UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Chesapeake Bay Helicopters, Inc. 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) CONCERNI NG COMMERCIAL OPERATION OF THE DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on May 8, 2015 \2 TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS .................................................................................3

SUMMARY ....................................................................................................................... ..4

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

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

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

NAME AND ADDRESS OF PETITIONER...................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHESAPEAKE BAY HELICOPTERS, INC. SEEKS EXEMPTION...............................................................8

THE EXTENT OF RELIEF CHESAPEAKE BAY HELICOPTERS, INC. SEEKS AND THE REASON CHESAPEAKE BAY HELICOP TERS, INC. SEEKS THE RELIEF..11

THE REASONS WHY GRANTING CHESAP EAKE BAY HELICO PTERS, INC.’S REQUEST WOULD BE IN THE PUBLIC INTEREST ..............................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ................................................................................17

SUMMARY THAT CAN BE PUBLISHE D IN THE FEDERAL REGISTER............32 ANY ADDITIONAL INFORMATION, VI EWS, OR ARGUMENTS AVAILABLE TO SUPPORT CHESAPEAKE BA Y HELICOPTERS, INC.’S REQUEST......................................................................................................................32

CONCLUSION.................................................................................................................333 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization C.F.R. Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation FCC Federal Communications Commission GCS Ground Control Station GPS Global Positioning System NAS National Airspace System NOTAM Notice to Airmen PIC Pilot In Command Section 333 FAA Modernization and Re form Act of 2012 (FMRA) Section 333 SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Sight VMC Visual Meteorological Conditions VO Visual Observer VTOL Vertical Takeoff and Landing4 SUMMARY CHESAPEAKE BAY HELICOPTERS, INC. se eks 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 op erate an Unmanned Aircraft System pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit CHESAPEAKE BAY HELICOPTERS, INC.to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conduc ting aerial data acquisitions within the National Airspace System (NAS) including, but not limited to th e following industries; ag riculture, oil and gas, aerial photography, wildlife preser vation, filming for TV or movie production, and utility inspection.

INTRODUCTION AND INTERESTS OF THE PETITIONER CHESAPEAKE BAY HELICOPTERS, INC. (herei nafter referred to as “CBH”) provides manned helicopter-mounted advanced aerial data capture technologies, as well as manned helicopter-based construction and support servic es under FAR Part 133, which enable companies to operate more efficiently and achieve competiti ve advantages in their respective markets.

BACKGROUND Unmanned Aircraft System: DJI Inspire 1 UAS

CBH seeks an exemption to operate the DJI Inspire 1 UAS (Inspire 1 UAS) for compensation or hire within th e National Airspace System (N AS). The Inspire 1 UAS is comprised of a vertical takeoff and landing (VTOL or helicopter) Unmanned Aircraft (UA) and a transportable Ground Control Statio n (GCS). The Inspire 1 UA has: a maximum gross weight of approximately 6.5 pounds; approximat e dimensions of a length of 17 inches, width of 18 inches, and height of 12 inches; and maximum speed of approximately 43 knots. The Inspire 1 UA is5 equipped with four rotors, each driven by a Li thium Polymer battery powered electric motor. Complete technical data is contained w ithin the attached manufacturer’s manuals.

The Inspire 1 UA that will be operated by CBH 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, Chesapeake Bay Helicopters, Inc., pu rsuant to the provis ions 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 petitions the Administrator to commercially operate the Insp ire 1 UAS within the Na tional Airspace System (NAS), and for an exemption from the require ments 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).

In consideration of the size, weight, speed, a nd limited operating area associated with the unmanned helicopter and its ope ration, CBH’s operation of the Inspire 1 UAS meets the

conditions of FMRA Section 333 an d therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, CBH 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 se t forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

CBH submits that the requested relief is proper since an equivalent level of safety will be ensured. CBH will perform maintenance, altera tions, or preventive maintenance on the UAS6 using the methods, techniques, and practices prescr ibed in the current operating and maintenance documents (i.e., the Inspire 1 UA S User Manual, the Inspire 1 Maintenance Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, the Intelligent Flight Battery Safety Guidelines), or will utilize manufact urer authorized support services to perform maintenance, alterations, or preventive ma intenance on the UAS. Furthermore, CBH will

document and maintain all maintenanc e records for the Inspire 1 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by CBH to the extent necessary to allow operation of the Inspire 1 UAS by a Pilot in Command (PIC) holding a private pilot certificate, as well as an airman medi cal certificate, and w ho has demonstrated, by meeting minimum flight-hour and currency require ments, that the PIC is able to safely operate the Inspire 1 UAS in a manner consis tent with this exemption, including evasive and emergency maneuvers, as well as operati ng the helicopter without hazard to people, vessels, vehicles and structures in accordance with Section 91.119(d).

