1



## Pravia, LLC’s Petition for Exemption for the Event 38 E384

Unmanned Aerial System

FAA Rules Docket : _

__________

Submitted on 30 Sep 2014

Tim Ray, Managing Partner Scott Brink , Managing Partner

Pravia, LLC 555 Falcon Trail Niceville, FL 32578 Phone: 970

- 443

- 5475, 970

- 310

- 1712 Email: tim@pr aviallc.com, scott@praviallc.com2 

## Table of Contents

Petition Summary

................................ ................................ ................................ .... 3 Background

................................ ................................ ................................ ............. 3 Statutory Authority

................................ ................................ ................................ . 5 Basis for Petition

................................ ................................ ................................ ..... 11

Sites

................................ ................................ ................................ ......... Appendix A E384 Operations Manual *

................................ ................................ ..... Appendix B E834 Maintenance Manual *

................................ ................................ ... Appendix C Event 38 Training Syllabus *

................................ ................................ ... Appendix D

* Documents were submitted confidentially for proprietary reason s and will not be available to the pu blic3

A. Petition Summary
Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Pravia,
LLC (Pravia) request s exemption from the following Federal Aviation Re gulations that are found under Title 14 of the Code of Federal Regulations (CFR) : Part 21 Subpart H , 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401

- 91.417)

. Pravia seeks expedited approval an d exemption from the CFRs listed above in order to operate the E384 Unmanned Aircraft System ( UAS) for the purpose of providing high resolution aerial imagery to a domestic agricultural seed company

. Operation of the E384 by Pravia will follow strict operational limitations as outlined in this documen t and all recommendations by the
FAA.
B. Background 1. Pravia , LLC Pravia is a s cientific and technological services company located in Niceville, FL that provides research, analysis, monitoring , and reporting of geographic data captured via remote sensing payloads aboard manned , fixed wing aircraft. Pravia’s two managing partners have bee n in the aviation industry for 17 plus years and have more than 8 years of combined Military UAS experience. P r avia’s UAS background make s it an ideal candidate t o t ackle the unique challenges associate d w ith commercial UAS operations for precision agriculture. 2. E384 The E384 UAS is manufactured by Event 38 located in Akron, Ohio. The system consist of a lightwei ght battery operated aircraft, ground control station, and associated data link equipment. The E384 airframe is constructed of EPO foam with a carbon fiber4

tail and weighs 5.9 lbs. with a wingspan of 6.2 ft . and total length of 4.3 ft. The E384 is powered by two lithium polymer batteries that drive an electric propeller. It is hand launched, has maximum flight time of 100 minutes , and op erates at a cruising speed of 27 mph

. The ground control station consist of a Turnigy 9XR r emote and PC computer which have a maximum data link range of 5.4 NM. If the E384 lose s link with the ground control stati on or detects a low battery state at any time it will initiate a return

- to

- launch
sequence .

T he E384 has extensive flight experience and a history of operational success

overseas , including flights by over one hundred professional operators on 6 continents. It has been used in Uganda to survey potential land for the construction of a hydroelectric power plant. It has also been used in Greece by the National Technical Uni versity of Athens to study open

- pit mining. In Belize the Fishery Department s tarted routine flights with the E384 to track illegal fishing in protected waters. More recently i n the United States the E384 was flown over three days at the Cleveland Airshow, demonstrating its ability to safely integrate and operate in the NAS.5

For ad ditional information on the E384 , reference A ppe ndix B (E384 Operations Manual) and Appendix C ( E384 Maintenance Manual ), which specify manufacturing information, aircraft performance, operating limits, normal and emergency procedures, fail

- safe features, and maintenance and inspection procedures. C. Statutory Authority 1. FAA Modernization and Reform Act of 2012, Sec tion 333 Section 333 (a) states that the FAA “ shall determine if certain unmanned aircraft systems may operate safety in the national airspace system before completion of the plan and rul ema king required by Section 332”

. Section 333 (b) then lists several factors that should be considered in dete rmining which UAS ’ would be eligible for expedited integration into the National Airspace System (NAS)

. Specifically UAS ’ that “ as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation withi n visual line of sight do not create a hazard to the users of the national airspace system or the public, or pose a threat to national security”. If a UAS meets the criteria laid forth in Sec tion 333 (b), Sec tion 333 (c) then gives the FAA the authority to decide if an airworthiness certification as specified by Title 49 U nited States Code , S ection 44704 is even required for operation . Section 333 (c) specifically states that the FAA can determine “w hether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of T itle 49, United States Code, is required for the operation of unmanned aircraft systems ” . Thus , the FAA has the ability to allow a UAS that meets the criteria put forth in Sec tion 333 (b) to operate within the NAS without an airworthiness certification as long as the UAS does not pose any hazar d or threat to the NAS, public, and national security.6

