

3

- Dimensional Terrain and Structural Modeling Disaster Response, including Emergency Search & Rescue Critical Infrastructure Monitoring , including Spectral & Thermal Analysis Security Awareness519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

2 | P a g e The HEFF UAS uses multiple, swappable onboard cameras to capture high definition imagery and video that may be translated into three dimensional models of a surveyed area

. UAI’s u se of the UAS will grant landowners, corporations, emergency response teams, and others an overall greater awareness

, heightened security, safety , as well as negate the need for conventional aircraft assista nce

. This results in enhanced efficiency for any activity conducted

, as well as an immediate environmental benefit.

Operation under the anticipated exemption will be subject to strict conditions and requirements

, ensuring at m inimum, an equivalent level of safety to currently authorized operating standards and procedures per FAA Regulations

.

Supplemental Information : The following information is to be submitted separately to assist the FAA in making an effective
evaluation:

Part A : Production Acceptance & Technical Specification of the High En durance Folding Frame (HEFF)

Part B : U nmanned Ad

- Hoc Industries, Inc. F light O perations and VLAUAS Guidelines

Part C : Operator and Observer Training Standard and Certification Example

Part D : HEFF Aircraft Logbook and Maintenance Reporting

Part E : UAI Summary of Ma nned and Unmanned Experience & Certifications

Background of Applicant

Unmanned Ad

- Hoc Industries , Inc.

Attn : Paul Ramirez
519 E Oak Hill Drive Spring, Texas 77386
Phone : (888) 396

- 5924, ext. 1
Email : Paul.Ramirez@globaluai.com

Unmanned Ad

- Hoc Industries was formed in 2014 to fill a clear need in the UAS commercial market for remote sensing applications

. UAI has assembled a group o f professionals each with over 9 years of
worldwide UAS experience in sa fety, flight operation s , project and site m anagement, engineering design, and system integration; bringing an unparalleled level of professionalism and safety experti se to

an emerging market

. UAI is strictly a services provider, and will not sell any of it s UAS components individually

.519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

3 | P a g e Aircraft Overview

The HEFF aircraft is of quad

- rotor design, based around a custom fabricated carbon fiber chassis

. Two lithium polymer batteries power four counter

- rotating electric motors in order to provide exceptional predictability, endurance, stability, and control

. In operational configuration, the aircraft weighs less
than 25 lbs and has dimensions of; length 31”, width 41”, and height 23”

. Maximum flight e ndurance is 45 minutes, while maximum limited airspeed is 60 knots

. Although highly maneuverable, the HEFF aircraft was designed with intent to hover in place primarily

. GPS utilization and redundant altimeter technology onboard the HEFF’ s flight controlling computer ensure a n accurate physical position is always ma intained while minimizing potential failures

. The aircraft, via its tablet computer Ground
Control Station, is capable of autonomous launch and recovery, as well as waypoint routing

. A handheld
remote control ler acts as the Operator’s direct line to aircra ft control, and is capable of initiating an automatic return home sequence

. Should Command and Control ( “ C2 ” ), data link, or battery level (20%) become jeopardized, the aircraft will automatically execute a pre

- programmed emergency seq uence

. Depending on the emergency, this may include hovering in place for a preset time , returning home on a planned route

, or landing autonomously.

UAI will require at least one company

- trained, FAA Ground School certified Operator and one company

trained Visual Safety Obs erver during operations in order to maintain positive physical and visual cont rol
of the aircraft at all times

. Because the HEFF is equipped with typical aircraft navigation lighting it is clear that the unmanned aircraft is more clearly visible during nig ht time conditions when compared to the ability to visually spot the vehicle during daylight hours

. For this reason UAI believes that by operating its
aircraft above 400 feet, near airports, or generally near populated areas in which people are not made

aw are and consent to unmanned operations will cause unacceptable safety risk and will not operate
within these conditions

. If granted exemption, UAI will yield right

- of

- way to all manned operations, as
well as file appropriate NOTAMs prior to any operations in the NAS.

Aircraft Lighting :

Forward & Aft Left : Red
Forward & Aft Right: Green

Atop Aircraft : Red Rotating Beacon
Below Aircraft : White Strobe519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

4 | P a g e Training

UAS Operator UAI requires every Operator to be fully qualified on its HEFF UAS appropriately

. Trainees are given demonstration in general skills such as; maintaining altitude, maintaining visual line of sight, general navigation principles, obstacle avoidance, air traffic de

- confliction, and emergency proced ures

. Qualification as an Operator for the HEFF UAS requires the Operator trainee to show proficient levels of all aforementioned skill areas, with special emphasis on emergency proce dure s

.