CBH seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Inspire 1 UAS does not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CBH submits that it will ensure that the In spire 1 UAS is in an airworthy condition, prior to every flight, by determining th at the UAS is in compliance with the current operating and maintenance documents (i.e., the Inspire 1 UAS User Manual, the Inspire 1 Maintenance Manual, the Inspire 1 UAS Quic k Start Guide, the Inspire 1 UAS Safety Guidelines, and the Intelligent Flight Battery Safe ty Guidelines), and that the aircraft is in a condition for safe flight.7 CBH also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , because the altitude reporting equipment of the Inspire 1 UAS is set to zero feet above ground level (AGL), rather than local barometric pr essure or field altitude , before each flight. The altitude information of the Inspire 1 UA is provided to the PIC via a barometric pressure sensor, Global Positioning Syst em (GPS) equipment, and a radi o communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. A level of safety equivalent to Section 91.121 will be ensu red as the altitude of the Inspire 1 UA will be reported to air traffic control (ATC) in feet above ground level (AGL), and CBH will operate the Inspire 1 UA within visual line of sight.

Additionally, CBH seeks an exemption from the requirements of Section 91.151(b),

entitled Fuel requirements for fl ight in VFR conditions . CBH submits that safety will not be affected by operation of the Inspire 1 UA durin g daylight hours in vi sual meteorological conditions (VMC) under visual flig ht 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 least 4.5 minut es (i.e., 25 percent battery power remaining).

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

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is: CHESAPEAKE BAY HELICOPTERS, INC. Attn: Oleg Bulanov Ph: 757-465-9936 Fax: 757-465-9946 Email: olegbulanov@cbhelos.com Address: 5202 W Military Hwy, Bldg. 11 Chesapeake, VA 233218 B. The Specific Sections Of 14 C.F. R. From Which CBH Seeks Exemption. 1. CBH Seeks Exemption From The Requi rements Of Section 61.113(a) And (b). Section 61.113, 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 certific ate 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 co mpensation 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 passengers or property for compensation or hire. 2. CBH 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. CBH Seeks Exemption From Th e Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall main tain 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 al timeter setting of a statio n along the route and within 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 setti ng of an appropriate available station; or (iii) In the case of an aircraft not eq uipped with a radio, the elevation of the departure airport or an appr opriate altimeter setting av ailable before departure;9 4. CBH Seeks 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 roto rcraft under VFR conditi ons unless (considering wind and forecast weather conditions) there is en ough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. CBH Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operat or of an aircraft— (a) Shall have that aircraft inspected as pres cribed in subpart E of this part and shall between required inspections, except as provi ded in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 6. CBH Seeks Exemption 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 th at has undergone main tenance, 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. CBH 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 paragr aph (c) of this section, no pe rson may operate an aircraft unless, within the preceding 12 ca lendar months, it has had -- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to servi ce 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.10 8. CBH Seeks Exem ption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordan ce with §§ 91.411 and 91.413, each registered owner or operator shall keep the following r ecords for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preven tive maintenance, and alteration and records of the 100-hour, annual, progressive, and ot her required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records 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 pe rson 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-limit ed parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items inst alled on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspecti on status of the aircra ft, including the time since the last inspection required by the insp ection program under wh ich 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 safety directive number a nd 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 installed engines, rotors, propellers, and appliances.11 (b) The owner or operator shal l retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this sect ion shall be retained until the work is repeated or superseded by ot her work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this se ction shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a regi stered 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 CBH Seeks And The Reason CBH Seeks The Relief.