2. How Pravia meets the criteria laid forth in S ection 333 Below are the criteria laid forth in Section 333 (b) and a detailed description of how Pravia meets ea ch of these criteria.

a. Size, Weight, and Speed The E384’s foam airframe weighs 5.9 lbs

. , has a 6.2 ft

. wingspan, length of 4.3 ft., and o perates at cruising speeds of 27 mph

. This small, lightweight aircraft that operates at relatively slow speeds will poses little to no hazard to people or structures on the ground , t hus making it an exponentially safer alternative to manned, fixed wing aircraft for aerial imaging.
b. Operational Capability The primary function of the E384 is to provide aerial imagery using one of
two interchangeable geo

- reference still cameras. H igh resolution data generated from these cameras offer a wide range of applications through analysis, such as biomass estimation, yield monit oring, leaf area indexing , and overall crop health. This information then helps companies maximize crop yields , which is of great benefit to the economy and the p ublic. The E384 is hand launched on

- site, requiring no runway for take

- off and landing and no transit to and from the site . Once airborne , the E384 will fly at an altitude of 400 ft

. AGL or less over th e designated agricultural plot

. Prior to flight, the Pilot in Command (PIC) set s a designated flight area and flight parameters to ensure that the E384 will remain within the confines of the approved site and not exceed a maximum altitude 400 ft

. AGL. If a critical issue such as a low battery
state or a loss of d atalink is detected at any time the E384 will immediately7

execute a return

- to

- launch sequence (Reference Appendix B )

. The E384’s small operational footprint and built

- in safety protocol provide a much sa fer alternative for aerial imaging and would pose a minimal h a zard to the NAS or public.

c. Proximity to Airports/Populated Areas The E384 will only operate over agricultural plots for the purpos e of collecting aerial imagery. There are 10 sites over which the E384 will be flown ( Reference C. 3.b. )

. All sites are owned and operated by a domestic agricultural seed company , which has already granted approval to Pravia to conduct E384 flights

. T here are a few small o ffice and mainte nance buildings located amongst the agricultural plots , and Pravia will ensure all E384 operations avoid overflight of these structures. In addition there are no commercial airports within 5 NM and no general aviation airports within 3 NM of any of the sites . The E384 will also operate at an altitude of 400 ft

. AGL or less , and as a result will be laterally de

conflicted from manned aircraft operations. By operating at low altitudes over agricultural plots , the E384 will pose no threat to individuals or structures on the ground and will remain well clear of any and all air traffic.
d. Visual Line of Sight (VLOS) The E384 will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (V MC) during da y - light hours. The
E384 will operate within 1 NM and VLOS of the PIC (and the Safety Observer positioned next to the PIC) at an altitude 400 ft

. AGL or less

. Th e Safety Observer will be responsible for ensuring that the E384 remains within VLOS at all times and will also assist in spotting potential hazards.8

3. Other Relevant Factors

a. Operational Limitations Pravia has established the following operational limitations for E384 flights over designated s ites.

o E384 f

lights are only p e rmitted over designated sites

o The E384 will operate at or below 400 ft

. AGL

o The E384 will operate within 1 NM and within VLOS of the PIC and Safety Observer

o The Safety Observer will be located next to the PIC and will ensure the aircraft remains within VLOS and assist in spotting potential hazards

o The E384 will operate in accordance with Day V isual Fl ight R ules and only in V isual M eteorological C onditions during daylight hours

o The d uration o f each E384 flight shall not exceed 100 minutes

o All take

- off and landings will occur on

- site in accordance with the E384 Operations Manual ( Reference Appendix B )

o E384 flights will avoid direct overflight of any office or maintenance buildings located on

