U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 20590 July 1, 2015 Re: Section 333 ExemptionRequest

Dear Sir or Madam: 

## FLYING LION

Pursuant to Section 333 oftheFAA Modernization and Reform Act of2012 (the "Reform Act"), Flying Lion, Inc. ("Petitioner") hereby applies for an exemption from the Federal Aviation Regulations ("FARs ")described in Section VII below, a Certificate ofWaiver and Authorization ("CO

### A'') and any other exemptions necessary to allow the Petitionerto operate the small Unmanned Aircraft Systems ("UAS") described in Section IV for commercial aerial data collection purposes, as more fully described in Section IX below. I. Background on Petitioner Petitioner is a provider ofon-demand aerial assessment, imagery and illumination services to Law Enforcement and Emergency Services. The company's innovative use ofa mobile command center for localized air support creates a unique solution for aerial support for public safety organizations with limited staffand budget. IT. Contact Information The contact information for Petitioner is set forth below: Barry J. Brennan, CEO Flying Lion, Inc. 2514 Gates Ave. #B Redondo Beach, CA 90278 http:/ lflyinglioninc.com/

www.flyinglioninc.com 2514 Gates Avenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.com

### III. Request for Exemption to Use UAS to ProvideAerial SupportForEmergency Responders Petitionerproposes to use UAS under controlled conditions to provide aerial illumination, video data (both Hi-DefandFLIR) and Haz-Mat detection for public safety incidents or events. The data collection will be conductedto assist Public Safety agencies in providing aerial observation and assessment. The Petitioner also requests the right to utilize the UAS for other commercial purposes thatrequire aerial data collection, (i.e. pre/post disaster imaging, and the status offixed assets in the telecommunication and energy industries. In each case aerial data collection will be conducted under the conditions set forth herein and the Section 333 exemption grant. In that regard, the airspace will be (i) limited, (ii) predetermined, and (iii) controlled as to access. Petitioner will limit operations to the area immediate above and directly adjacent to the incident or circumstances that affect Public Safety. Operations will always occur within the line ofsight ofthe UAS operator. Petitioner will take steps to protectthe privacy ofthe property owners and nearby individuals. Given the potential for this exemptionto lead to developments that will save lives, emergency resources, andproperty, the Petitionerrequests thatthis request for exemption be considered on an expedited basis. In that regard, Petitionernotes thatthe FAA has previously granted exemptions for similar activities for the Altura Zenith ATX8, the Dn Phantom and the Dn Inspire. All these systems are used bythe Petitioner. 

### IV. Unmanned Aircraft Systems A. Aerialtronics Altura Zenith ATX8

The AlturaZenith ATX8 is a multi-rotor aircraftbuilt with a monocoque carbon airframe. The Zenithhas a 5.6 kgtake-offweight and a maximumpayload of2.9 kg. The Zenith carries a 16.600 mAh battery, which facilitates up to 45 minutes offlight-time. Itcan be flown with either a radio ortablet and carries a variety ofpayloads. The Zenith has a maximum cruise speed of20 m/s. It features auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. Specifications include:

• Length x Width: 23.6" x 23.6" • Height: 13. 7"- 21.6" tall • Weight: 7.7 lbs., withoutpayload (less than 15 lbs. withpayload) B. DJI Phantom

The DJI Phantom is a multi-rotor copterthatthat will weigh less than 55 lbs. when fully loaded. It will be operated at a maximum speed ofless than 50 mph and a flight time ofno more than 20 minutes. Ifits communications withthe PIC is lost, the safety system will allow it to either hover inplace and slowly descend orto return to a predeterminedpoint. C. DJI Inspire

The DJI Inspire is a multi-rotor copterthat will weigh less than 55 lbs. when fully loaded. Itwill be operated at a maximum speed ofless than 50 mph and a flight time ofno more than 20 minutes. Its safety system will allow it to eitherhover in place and slowly descend if communication with the PIC is lost orto return to a predetermined point. 