1. Extent Of Relief CBH Seeks And The Reason CBH Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.1 13(a) and (b) entitled Private pilot privileg es and limitations:

Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot certificate, as well as a current and valid FAA issued airman medical certificate, and who has met certain flight-hour and currency require ments, to conduct the proposed UAS flight operations for compen sation or hire. This relief is requested since the limitati ons set forth in Section 61.113(a) and (b) state that a private pilot may, for comp ensation 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 passengers or property for compensation or hire. As set forth more fully below, CBH submits that an equivalent level of safety will

be maintained because no PIC will be allowed to operate the Inspire 1 UAS unless that PIC has met certain flight-hour and currency requireme nts, demonstrating that the PIC is able to safely operate the Inspire 1 UAS in a manner consistent with the ope rations specifications as set forth herein, includi ng evasive and emergency maneuvers, as well as operating the12 helicopter without hazard to people, vessels, ve hicles and structures in accordance with Section 91.119(d). Further, CBH submits that all flights of the Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to CBH’ data acquisition business; and (2) will not carry passengers or proper ty for compensation or hire.

2. Extent Of Relief CBH Seeks And The Reason CBH Seeks Relief From Section 91.7(a).

Relief from Secti on 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow CBH to determine that the Insp ire 1 UAS is in an airworthy condition prior to every flight by ensuring that the UAS is in compliance with the current operating and maintenance documents (i.e., the Inspire 1 Maintenance Manual, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the Inspir e 1 UAS Safety Guidelines, and the Intelligent Flight Battery Safety Guidelines).

CBH seeks the requested relief because the Inspire 1 UAS does not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CBH will ensure that the Inspire 1 UAS is in an airw orthy condition based upon its compliance with the operating and maintenance documents prior to every flight, and further, determine that the aircraft is in a condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief CBH Seeks And The Reason CBH Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the Inspire 1 UAS, because the Inspire 1 UA’s alti tude reporting equipment may be set on the ground to zero feet AGL, rather than loca l barometric pressure or field altitude, before13 each flight. The Inspire 1 UAS utilizes a baro metric pressure sensor, GPS equipment, and a radio communications telemetry data link to dow nlink altitude information from the UA to the PIC at the ground control station (GCS). Considering the limited altitud e of the proposed operations, relief from 14 C.F.R. § 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, a level of safety equivalent to Section 91.121 will

be ensured as the altitude of the Inspire 1 UA will be reported to air traffic contro l (ATC) in feet above ground level (AGL), and CBH will operate the Inspire 1 UA w ithin visual line of sight.

4. Extent Of Relief CBH S eeks And The Reason CBH Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for fl ight in VFR conditions , is requested to the extent require d to allow flights of the battery powered Inspire 1 UA during daylight hours in visual meteorological condition s (VMC), under visual fl ight 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 mi nutes (i.e., 25 percent battery power remaining). CBH seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Inspire 1 UA will severely constrain the practicality of any aerial data acquisition and research flight opera tions that CBH proposes to conduct pursuant to

this Petition. Significantly, as set forth below, the techni cal specifications of the Inspire 1 UAS, the Inspire 1 UAS operating documen ts, and CBH’ proposed operating limitations, ensure that CBH will safely operate the battery powered In spire 1 UA during daylight hours in visual meteorological conditions (VMC) under visual flig ht rules (VFR), with enough battery power to fly, for a total duration of 13.5 minutes to th e first point of inte nded landing and, assuming14 normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery power remaining).

5. Extent Of Relief CBH Seeks And The Reason CBH 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 airw orthiness certificate, CBH reque sts relief from these Sections because the Inspire 1 UAS does not require an airworthiness certificate. As set forth more fully below, the Inspire 1 UAS meets the conditions of FMRA Section 333, for operation without an airworthiness certificate. Accordingly, CBH will perform maintenance, alterations, or preventive maintenance on the UAS using the met hods, techniques, and pract ices prescribed in the current operating and maintenance documents (i.e., the Inspire 1 Maintenance Manual, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelines, and the Intelligent Flight Battery Sa fety Guidelines), or will utilize manufacturer authorized support services to perform maintena nce, alterations, or preventive maintenance on the UAS. Furthermore, CBH will document a nd maintain all maintenance records for the Inspire 1 UAS. D. The Reasons Why Granting CB H’s Request Would Be In The Public Interest; That Is, How It Wo uld Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing CBH to safely, efficiently, and economically perform aerial data acquisitions within th e NAS, commercially, in support of the various industries currently served by CBH’s manned helicopters. Additionally, use of the Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Ches apeake Bay Helicopters’ proposed operation of the Inspire 1 UAS will be r ealized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisitions Performed.15 CBH submits this Petition to commerciall y operate the Inspire 1 UAS and perform aerial data acquisition within the NAS, in support of the various industries currently served by CBH’s manned helicopters. The Inspire 1 UAS will provide safe, efficient, and economical aerial data acquisition operations to further each of these industries, which are critical to the well-being of the general public.