- site

o All employees working on

- site will be thoroughly briefed on E384 operations prior to operations commencing

o E384 operations will be conducted by commercially certified pilots who have completed Event 38’s Training Program ( Reference Appendix D )9

o E384 flights will be c ancelled in th e event that any aircraft or ground control station equipment is inoperative or not fully functional

o If the PIC or Safety Observer spot a potential hazard, such as a manned aircraft within close proximity to the designated flight area, the PIC will immediately land the E384 and operations will only resume after the hazard is clear of the area

o All E384 maintenance will be accomplishe d in accordance with the
E384 M aintenance Manual ( Reference Appendix C )

o Only one E384 will be airborne at any given t ime for each designated site

o The PIC wil l file a NOTAM for E384 f light s at each s ite, providing at a minimum radial/DM E , radius, and a date/time group Pravia will be bound by these limitations for commercial flights after FAA approval of the exemptions laid forth in this petiti on. Pravia will also follow any guidance from the FAA in accordance with Sec 333 (c) which states that after determining if a UAS meets the criteria for safe operation that the FAA “shall [also] establish requirements for the safe operation of the” UAS in the NAS.10

b. Sites

There are 10 current sites that are owned and operated by a domestic agricultural seed company where E384 operations would be conducted. This
company has already granted approval to Pravia to conduct UAS operations at these locations. These sites are agricultural plots where crops are grown and monitored by scientist in an effort to increase crop efficiency and yield. A few small office and maintenance buildings can be found at several of these sites an d Pravia will ensure all E384 operations avoid overflight of these structures . In addition to this there are no commercial airports within 5 NM and no general aviation airports within 3 NM of these sites (Reference Appendix A for additional site information) As precision agricultural continues to grow there is the potential for additional sites that would require E384 operations for aerial imagery collection. In addition to seeking approval to operate the E384 at these 10 current sites, Pravia seeks approval to operate at future sites that meet the following criteria: 1) site is o wned and operated by the domestic agricultural seed company 2) site11 consists of agricultural plots, 3) no commercial airports ar e within 5 NM of the site, and 4) no general aviation airports are within 3 NM of the site. Pravia will also comply with any additional requirements or restrictions the FAA may have for E384 operations at these future sites.
D. Basis for Petition 1. Name and Address of the Petitioner Pravia, LLC 555 Falcon Trail Niceville, FL 32578 Phone: 970

- 443

- 5475, 970

- 310

- 1712 Email: tim@praviallc.com , scott@praviallc.com 2. Specific Sections of 14 CFR from which Pravia Seeks Exemption Below are the sections from which P ravia seeks exemption, with specifics on the

e xtent of relief sought, reason for relief, and why exemption would not adversely affect safety.

a. Part 21 Subpart H

– Airworthiness Certificatio n

Part 21 Subpart H establishes the requirements for the issuance of an airwor thiness certificate

. Pravia seeks complete exemption from Part 21 Subp art H pursuant with Section 333, which authorizes the FAA to exempt a UAS from the requirements o f an airworth iness certificate base d on consideration of the following: size, weigh, speed, operation al capability, proximi ty to airports and populated areas , and operation within VLOS

.12 An equal level of safety will be achieved with the o perational l imitations established in this document ( Reference B.3.a) for all Pravia E384 f lights. Specifically that all flights will occur within VLOS of the PIC and Safety Observe, at an altitude of 400 ft

. AGL or less , and only over designated agricultural plots . As a result the E384 can safely operate without creating a hazard to any other aircraft, people , or structures on the ground. The combination of the E384 ’s safe operational history overseas and small, lightweight airframe , in conjunction with Pravia’s pi lot requirement s and o perating limitations result in a safer alternative for aerial imagery collection.
b. 45.23 (b)

– Marking Requirements 45.23 (b) requires aircraft to display the r oman capital letter “N” with registration number and the words “restricted ”, “light

- sport”, “experimental”, or “provisional”, as applicable , on the entrance to the ca bin, cockpit, or pilot station in lettering that is between 2 in

. and 6 in

. in height. The E384 is unmanned and thus has no cabin, cockpit, pilot st ation, or entran ce on which these required markings could be displaye d. In addition Pravia may not have a registration number assigned by the FAA . As a result Pravia seeks full exemption from this regulation. Pravia will to the maximum extent possible comply with the location requirements of 45.27 (a) and the size requirements of 45.29 (f). Pravia specifically proposes to put the word “ EXPERIMENTAL ” in the largest lettering possible on the fuselage of the aircraft in accordance with 45.29 (f) “i f no surf ace authorized to be marked by 45.27 is large enough for full

- size marks, marks as large as practicable must be placed on the la rgest of the authorized surfaces”

.13

Pravia also proposes placing a flag at the g round c ontrol s tation with the words
“EXPE RIMENTAL UAS” in 3 in

. lettering. An equal level of safety would be maintained by displaying the word

“ EXPERIMENTAL ” on the fuselage of the aircraft and by placing a flag at the
g round c ontrol s tation with the words “EXPERIMENTAL UAS”

