## us Deporrmenl of Tronsponolioo Fede r al Aviation Administration

June 29 , 2015

Charles Roberts 2090 Brush Grove Road Rochelle , 

### JL 61068 D ear Mr. Roberts: 800 Inde pe n de nc e Ave
. S W Wa sh•nglon DC 20591

This letter is to infonn you that we are unable to process your request for an exemption from Title 14 , Code of Federal Regulations ( 14 CFR)

. It explains why we can not process your request and what you should do in the next 30 days. 

### Wh y We Can Not Process Your Reque st We entered your J une 25,2015, exemption request into the public docket (No. FAA-2015- 2178) , but we are unable to process your request any further. The information you sent does not comply with the requirements of§ 11.81 (copy enclosed). For us to consider the request any further , you must send us all of the following:

• The specific section or sect io n s of 14 CFR from which you seek relief , the extent of the relief you seek, and the reason you seek relief.

G The r e asons why granting the request would be in the public interest; that is , how it would benefit the pub lic as a whole

.
• The reasons why the exemption wou ld 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 you seek an exemption.

• Any additional infonnation, vi ews, or arguments available to sup port your request. 

### Wha t Y ou Should D o If you 'vant us to process your request any fu11her , you must send the information described earlier to reach us within 30 days. Please note that 

### § ll.63(d ) requires you to send your petition for exemption at least 120 days before the proposed effective date of the exemption.If We Do No t Hear F rom You 

### If we do not hear from yo u within 30 days , we will close the docket without notifying you further. If yo u have any questions or r eq uire additiona l time, yo u may ca ll (202) 26 7-9677

. Sincerely ,

Brenda 

### Robeson Program 

### Analyst , Airmen 

### and

Airspace Rules Division Enclosure 2August 12 , 2015 Brenda Robeson Program Analyst, Airmen & Airspace Rules Division US Department of Transportation Federal Aviation Administration 800 Independence Avenue SW Washington DC 2059 1 Re: Response to your letter dated 6/2 9/2015 Dear Ms. Robeson: Attac hed is my response to your letter dated 6/ 29/2015 (also attached). Sincere ly,

Charle s C. Roberts , Jr. 2090 Brush Grove Rd. Rochelle, IL 61 068Charles C. Roberts , Jr. requ es ts exemption from the requirements of 14 C.F.R Sections 6 1. 113(a) & (b), 91.7(a), 9 1.1 21, 91.151(b) , 91.405(a), 91.407(a)(l) , 9 1.409(a)(l) & (a)(2), and 91.417(a) & (b) , and permit Charles C. Roberts, Jr. to operate prop erty s urveys in the Un ited States, as fo ll ows. Charles Robert s seeks relieffrom Section 6l. ll 3(a) and (b), entitled "Private Pilot Privileges and Lim itations: Pilot in Command (PIC) " : Charles Roberts states that safety will not be compromised because th e PIC will be thoroughly trained in the operation ofthe UAS which includes severa l hours of flight operation, training in sa fe ty procedures according to the manufacturer ' s manua l , and training in the fai l safe system provided by the UAS manufacturer. The operator wi ll be in good physical condition. T he u sage of the UAS wi ll be incidental to the bu s iness of Charles Roberts and will not carry passengers. Charles Robert s seeks re lief from Section 91.7(a) entitled "Civil Ai rcraft Airworthiness": Charles Robert s states that prior to each usage , the UAS will be tested to insure an airworthy condition as per the manufacturer's manual. T he UAS does not require an a irworthines s certificate in accordance with C.F .R. Part 21 , Subpart H , as it is in compliance with the operatio n manual prior to eac h usage and has satis fi ed any maintenance related questions. Charles Roberts seeks re li ef from Section 91. 1 2 1. e ntitled "Altimeter Settings": Cha rles Roberts states that the UAS zero altitude will be set at the launch s ite rather than at a loca l barometric pressure in s trument before each u sage. FAA requires reporting altitude information on UAS operation , but the altitude reading wi ll not have the same reference as that from a local barometric pressure instrument. Since the flights are of li mited altitude, relief is requested because altitude settings are reset at launch and an eq uival ent level of safety wi ll be achieved from usage of the onboard UAS barometric pressure se nsing system. Char les Rob ert s seeks relief from Section 91.151 (b). entitled "Fuel Requ irements for Fli g ht in VFR Conditions": C harle s Rob erts states that battery powered flight of approximately 10 minutes during daylight hours in VFR cond itions is the capability of UAS. The 20 mi n ute ad ditional flight time requirement cannot be achieved with s uc h a UAS because of limited battery capacity. Consequently, relief is so ught. Charles Roberts seeks relief from Sections 9 1. 405(a), 9 1.407 (a)(l), 91.409(a)(l) & (a)(2), and 9 1. 4 17(a) & (b): Charles Roberts states that the above sections refer to aircraft with an airworthiness certificate. The UAS does not require an airworthiness certificate. Consequentl y , relief is soug ht. Charles Roberts will be using trained technicians to perform maintenance on the UAS as we ll as document the maintenance.Reasons it would benefit the public for allowing relief for Charles Roberts: Granting the request wi ll benefit the public interest by allowing Charles C. Rob erts, Jr. to perform aerial s urv eys of farm fields which result in increased productivity, increased farm crop yields and more food available to soc ie ty . Grantin g the request will benefit the public interest by allowing Charles C. Roberts , Jr. perform aerial surveys of buildings which will result in decreased congestion in the air space , reduction in pollution s ince internal combustion eng ine aircraft will not be u sed , reduced noise pollution , increased safety since the mass of the ve hi cle is very low and reduced cost of building analysis. The battery powered UAV w ill save several gallons of aviatio n fuel when compared to a conventional manned aircraft. The UAV weighs less than 3 pounds , reducing the chance of damage to lif e and property when compared to a severa l thousand pound manned a ircraft and crew. The UAS will benefit th e economy, will offer g reater fl exibility for close in analysis of the s ubj ect property, with s ig nifi cantly reduced cost over manned aircraft.