2. The Public Will Benefit From Decreased Congestion Of The NAS. The Inspire 1 UA is battery powered and serv es as a safe, efficient, and economical alternative to the manned aircraft traditionally util ized to obtain aerial data and/or imagery. By reducing the amount of manned aircraft needed to perform aerial data acquisitions, an exemption allowing the use of a Inspire 1 UAS would reduc e the amount of manned aircraft in the NAS,

reduce noise and air pollution, and increase the sa fety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and de parting aircraft will be reduced. The Inspire 1 UA does not require an ai rport to takeoff or land. Likewi se, a reduction of manned aircraft conducting aerial survey missions w ould result in fewer aircraft th at must be handled by air traffic control during the ground, takeoff, depart ure, arrival, and landing phases of flight operations.

3. The Public Will Benefit From Th e Safety And Efficiency Of The Inspire 1 UAS. Conducting aerial acquisitions with the Insp ire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial data acquisition operati ons. By using battery power and electric motors, the Inspire 1 UAS produces no ai r pollution, and is the most viab le environmentally conscious16 alternative to the traditional manne d helicopters that are typically utilized for aerial acquisitions, and burn approximately 20-50 gall ons per hour of fuel. The Insp ire 1 UA, while reducing the carbon footprint of aerial acquisiti ons, also reduces noi se pollution, as the UA is propelled by battery powered electric motors, rather than an internal combustion engine. By using the Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associ ated with traditional manned helicopter flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flightcrew members located onboard the helicopter, the Inspire 1 UA (weighing approximately 6.5 pounds at its maxi mum gross weight with a length of 17 inches, width of 18 inches, and with no fuel on board), has less physi cal potential for collateral damage to life and property on the ground, and in the air, compared to the manned helicopters that typically conduct aerial acquisitions (weighing 3-6,000 pounds with a rotor diameter of 30-40 feet, and a fuel capacity of approximately 100 gallons). 4. Performing Aerial Acquisition Op erations With The Inspire 1 UAS Will Benefit The Economy. In addition to being safe and efficient, the Inspire 1 UAS is also an economical alternative to using manned helic opters to conduct aerial acquisitions. As such, operation of the Inspire 1 UAS will allow United States based comp anies, like CBH, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) re gulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and al ternative technology in order to remain competitive. Operat ing the battery powered Inspire 1 UAS is one such technology that not only allows companies greater operation al flexibility compared to manned aircraft, but provides such flexibility without the high opera tional cost of a traditional manned aircraft.17 By operating the Inspire 1 UAS, companies such as CBH, can remain competitive and profitable, and therefore, provid e 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 commercial use of the Inspire 1 UAS, provides a stable workforce that increases consumer spen ding; improves local, state, and federal tax revenues; and allows companies to invest in research and developmen t in order to remain competitive both in the

United States and abroad. 5. There Are No Privacy Issues.

Similar to the manned aerial ac quisition flight operations that have been conducted since its inception in 1998, CB H’s proposed operation of the Insp ire 1 UAS will not implicate any privacy issues. Specifically, the Inspire 1 UA S will be operated pursua nt to the specific