. Since the E384 will always be within VLOS of the P IC (positioned at the g round c ontrol s tation) and flown at a low altitude (400 ft

. AGL or less) the markings on the airframe and the flag located at the g round c ontrol s tation would allow all parties to v isually be infor med of the UAS’ operating status.

c. 91.7 (a)

– Civil A ircraft A irworthiness 91.7 (a) states that “n o person may operate a civil aircraft unless it is in an airworthy condition”. Pravia is already seeking exemption for airworthiness Certification (R eference D. 2

. a . ) and thus no FAA standard will exist for determining airworthiness. As a result Pravia seek s full exemption from this regulation. Pravia will achieve an equal level of safety by using E384 Operations Manual and Maintenance Manual (Appendix B and C ) which contain pre

- flight protocol for each flight, safety checks, and comprehensive maintenance procedures. In addition the E384 has already demonstrated the ability to fly safely in the NAS at the Cleveland Airshow, and thus is airworthy.
d. 91.9 (b)

– Civ il A ircraft F light M anual in the A ircraft 91.9 (b) states that no person may operate an aircraft unless there is a current approved flight manual for the aircraft onboard. The E384 ’s small and14 lightweight airf

rame is not physically capable of carrying an a ircraft f light m anual onboard. In addition to this the E384 is unmanned , and the PIC is located at the
g round c ontrol s tation. Pravia thus seeks exemption from the requirement to carry the a ircraft f

light m anual o nboa rd. Pravia instead proposes that the E3 84 Operations Manual (Reference Appendix B), which contain s information normally found in an aircraft flight manual, be kept at the g round c ontrol s tation where is readily assessable to the PIC and Safety Observer for reference. If it were physically possible for these required documents to be placed onboard the aircraft , the PIC and Safety Observer would have no means of accessing the information due to the fac t that E384 is unmanned with no aircrew onboard. Therefore an equal level of saf ety will be meet by keeping the E38 4 Operations M anual at the g round c ontrol s tation where it will be readily accessible (within arm’s reach ) to the PIC who is operating the aircraft, thus meeting the intent of the regulation.

e. 91.103

– Preflight A ction 91.103 requires that the PIC be familiar with specific information before each flight such as weather , forecast, and fuel requirements. In addition to this the
PIC must be familiar with information found within the approved f light m anual relating to aircra ft performance and take

- off and landing distances. Due to the fact that the E384 has no FAA

- approved f light m anual Pravia seeks exemption from this regulation. Pravia proposes to use the E384 Operations Manual ( Reference Appendix B) in lieu of an FAA

- appro ved f light m anual. T his publication has15

extensive pre - flight checklist s that include reviewing weather, battery requirements, take

- off and landing distances , and aircraft performance data. The information found in the E384 Operations Manual is c omparable to the information found in a FAA

- approved f light m anual, to include a comprehensive step

- by

- step pre

- flight checklist. As a result an equal level of safety will be maintained by the PIC using this publication , which addresses the items listed in 91.103. f. 91.109

– Flight Instruction 91.109 states that “no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls”. The
E384 is operated by the PIC through a ground control station that comm unicates with the aircraft via line of s ight (LOS) transmissions. The E384 by design does not have fully functioning dual controls and as a result Pravia seeks exemption from this regulation

. Exemption from this regulation requiring dual controls will not c reate a safety hazard because the E384 is unmanned and does not carry a pilot or
p assenge rs on board. In addition the E384 ’s small size and foam airframe is significantly less hazard ous to persons and structures on the ground than a manned , fixed

- wing aircraft

. Because the E384 ground control station consist of a
RX9 c ontroller and PC computer , it will be accessible to both the Instructor and Student at all times. The “controls” can in essence be passed back and forth between the Instructor and Student , achieving an equivalent level of safety as ha ving two sets of controls.16

g. 91.119

– Minimum Safe Altitude 91.119 establishes the minimum altitude that civil aircraft may safely operate at. 91.119 (c) specifically states that over “ other than congested areas ” a civil aircraft cannot operate below an “altitude of 500 feet above the surface, except over open wat er or sparsely populated areas (and) i n those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or
structure ”

. The sole function of the E384 is to fly at low altitudes over agricultural plots , which can be categorized as “other than congested areas”. Small UAS ’ , like the E384 , by design ar e typically flown at altitudes of less than 500 ft