UAS Safety Observer UAI requires every person who will be acting as a flight safety observer to be proficient in airspace knowledge, emergency procedures, aeronautical chart interpretation and airspace safety, ground operations, ATC radio frequency communication . Two

- W ay radio communication will be established between the UAS operator and safety observer(s) during flight operations. HEFF Level 1 operator certification is the minimum standard for safety observer qualification.

Currency is maintained through monthly air craft flights and instruction

.

Authority for Petition

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a me thod for seeking expedited FAA authorization of safe, civil UAS operation in the National Airspace System (“NAS ”).

Section 333(a) states that th e Secretary of Transportation “shall determine if certain Unmanned Aircraft

S ystems may operate safely in the National Airspace S ystem before completion of the plan and rule

making required by Section 332 of this Act or th e guidance required by Section 334 of this Act. ”

Section 333(b) outlines any factors the Secretary of Transportation must consider in order to determine whether commercial UAS operation should be approved

. These factors include at minimum “[the UAS’s]

si ze, 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 [...] ”

Section 333 (c) states that sho uld the Secretary determine a certain UAS may operate safely in the NAS, “the Secretary shall establish requirements for safe operation of such aircraft systems in the National Airspace System.”

Section 44701(f) of Title 49, United States Code, states that “The [FAA] Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the Administrator finds the exemption is in public interest.”519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

5 | P a g e Explanations

14 CFR Part 21 , Subpart H : Procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthi ness approvals

Section 91.203(a)(1) requires all civil a ircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Giv en the size and weight of the HEFF
aircraft (25 lbs ) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meet s the requirements of an equivalent level of safety under Part 11 and Section
333 of the Reform Act. The Federal Aviation Act 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 UAS
involved.

In this case, an analysis of these cr iteria demonstrates that the HEFF operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an ai rworthiness certificate. The HEFF weighs 25 lbs fully configured . It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by b oth the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size
of the aircr aft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equ ivalent level of safety.

 Lightweight (< 25 lbs), small form factor aircraft

 Powered by sealed lithium polymer batteries, eli minating fuel spillage or risk of fire

 Remote crew location, eliminating risk in the event of an incident

 Waypoint/Route programming capability, ensur ing obstacle/obstruction avoidance

 Built in fail

- safe modes ( hover in place, return to home, autonomous la nding)

After consideration of the size, weight, speed, and limited operating area associated with the aircraft
and its operation, UAI believes exemption from 14 CFR Part 21 should be granted.519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

6 | P a g e 14 CFR 45.23(a ) : Display of marks; general

The HEFF does no t have an entrance to a cabin, cockpit or pilot station in order to place required markings. Due to the size of the aircraft, 2 inch lettering is not possible. The HEFF will have a 1” marking denoting its tail number which will achieve an equivalent level of safety as required by §45.29(f) in
which the pilot, observer, and others ground crew personnel attending to work on the aircraft will see each aircraft with a specific marking to denote aircraft serial number. Aircraft t o be flown will be registered in accordance with 14 CFR part 47.

UAI requests exemption be granted from 14 CFR Part 45.

14 CFR 61.113(a) and (b); 61.133(a) : Private pilot privileges and limitations ; Pilot in Command; Commercial Pilot Privileges and Li mitations

UAI’s intent:

 Provide UAS services over property only with permission from landowner

 Display appropriate warning signage on all borders of property during operation

 Maintain high level UAS airmanship skillset via UAI specified currency & training requirements

 Ability to achieve equivalent level of safety required by current regulations

 As o peration of UAS is fundamentally different than manned aircraft

, the current level of air and ground instruction of all aircraft operators (see Suppleme ntal Information, Part E ) is sufficient for safe UAV operations. A private pilot’s license does not apply to UAV operations and should not be considered as a minimal qualification to perform unmanned aircraft operations. Furthermore, a commercial pilot cer tificate as prescribed in Part 61.133 is outside the scope of the proposed unmanned aircraft operations as no carrying of persons or property will be performed.

UAI believes exemption from 14 CFR 61.113(a) and (b); 61.133(a) should be granted.

14 CFR 91.7(a) : Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there is no published standard for validating airworthiness condition of the HEFF aircraft, UAI will abide by internal company process documentation to validate operational functionality which will achieve an equivalent level of safety by ensuring compliance with all maintenance and inspection manuals (Supplemental Information, Part D ).

U AI believes exemption from 14 CFR 91.7(a) should be granted.519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

7 | P a g e 14 CFR 91.119(c) : Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altit ude 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.