conditions and limitations set forth herein, and in accordance with the Federal Aviation Regulations, including the minimum safe altitude requirements of 14 C.F.R. § 91.119(a) and (d) and without hazard to any person, ve ssel, vehicle, or structure. E. The Reasons Why Granting The Exemption Would Not Ad versely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which CBH Seeks Exemption. 1. Reasons Why The Inspire 1 UA S Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, a nd limited operating area associated with the unmanned aircraft and its operation, CBH’ operati on of the Inspire 1 UAS meets the conditions of FMRA Section 333, and will no t require an airworthiness cer tificate in accordance with 14 C.F.R. Part 21, Subpart H.18 Section 333 provides authority for a UAS to operate without airwor thiness certification and sets forth requirements for considering whethe r a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Spec ifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requ irement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certa in unmanned aircraft systems may ope rate safely in the national airspace system before comple tion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Sy stems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proxim ity 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, cer tificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft sy stems identified under paragraph (1). (c) Requirements for Safe Operation.--If the S ecretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, CBH submits that the Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Sect ion 333, as demonstrated by: (a) the characteristics of the Inspire 1 UAS; (b) the pilot certification requi rement; (c) the specific operating limitations; and (d) the CBH “Standard Operating Proced ures (SOP) And Policies” which contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). a. The Specifications Of The In spire 1 UAS Demonstrate Its Safe Characteristics.19 The Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security co nsidering its size, weight, speed, and operational capability. i. Technical Specifications Of The Inspire 1 UAS. The technical specifications of the Inspire 1 UAS are set forth in the Inspire 1 User Manual, attached hereto as Exhibit A. ii. The Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The Inspire 1 UAS may be operated in both manua l and autonomous flight modes. A complete description of autonomous flight modes is provided in the Inspire 1 User Manual, attached hereto

as Exhibit A. iii. The Inspire 1 UAS Is Desi gned For Automatic Return To Home Point Or Automatic Landing In The Event Of Loss Of The Control Link Or Navigation. A complete description of the Failsafe Func tions of the Inspire 1 UAS is set forth at pages 13 through 17 of the Inspire 1 User Ma nual, attached hereto as Exhibit A.

iv. The Inspire 1 GC S And Its Operation. The Inspire 1 ground control station (GCS) is co mprised of at least on e remote controller, as well as a mobile device supporting the syst em software, known as the DJI Pilot App. A complete description of the opera tion and specifications of the Inspire 1 remote controller is provided at pages 23 through 33 of the Inspire 1 User Manual. A complete description of the operation and specifications of DJ I Pilot App is provided at page s 40 through 43 of the Inspire 120 User Manual. The Inspire 1 UAS is complia nt with all Federal Communications Commission (FCC) requirements, and the radio frequency spec trum used for operation and control of the UA is set forth at page 58 of th e Inspire 1 UAS User manual. b. Flight Operations Of Th e Inspire 1 UAS Are Limited To The Line Of Sight Of A Certif icated Pilot in Command With A Safety Observer. CBH will only utilize certific ated pilots who possess a current and valid FAA issued airman medical certificate to act as a pilo t in command (PIC) of the Inspire 1 UAS. Additionally, a safety observer will assi st all pilots during flight operations.21 c. Flights Of The Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, CBH proposes to commercially operate the Inspire 1 UAS for the special purpose of conducting aerial data acquisitions with in the NAS, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of ex emption are limited to the following aircraft described in the operating documents, a ro torcraft weighing 55 pounds or less at maximum gross weight: Inspire 1 Unmanned Aircraft System. Proposed operations of any other aircraft will require a new pe tition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducti ng operations for the purpose of aerial data acquisitions. 3. The UA may not be flown at an i ndicated airspeed exceeding 43 knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specif ied in the operating doc uments. All altitudes reported to ATC must be in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use hu man vision unaided by an y device other than corrective lenses, as specified on the PIC’ s FAA-issued airman medical certificate. 6. The use of first person vi ew (FPV) by the PIC or visu al observer (VO) is not permitted. 7. All operations must utilize a visual observer (V O). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messa ging or texting is not permitted during flight operations. The PIC must be designated be fore the flight and cannot transfer his or her desi gnation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 8. The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground ba sed obstacles/obstructions and is not permitted to operate the came ra or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administ rator upon request. If a discrepancy exists between the conditions and lim itations contained in the grant of exemption and the procedures outlined in the ope rating documents, the condition s and limitations contained in the grant of exemption take precedence and must be foll owed. Otherwise, the operator22 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 a nd revised documents if it petitions for extension or amendment to the grant of exem ption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendm ent to the grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be cont acted if questions arise regarding updates or revisions to th e operating documents. 10. Prior to each flight the PIC must inspect th e UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition th at affects the safe operation of the UAS, the aircraft is prohibited from operating until th e necessary maintenanc e has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspecti on. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenanc e or alterations that affect the UAS operation or flight characteristics, e.g. repla cement 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 discrepanc ies, e.g. inoperable components, items, or equipmen t, not already covered in th e relevant sections of the operating documents. 13. The operator must follow the UAS manufac turer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry ou t its maintenance, inspecti ons, and record keeping requirements, in accordance with the opera ting documents. Maintenance, inspection, alterations, and status of replacement/overh aul component parts mu st be noted in the aircraft records, including total time in se rvice, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exemption mu st 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 leas t a private pilot certificate an d at least a current thirdclass medical certificate. 18. The operator may not permit any PIC to ope rate unless the PIC meets the operator’s qualification criteria and dem onstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated unde r the exemption, including evasive and23 emergency maneuvers and as well as operating the helicopter without hazard to people, vessels, vehicles and structur es in accordance with Section 91.119(d). PIC qualification flight hours must be logged in a manner cons istent with 14 C.F.R. § 61.51(b). The VO is also required to complete the operator’s traini ng requirements. A record of training must be documented and made availa ble upon request by the Admi nistrator. Flights for the purposes of training the operato r’s PICs and VOs (training, proficiency, and experiencebuilding), are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated traini ng sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate without hazard to nonparticipants in accordance with 14 C.F.R. § 91.119(d). 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducte d under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 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 th e operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made availabl e to the Administ rator 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, itmust return to a predetermined location within the planned opera ting 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 fl ight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (A TO) issued Certificate of Waiver or Authorization (COA) prior to c onducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airmen (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 airspa ce, altitude level and potential transponder requirements.24 26. All aircraft operated in accordance with th e exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and ha ve identification (NNumber) 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 fre quency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UA S any time the UAS is operating. These documents must be made available to the Ad ministrator or any law enforcement official upon request. 29. The UA must remain clear and yield th e right of way to all manned aviation operations and activi ties at all times. 30. The UAS may not be operated by the PIC from any moving de vice or vehicle. 31. The UA may not be operated over co ngested or densely populated areas. 32. Flight operations must be conducted at an a ltitude that allows, if a power unit fails, an emergency landing without undue hazard to persons or pr operty on the ground as per 14 CFR 91.119(a). Additionally, the helicopter shall be operated without hazard to persons or property on the ground at a ll times as per 14 CFR 91.119(d). 33. All operations shall be c onducted over private or cont rolled-access property with permission from the land owner/ controller or authorized re presentative. Permission from land owner/controller or author ized representative will be obt ained for each flight to be conducted. 34. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational ar ea as defined by the applicab le COA must be reported to the FAA's UAS Integration Office (AFS-80) wi thin 24 hours. Accidents must be reported to the National Transportation Safety Boar d (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. d. Operation Of The Inspire 1 UAS Will Be In Accordance With Standard Operating Procedures And Policies. “CBH Standard Operating Procedures (SOP) And Policies” will regulate CBH’ operation of the Inspire 1 UAS and will significan tly contribute to maintaining the level of safety contemplated by the regulatio ns from which CBH now seeks relief.25 The “CBH Standard Operating Procedures And Policies,” which contain proprietary information, are attached hereto as Exhibit F, and is to be held in a se parate file pursuant to 14 C.F.R. § 11.35(b).