### V. StatutoryAuthority for Requested Exemptions This petition for exemption is submitted in accordance with Section 333 ofthe Reform

www.flyinglioninc.com 2514 GatesAvenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.comAct. Pursuantto Section 333 ofthe Reform Act, the Federal Aviation Administration (FAA) Administrator (the "Administrator") is to permit operation ofan unmanned aircraft system where it does not create a hazard to users ofthe national airspace system (NAS) orthe public orpose a threatto national security. Moreover, the Federal Aviation Act grants the Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides such a requested exemption is in the public interest. See 49 U.S.C. §§ 106(£), 44701-44716, etseq. A party requesting an exemption must explain the reasons why the exemption: (i) would benefit the public as a whole, and (ii) would not adversely affect safety or how it wouldprovide a level ofsafety at least equal to the existingrules. 14 C.F .R. § 11.81. 

### VI. Safety Measures and PublicInterestBenefits As described in more detail in Section IX, the Petitioner will take measures to ensure such operations will not create a hazard to aviation orthe public. Flights will be conducted under 400 feet AGL thereby avoiding interference with users ofthe NAS. Flights will be suspended immediatelyto yield right-of-way to any other aircraft. Gee-fencing will be utilized when available to ensure that a UAS does not fly outside ofthe intended area. The site will be secured and only authorizedpersonnel will be permitted onthe grounds. Given the size and speed ofthe UAS, the controlled nature ofthe locations being used and the lack ofexplosive materials orflammablejetfuels, the operations will not pose a threatto national security. There are a number ofreasons why granting the Petitioner's request to operate the UAS for the assistance ofPublic Service Agencies is inthe public interest. For example, use ofUAS in this manner will make conditions for law enforcement, fire/rescue and otherpublic service agencies representatives safer. Today most agencies do not have access to aerial observation services. Such activities are inherently dangerous and this provided service will allow for better assessment ofthe situation and allocation oflimitedresources. Public safetypersonnel will be able to reduce their exposure to many life threatening hazards byusing a UAS. In addition, they will be able to obtainthe data necessary to make accurate assessments more quickly. Similarly, utilization ofUAS to pre/post disaster inspect construction, telecommunication and energy physical assets will result in enhanced safety for individuals, cost savings and greater efficiencies in large and critical industries. 

### VII. Specific Sections from Which Petitioners Seek an Exemption Based upon the informationprovided and the exemptions that the FAA has already granted pursuantto Section 333, the Petitionerrequests the following exemptions: 

### 14 C.F.R. 

### § 61.113(a) 14 C.F.R. 

### § 61.23(a) 14 C.F.R. 

### § 61.23(c) 14 C.F.R. 

### § 61.101(e)(4) 14 C.F.R. § 

### 61.101(e)(S) 14 C.F.R. 

### § 61.113(a) 14 C.F.R. 

### § 61.315(a) 14 C.F.R. 

### § 91.7(a) 14 C.F.R. § 

### 91.119(c) 14 C.F.R. 

### § 91.121 14 C.F.R. 

### § 91.151(a) 14 C.F.R. 

### § 91.405(a) 14 C.F.R. § 

### 91.407(a)(1) 14 C.F.R. 

### § 91.409(a)(l) 14 C.F.R. 

### § 91.409(a)(2) 14 C.F.R. 

### § 91.417(a)

www.flyinglioninc.com 2514 Gates Avenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.com14 C.F.R. § 91.417(b) Vlll. Justifications for Each Exemption Request 1. 14 C.F.R. 

### § 61.23(a), 14 C.F.R. 

### § 61.23(c), 14 C.F.R. § 61.101(e)(4), 14 C.F.R. § 61.101(e)(5), 14 C.P.R. §61.113(a) and_14 C.F.R. 

### § 61.315(a). Petitionernotes that FAA is nowrequiring the Pilot in Commandto hold either an airline transport, commercial, private, recreational or sport certificate pilot license and either a currentFAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. Petitioner will ensure that its PICs will satisfy each ofthese requirements. Since Petitioners' PICs will be operating UAS underthe same conditions as those previously granted, an equivalent level ofsafety will be metby granting these exemptions. 2. 14 C.F.R. §91.7(a) Civil aircraft worthiness. Section 91.7(a) requires that an operator determine an aircraft is in airworthy condition before a flight. Petitioner requests relieffrom this section provided thatthe operator ofthe UAS determines priorto each flight thatthe aircraft is in compliance with the applicable Operational Documents. Such pre-flight inspection will provide the equivalent level ofsafety as thatprovided bythis section. Petitionernotes that the Administrator has granted relief from this section in previous exemptions. 3. 14 C.F.R. 