. AGL and in close proximity to the PIC and Safety Observer to maintain VLOS. Pravia has established operating l imitations to achieve the highest level of safety, specifically that the E384 will not operate above 400 ft

. AGL and that the E384 will remain within VLOS of the PIC and Safety Observer. For these reason s Pravia seeks exemption from this regulation. An equivalent level of safety will be maintained by only operating the
E384 over d esignated s ites (R eference 3.C.b) . In addition the E384 ’s small size
and foam airframe i s significantly less hazardous to persons and structures on t he ground than a manned, fixed

- wing aircraft providing the same service. Also by
ope rating at an altitude o f 400 ft. AGL or less the E384 will be laterally de

conflicted from manned aircraft that are subject to this minimum safe altitude regulation and thus an equal if not greater level of safety will be maintained.17

h. 91.121

– Altimeter Settings 91.121 requires aircraft to maintain a cruising level or flight level in reference to a current reported altimeter setting. The E384 is not equipped with a programmable altimeter but rather determines location and altitude via an onboard
GPS

. Also since th e E384 will be operating at or below 400 ft. AGL, there is no need to maintain hemispherical cruising altitudes for de

- confliction with manned aircraft. For these reason s Pravia seeks exemption from this regulation. An equal level of safety will be achiev ed through the E384 ’s GPS , which provide s altitude and location data to the PIC via the ground control station

. The E384 Operations Manual specifically address es checking the GPS read

- out to ensure that it’ s within tolerance prior to commencing flight oper ations. This , combined with the fact that the aircraft’s altitude will be visually monitored by the PIC and Safety Observer , ensure s an equal level of safety is attained in lieu of referencing an altimeter setting. Furthermore by operating at or below 400 ft

. AGL the E384 will not create a hazard to any manned aircraft maintaining hemispheric crui sing altitudes based on a current altimeter setting. i. 91.151 (a)

– Fuel Requirements for Flight in VFR Conditions 91.151 (a) states that no person may begin a fligh t in Day VFR conditions unless there is enough fuel to fly to the intended landing point and fly for 30 minutes after that point is reached. The E384 is battery operated and does not carry fuel. It has a maximum flight time of 100 mi nutes on fully charged batteries

. Compliance with the regulation woul d leave the E384 with 70 minutes of flight18

time. 70 minutes of flight time would be sufficient enough to accomplish the task of imaging the designate agricultural plot but this restriction is not necessary due to the fact E384 has the ability to land anywhere. T herefore Pravia seeks full exemption from this regulation because the risk or danger associated with failing to reach a safe landing point with 30 minutes of extra “fuel” does not exist . The
E384 does not have to return to a “landing point” but rather can be safely put down anywh ere over the agricultural plot

. An equal level of safety will be ma intained simply by the fact that the
E384 is designed to safely land anywhere over the agricultural plot in the e vent that the b attery is exhausted. Any risk associated with battery duration (fuel) in relationship to flight time is mitigated by the fact that E384 has the ability to land anywhere and at any given time. j. 91.203 (a) & (b)

– Civil A ircraft: Certifications R equirements 91.203 requires all civil aircraft to have “within it...an appropriate and current airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that is legible to passengers or crew”. Pravia is a lready seeking exemption from the airworthiness certificate regulation and thus requires an exemption from this regulation. In addition t he E384 due to its size and design has no cabin or cockpit and therefore does not have the ability to affix or carry

ce rtification or registration documents. Furthermore the E384 does not carry any passengers or crew for whom the certificate is required to be d isplayed. Pravia proposes that any FAA

- req uired documents be kept at the g round c ontrol s tation19 and that a small p lacard be affixed to the E384 airframe with manufacture, registration, and contact information. An equal level of safety will be achieved by having any FAA required documents located at the g round c ontrol s tation where it will be readily accessible to the PIC and any other agencies th at may require the information. Having a placard attached to the E384 airframe will also allow any person or age ncies to be informed of the UAS’ origin and status.
k. Part 91 Subpart E (91.401
- 91.417)

– Maintenance, Preventative Maintenance, and Alterations These regulations provided the maintenance and inspections requirements in reference to Part 39 and Part 43. 91.405 (a) specifically states that “no person may perform maintenance, preventive maintenance, and alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, in cluding part 43 of this chapter”. Pravia seeks full exemption from these regulations due to
the fact that these sections apply to an aircraft with an airworthiness certif icate for which Pravia is already seeking exemption. An equal level of safety will be achieved by using the E384 Operations Manual (Reference Appendix B) and E384 Maintenance Manual ( Reference Appendix C ) which provide step