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Ad versely Affect Safety. CBH submits that the equivalent leve l of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Inspire 1

UAS unless that PIC has dem onstrated, by meeting minimu m flight-hour and currency requirements, that the PIC is able to safely operate the Inspire 1 UAS in a manner consistent with the exemption, including evasive and emer gency maneuvers, as well as operating the helicopter without hazard to people, vessels, ve hicles and structures in accordance with Section 91.119(d) in the same ma nner as our manned helicopters. Considering CBH’ proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowle dge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and th e airmanship skills necessary to safely operate the Inspire 1 UA S, CBH submits that the additional manned airmanship experience of a commercially ce rtificated pilot would not correlate to the airmanship skills necessary for CBH’ specific proposed flight operations. The FAA has previously granted relief fr om Section 61.113(a) a nd (b) specific to UAS, in circumstances similar, in all materi al 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, 11170, 11171, 11172).26 CBH will not allow any PIC to operate the Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hou r requirements or the Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the Inspire 1 UAS in a manner consistent with this exemption, includ ing evasive and emergency maneuvers, as well as operating the helicopter without hazard to people, vessels, vehicles and structures in accordance with Section 91.119(d) in the same manner as our manned helicopters. Specifically, the PIC must have accumulate d and logged, in a manner consistent with 14 C.F.R. § 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-ro tor UAS (with a minimu m of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operationsunder the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings of the Inspire 1 UA in th e 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 CBH’ proposed operations. The Administrator has held that prior documented flight experience that was obtai ned in compliance with appli cable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or si milar operations), the PIC must have accumulated and logged, in a manner cons istent with 14 C.F.R. 61.51(b), 25 hours of total time as a UAS rotorcraft pilot includi ng 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 mini mum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA cons iders these minimum hour requi rements 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 th e 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour re quirements, 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 requirement s in Exemption No. 11062 are appropriate to27 practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-buildin g flights can also be conducted under the grant of exemption to accomplish the require d flight time. During training, proficiency, and experience-building flights the PIC is re quired to operate the UA with appropriate distances in a ccordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, CBH will ensure safe operations by not allowing any PIC to operate the Inspire 1 UAS unless that PIC has demonstr ated, by meeting mini mum flight-hour and currency requirements, that the PIC is able to safely operate the In spire 1 UAS in a manner consistent with the exemption, including ev asive and emergency maneuvers, as well as operating the helicopter without hazard to pe ople, vessels, vehicles and structures in accordance with Section 91.119(d) in the same manner as our manned helicopters. 3. Reasons Why An Exemption From Th e Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety establishe d by Section 91.7(a) will be maintained because prior to every flight, CBH will ensure that the Inspire 1 UAS is in an airworthy condition based upon the UAS’s co mpliance with its operating documents and as stated in the proposed conditions and limitations herein. Additionally, the FAA has previously grante d relief from Section 91.7(a) specific to UAS, in circumstances similar, in all materi al 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, 11166, 11167, 11170, 11171, 11172).28 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety establ ished by Section 91.121 will be maintained

because the altitude of the Inspire 1 UA will be reported to air traffic control (ATC) in feet above ground level (AGL), and CB H will operate the Inspire 1 UA wi thin visual line of sight, at or below 400 feet AGL. Furthermore, the a ltitude information of the Inspire 1 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link,

which downlinks from the UA to th e GCS for active monitoring of the flight path and altitude. Prior to each flight, a zero a ltitude initiation point is automati cally established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respec ts, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171).

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 eq uivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the te chnical specifications of the Inspire 1 UAS; (2) the limitations on the proposed flight ope rations; and (3) the location of the proposed flight operations. Accordingly, CBH will ensu re that it will safely operate the battery powered Inspire 1 UA 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 inte nded landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery power remaining).29 Here, as in Exemption No. 11109, the techni cal specifications of the Inspire 1 UAS; the limitations on the proposed f light operations; and the locati on of the proposed operations, will ensure an equivalent le vel of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as th e Inspire 1 UAS provide s visual and audible warnings to the PIC at the GCS when the UA experiences low battery voltage, and if no action is taken in response to the warnings, the UA will automatically return to its starting point and land. A full description of the low battery level failsafes is provided at page 14 of the Inspire 1 User Manual, att ached hereto as Exhibit A. Significantly, previous exemptions gr anted 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 consid ered. 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 FA A has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those 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, 11166, 11167, 11170, 11171, 11172). 6. Reasons Why An Exemption From The Requirements Of Sections 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, CBH submits that th e equivalent level of safety with regard to the regulatory maintenance and alteration requirements esta blished by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) wi ll be met because CBH will perform maintenance, alterations, or preven tive maintenance on the UAS using the methods, techniques, and practices prescr ibed in the current operating and maintenance documents (i.e.,30 the Inspire 1 Maintenance Manual, the Inspire 1 UAS User Manual, the Inspire 1 UAS Quick Start Guide, the Inspire 1 UAS Safety Guidelin es, and the Intelligent Flight Battery Safety Guidelines), or will utilize manufacturer author ized support services to perform maintenance, alterations, or preventive maintenance on the UAS. Furthermore, CBH will document and maintain all maintenance records for the Inspire 1 UAS. Since the Inspire 1 UAS will be insp ected as prescribed by the operating documents, CBH will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating and maintenance documents are attached hereto, identified as the following Exhibits: (A) the Inspire 1 UAS User Manual; (B) the Inspire 1 UAS Qu ick Start Guide; (C) the Inspire 1 UAS Safety Guidelines; (D) the Intelligent Flig ht Battery Safety Guidelines; and (E) the Inspire 1 UAS Maintenance Manual. The foregoing exhibits contain proprietary information and are to be held in a sepa rate file pursuant to 14 C.F.R. § 11.35(b). Likewise, the exemption sought will not adversely affect safety because CBH will perform maintenance, alterations or preventi ve maintenance on the UAS using the methods, techniques, and practic es prescribed by the operating documents, or will utilize manufacturer authorized support services to perform maintenance, alterations, or preventive maintenance on the UAS. Furthermore, the exemption sought would ma intain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because CBH will document and maintain maintenance records for the Inspire 1 UAS. In consideration of CBH’ pr oposed operating limitations, the operating documents, and the technical aspects of the Inspire 1 UAS, CB H 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),31 91.409(a)(2), and 91.417(a) and (b). The FAA has pr eviously granted relief specific to UAS in circumstances similar, in all material resp ects, 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, 11166, 11167, 11170, 11171, 11172).