### § 91.119(c) Minimum safe altitudes over congested and other areas. Section 91.119( c) establishes safe altitudes for operation ofcivil aircraft over areas other than congested areas. The Petitionerrequests**reli~f**from this section withrespect to those participatingpersons, vehicles, and structures directly involved with emergency situation. The UAS will never operate athigher than 400 AGL. 

### It will be operated in a limited area, Relieffrom this section is warranted as operations will be conductedwith adequate safety provisions as outlined herein and in the applicable Operational Documents. As a result, an equivalent level ofsafety will be met by granting this exemption. Petitionernotes thatthe Administrator has granted relieffrom this section inprevious exemptions. 4. 14 C.F.R. 

### § 91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

... to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." An exemption from section maybe needed ifthe UAS does not have a barometric altimeter but instead has a GPS altitude read out. An equivalent level ofsafety will be achieved bythe operator, pursuantto the applicable Operational Documents, confirmingthe altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitioner notes thatthe Administrator has granted relieffrom this section in previous exemptions. 5. 14 C.F.R. 

### § 91.151(a) Fuel requirements for flight in VFR conditions. Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under

www.flyinglioninc.com 2514 Gates Avenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.comVPR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly after that for at least 30 minutes." Complying withthe 30 minute reserve would severely limitthe length ofthe Petitioner's UAS flights and hamperthe ability to provide aerial supportto emergency situations. Given the limitations onthe UAS's proposed flight area, a longertime frame for flight is reasonable. Operating the UAS in a tightly controlled area, does notraise the type ofrisks thatthis section was intendedto address, particularly given the size and speed ofthe UAS. Petitionerbelieves that an equivalent level ofsafety canbe achieved bylimiting flights to 50 minutes or20% ofbattery power, whicheverhappens first. 6. 14 C.P.R. 

### § 91.405(a) Maintenance required; 14 C.P.R. 

### § 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 C.P.R. 

### §§ 91.409(a)(l) and (2) Inspections: 14 C.P.R. 

### §§ 91.417(a) and (b) Maintenance records. Maintenance will be accomplished bythe operatorpursuantto the applicable Operational Documents. An equivalent level ofsafety will be achieved because the UAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise, the UAS will be operating from no higherthan 400 feet AGL and can immediately land. As provided in the applicable Operational Documents, the operatorwill ensure thatthe UAS is inworking orderpriorto initiating flight, perform required maintenance, and keep a log ofanymaintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintainthe aircraft in an airworthy conditionto provide the equivalent level ofsafety. As a result, an equivalent level ofsafetywill be met by grantingthis exemption. Petitioner notes thatthe Administratorhas granted relieffrom this section in previous exemptions. 7. Additional Relief. In additionto the exemptions listed above, the Petitionerrequests exemption from such other rules andregulations as the PAA deems appropriate to enable the operations described herein. Since previous exemptions granted under Section 333 ofthe Reform Acthave been effective for two years, the Petitioner also requests that ifthe PAA issues interim or final rules applicable tothe operation ofanyUAS included herein after the Petitionerreceives a Grant ofExemptionthat any conditions and limitations required in such Grantthat are more burdensome than the newregulation be appropriately modified orremoved. IX. Operating Parameters for UAS Use Petitionerproposes that ifthe requested exemptions are granted, itwill operate the UAS underthe following conditions: 1. UAS operations will be conductedby a Pilot in Command (PIC). The UAS will be in visual line ofsite (VLOS) ofthe PIC at all times. 2. All UAS operations will utilize a visual observer ("VO"). The VO will notperform any other duties beyond assisting the PIC with seeing and avoiding airtraffic and other ground-based obstacles/obstructions. 3. The PIC and VO will be able to communicate verbally at all times.