- by

- step instructions on regular and corrective maintenance . The PIC will be responsible for conducting maintenance in accordance with the se procedures . Any E384 maintenance that is not covered in these procedures will be performed by the manufacture r . Pravia will ensure that all maintena nce perfo rmed on the E384 by the PIC and manufacture r is20

documented in accordance with 91.407 (a) (1). Specifically that the records wil l include “a description of the work perf ormed; and the date of completion of the work performed; and the signature...of t he person approving the aircraft for return to service”. T he PIC will authorize the E384 for return to service for all maintenance covered in the E384 Operations Manual and Maintenance Manual and the manufacture r will authorize the E384 for return to service for all maintenance that is outside the scope of these two documents . Pravia will also ensure that no modifications or alterations are made to the airframe that affect the flight operating characteristics of the E384

. 3. How request benefits public as a whole The E384 is a safe, efficient, and an economical alternative to manned, fixed

wing aircraft that are currently being used to conduct aeri al imaging of agricultural plots

. There are a four major reasons why the p ublic would benefit from granting Pravia

exem ptions from these regulations. Authorizing E384 flights over designated sites would 1) reduce the number of manned aircraft in the NAS, 2) reduce air and noise pollution, 3) reduce the risk to life and property on the ground, and 4) increase agr icultural economic growth. Util izing the E384 in lieu of a traditional manned, fixed wing aircraft will result in the overall reduction of manned aircraft in the NAS. Thus there will be less aircraft that require control and coordination with Air Traffic C ontrollers (ATC)

. Because the E384 can take

- off and land on

- site and operate at an altitude of 400 ft

. AGL (or less) within VLOS of the PIC there is no need for ATC to provide coordination during ground, take

off, departure, transit, arrival, and landing p hases of flight. As the skies over the United21

States get busier and busier , any small effort to lighten the load of the Air Traffic Controllers would be of great benefit to the public.
At 5.9 lbs

. the battery operated E384 with an electric motor provides a much quieter alternative to manned, fixed

- wing aircraft. Traditionally a manned aircraft would have to transit from the departure airport to the desired site and fly at low altitudes to achieve high

- resolution imagery. The E384 will require no t ransit time , and the electric motor will be ex ponentially quieter than a twin

- engine combustion motor on passenger aircraft that is typically used to conduct aeri al imaging. In addition the E384 requires no fuel since it is battery operated. A manned aircr aft on the other hand typically burn s 20

- 30 gallons of aviation fuel per hour which is polluting the air not only over the site but over the path of transit and around the airport. Con ducting aerial imaging with the E384 in lieu of a manned aircraft would thus greatly reduce both air pollution and noise pollution which is of great benefit to the public. Using the E384 would also greatly reduce if not completely eliminate the risk to life and property on the ground. The E384 ’s incredibly small size, reduced weight, and foam airframe pose no hazard to people or structures on the ground as opposed to a manned twin engin e - passenger aircraft which has a much greater potential for collat eral damage. In addition the E384 is unmanned and as a result the risk associated with piloting this aircraft is non

- existent. Overall the E384 provides a much safer alternative to manned, fixed

- wing aircraft operations for the purpose of collecting aerial imagery. Lastly using the E384 to provide aerial imagery would resul t in agricultural economic growth. High

- resolution data generated from E384 flights would provide scientist s with invaluable information on biomass estimation, yield monitoring, leaf area22

indexing, and overall crop health. By analyzing this data sci entist s can make modifications to a wide range of variables that will maximize crop yields

. More efficient crops would allow the U

. S

. to generate more food for stateside consumption but also increase the amount of crops that can be exported to foreign countries. The major increase in economic growth in the agricultural industry would energize the U

. S

. economy , which in turn would be of great benefit to the public. 4. Additional information, views, and arguments The following documents have been included as Appendices to this Petition. Appendix B, C, and D have been submitted confidentially for proprietary reasons and will not be available to the public.

o Sites (Appendix A)

o E384 Operations Manual (Appendix B)

o E384 Maintenance Manual (Appendix C)

o Event 38 Training Syllabus (Appendix D) 5. Summary for Federal Register
Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Pravia, LLC requests exemption from the following Federal Aviation Regulations that are found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H , 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401

- 91.417) . Exemption from these regulations would allow Pravia, LLC to operate the E384 Unmanned Aerial System over a domestic agricultural seed company’s sites for the purpose of providing high

- resolution aerial imagery of agricultural plots.