7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FA A Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , CBH requests that the FAA prescribe special conditions for the intended operation of th e Inspire 1 UAS, which contain such safety standards that the Administrator fi nds 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 §§ 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). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial data acquisitions within the NAS for compensa tion or hire. FMRA Section 333 sets forth the requirements for considering wh ether a UAS will create a hazard to users of the NAS or the public, or otherwis e pose a threat to national secu rity; and further, provides the authority for such UAS to opera te without airworthiness certif ication in accordance with any requirements 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 the Inspire 1 UAS, since the airworthine ss regulations of 14 C.F.R. Part21 do not contain adequate or appropriate sa fety 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 regu lations of this subc hapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller32 because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendm ents thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter a nd 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 esta blished in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA S ection 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for CBH ’ intended operation of the Inspire 1 UAS, which contain such safety standards th at 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 CBH Seeks Exemption: CHESAPEAKE BAY HELICOPTERS, INC. seeks exemption fr om 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 Na ture Of The Exemption CBH Seeks: This exemption will permit CH ESAPEAKE BAY HELICOPTERS, INC.to commercially operate an Unmanned Airc raft System (UAS) for the purpose of conducting aerial data acqui sitions within the Nationa l Airspace System (NAS). G. Any Additional Information, Views, Or Arguments Available To Support CBH’s Request.

This Petition is made pursu ant to the FAA Modernizat ion and Reform Act of 2012 (FMRA) Section 333, which direct s the Secretary of Transporta tion to determine if certain UAS may operate safely in the NAS. As suc h, CBH’ request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.33 FMRA Section 333 sets forth the requirem ents 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.

As discussed in detail above, CBH will opera te the Inspire 1 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or othe rwise pose a threat to national security. CBH respectfully submits th at because this small, unmanned aircraft system will be used in lieu of comparativ ely hazardous operations now conducted with our conventional manned helicopters, the FAA can have confidence that the pr oposed operations will achieve at least an equivalent or greater level of safety. Additionally, CBH already employs many policies and procedures that demonstrate a commitment to the safety of employees and the public in its helicopter operations, including an a v i a t i o n- b a s e d Safety Management System, FAA Approved FAR Part 133 Helicopter External Load operations and DOT drug and alcohol testing fo r safety-sensitive employees. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibil ities under Section 333( c) of the Reform Act to “establish requirements for the safe operation of such airc raft systems in the national airspace system.”

CONCLUSION As set forth herein, CBH seeks an exemption pursuant to 14 C.F.R. §11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of the Inspire 1 UAS commercially, with out an airworthiness certificat e, for the limited purpose of conducting aerial acquisitions within the National Airspace System ( NAS). By granting this Petition, the FAA Administrator will be fulfilling the Cong ressional mandate of the FAA Modernization and34 Reform Act of 2012, while also a dvancing the interests of the publ ic, by allowing CBH to safely, efficiently, and economically operate the Inspire 1 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Sect ion 333, CBH respectfully requests that the Administrator grant this Petition for an 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 nd permit CBH to operate the Inspire 1 UAS commercially for the purpose of conducting aerial acquisitions w ithin the NAS.

Dated: May 8, 2015 Respectfully submitted, Chesapeake Bay Helicopters, Inc. /s/ Oleg Bulanov Oleg Bulanov 5202 West Military Hwy. Bldg. 11 Chesapeake, VA 23321 Tel: (757) 465-9936 Fax: (757) 465-9946