www.flyinglioninc.com 2514 Gates Avenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.com4. Petitioner will rely on the UAS vendor(s) to provide a pilot qualification program, including a training program incorporating proper aircraft operations and safety standards. The PIC and the VO will have obtainedthe necessary qualifications/training. A record ofcompletion ofthis qualificationprocess will be documented and made available to the Administrator upon request. 5. UAS will not be flown at ground speeds exceeding 50 mph. 6. Flights will be operated at an altitude ofno more than 400 feet above ground level. 7. Each UAS flight operation will be completed within 50 minutes flight time orwith 20% batterypowerremaining, whichever occurs first. At 30% battery the UAS will enter a return and land sequence; at 20% it will land immediately. 8. UAS will notbe operated over any person (otherthan participatingpersonnel) at an altitude that is hazardous to persons orproperty onthe surface in the event ofa UAS failure oremergency. UAS will be operated at a distance from participating buildings ofat least 10 feet. Operations will be conducted atleast 500 feet from nonparticipating persons orbuildings, unless barriers are in place to provide adequate protection. 9. The UAS will abort the flight in the event ofunpredicted obstacles oremergencies in accordance withthe applicable Operational Document. 10. The UAS will remain clear and yield the right ofwayto all other manned operations and activities at all times. 11. The UAS will not be operated bythe PIC from any moving device orvehicle. 12. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 13. The applicable Operational Documents and all documents required under 14 C.F.R. 

### § 91.9 and 91.203 will be available to the PIC atthe Ground Control Station ofthe UAS anytime the aircraft is operating. These documents will be made available to the Administratorupon request. 14. Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to theNational Transportation Safety Board (NTSB). 15. The operator will follow the procedures as outlined in its applicable Operational Documents. 16 Priorto each flight, pilotwill inspect the UAS to ensure it is in condition for safe flight. Ifthe inspection reveals a discrepancy, the aircraft will be prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight.

www.flyinglioninc.com 2514 GatesAvenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.com17. All maintenance and alterations will be properly documented in the aircraft records. 18. AnyU S thatundergoes maintenance oralterations that affect the UAS operation or flight characteristics will undergo a functional flight test in accordance with the applicable Operational Documents. 19. Petitioner will institute a rigorous maintenance program to ensure airworthiness ofthe UAS. Operatorwill follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 20. Each UAS will comply with all manufacturer Safety Bulletins. X. Summary to be Published in Federal Register Petitioner: Flying Lion, Inc. Sections of 14 C.F.R. Affected:§ 61.23(a); § 61.23(c); § 61.101(e)(4);§ 61.101(e)(5); §61.113(a);, 61.315(a); § 91.7(a); § 91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and 

### (b). Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.P .R. § 61.23(a); 14 C.P.R. § 61.23(c); 14 C.P.R.§ 61.101(e)(4); 14 C.P.R. § 61.101(e)(5); 14 C.P.R. §61.113(a);_14 C.P.R.§ 61.315(a); § 91.7(a);14 C.P.R.§ 91.119(c); 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to conduct inspections for commercial purposes using small unmanned aircraft systems (UAS) subjectto operatingprocedures that meet orexceed those that FAArequires for similar operations. 

### XI. Conclusion Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Actregarding size, weight, speed, operating capabilities, proximityto airports and populated areas, operation within visual line ofsight, and national security, provide more than adequatejustificationfor the grant ofthe requested exemption allowing operation ofPetitioner's UAS for the purposes set forth herein. Please contact Petitioner, Barry

### J. Brennan at 310.722.1550 or bb@flyinglioninc.com with any questions aboutthis filing.

Sincerely,

Barry J. Brennan CEO Flying Lion, Inc.

www.flyinglioninc.com 2514 Gates Avenue #B, Redondo Beach, CA 90278 Tel: 310-722-1550 Email : bb@flyinglioninc.com