An equivalent level of safety will be achieved given the size, weight, speed, and material with which the
HEFF is built. F light operations will not occur without the permission of the land owner /authorized agent or those who control the land. Because of the advance notice to the landowner, all affected indi viduals will be aware of the unmanned flight operations. Compared to aerial survey operations conducted with aircraft or rotorcraft carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conven tional aircraft operating at or below 500 feet AGL. T he low

altitude operations of the UAS will maintain separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

The ideal altitude for the projects proposed within this request will be at or below 400 feet above ground level and standard operational procedures will provide for a constant airspace awareness to allow for maximum separation between small UAS operations and operations of con ventional manned
aircraft. Additionally , UAI operators and observers will display appropriate warning signage on all perimeters of surrounding property while UAV operations are in progress.

UAI believes exemption from 14 CFR 91.119(c) should be granted, as an equivalent level of safety will be
achieved.

14 CFR 91.9(b)(2) : Civil Aircraf t Flight Manual in the Aircraft

The regulation requires that any person to operate a U.S.

- registered civil aircraft “[...] (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placar ds, or any combination thereof.”

Given the size of the HEFF, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on
the aircraft.

The equivalent level of safety will be achieved by kee ping the flight manual ( Supplemental Information,

Part A ) at the ground control point where the pilot flying the UAS will have immediate access to required flight manual documentation.

UAI believes exemption from 14 CFR 91.9(b)(2) should be granted, as an equivalent level of marking and
documentation will be achieved.519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

8 | P a g e 14 CFR 91.109(a) & 91.319(a)(1) : Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. In operational configuration, the HEFF is a remotely p iloted aircraft and does not have fully functional dual controls. Flight control is accomplished through the use of a control box or ground control station
that communicates with the aircraft via line

- of

- sight radio communications. The flight plan is pre

p r ogrammed into the auto pilot before or during flight and may also receive manual pilot input control functions to alter the pre

- programmed flight. If instruction is accomplished through a training program,
as set forth in Part C of the Supplemental Informa tion
, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental a ircraft ( 5778K & 9862A ) . The equivalent lev el of safety will be achieved by the manufacturer providing the training and through the use of experienced and qualified pilots familiar with the HEFF.

UAI believes exemption from 14 CFR 91.109(a) & 91.319(a)(1) should be granted.

14 CFR 91.203 (a) & ( b) : Carrying Civil Aircraft Certification and Registration

This regulation provides as follows : (a) [...] no person may operate a civil aircraft unl ess it has [...] an appropriate and current airworthiness
certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passenge rs or crew.

The HEFF when fully configured for flight operations weighs no more than 25 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot on board th e aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation.

UAI believes exemption from 14 C FR 91.203 (a) & (b) should be granted, as the regul ation is not applicable to its HEFF UAS

.519 E Oak Hill Drive, Spring , Texas 77 386

- 1282
Phone : 888

- 396

- 5924 • Email : info@globaluai.com

9 | P a g e 14 CFR 91.121 : Altime ter settings

Section 91.121 requires aircraft operators to maintain cruising altitude or flight level by reference to an
altimeter. As the HEFF U AS utilizes Global Positioning System and internal redundant barometric altimeters flight level will be determined using this type of instrumentation.

U AI believes exemption from 14 CFR 91.121 should be granted, as the regulation is not applicable

.

14 CFR 91.151(a)(1) : Fuel requirements for flight in VFR conditions

Due to the HEFF UAS being battery powered, UAI believes exemption from 14 CFR 91.151(a)(1) should be granted, as the regulation is not applicable.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a )(1), 91.409(a)(2), 91.417(a)(b) : Maintenance Requirements

Section 91.405(a) requires that an aircraft operator or owner “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 [...] ” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraf t for return

to service.

UAI has prescribed a specific process and inspection standard that will allow an equivalent level of safety
to be achieved as a result of diligent and consistent ly applied maintenance practices

. The aircraft operator is responsible for accurate status upkeep of the maintenance record to include the battery maintenance log , ensuring the UAS is in safe condition for flight operations, and ensuring all software is

curre nt prior to aircraft operation. Through this, UAI believ es exemption from the listed regulations should be granted.

Summary

UAI believes that a pproval from the FAA will enhance efficiency and safet y in any operation its HEFF UAS
conducts

, due to reducing the need for manned aircraft

. D ue to its camera

- only p ayload capability, lack of cargo, fuel or combustible materials in general, aircraft size, weight, and limited operating area, the

HEFF UAS presents no major risk to individuals, nor poses any threat to National Securi ty. While
adher ing to at least an equi valent level of safety of all current regulations, UAI firmly believes exemptions to the listed regulations should be granted, and operation of its HEFF UAS commercially should be permitted

.