# WCTC

Design Sottware Solutfons 

# ~ AUTODESK© Gold Partner

8101 34th Avenue South Suite 100 Bloomington, MN 55425 Ph: 866-941-1181 Fx: 952-941-6515

US Department Of Transportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

June 12 th , 2015

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, CAD Technology Center, Inc. request to be exempted from the Federal Aviation Regulations (FAR) listed below so that CTC may operate UAS commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333. As air safety is of paramount importance, CTC has developed a highly structured safety flight manual for our pilot as well as observer. As recent as the new proposed FAA regulation released as of February of 2015, CTC intends to operate well within the most stringent proposal required to operate an unmanned aircraft in the National Airspace System (NAS). We are prepared to attend any required course of study, participate in flight evaluation and pay any required fee(s) that may be instituted. The 

### PIC will take all actions including reviewing weather, battery requirements, landing and takeoff performance before initiating flight missions. As described below, the requested exception would permit the operation of light weight UAS under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation's ( the FAA Administrator's) responsibility to" establish requirements for safe operation of such aircraft systems in national airspace systems." Section 333(c), of the Reform Act. CTC's UAS is an aircraft weighing less than 55 pounds including payload (The DJI Phantom 2 Vision Quad Copter). It operates at a speed less than 50 knots and has the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS has an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. CTC respectfully requests the grant of an exception to the following specific sections of the Title 

### 14 Code of Federal regulations allowing it to operate lightweight UAS for commercial use, 14 CFR 21,

www.cadtechnologycenter.comsubpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a),

91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b). CTC submits this application in accordance with the Reform Act ,112 P.L. 95 331-334, seeking relief from any currently applicable FAR'S operating to prevent CTCs future commercial use of small UAS to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public's interest to do so. CTC's UAS meets the definition of a"small unmanned aircraft" as defined in Section 331 and therefor the integration of the UAS are expressly contemplated by the Reform Act. CTC would like to operate its light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following: The UAS size, speed, weight and operational capability Operation of the UAS in close proximity to airports and populated areas Operation of the UAS within visual line of sight of the operator Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent (evel of enhanced safety, reduced emissions utilizing UAS verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitation on operations of CTC:

1. Flights will only occur in the day time hours 2. Flights will be operated in the line of sight of the operator (PIC) and Observer (VSO) 3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by manufacturers recommendations 4. The UAS will weigh less that 55 Ibs.

www.cadtechnologycenter.com5. Flights will be operated at 200 feet AGL or less

6. Crew will be at a minimum of operator(PIC) and an observer and/or camera operator(VSO) 7. Operator and crew will remain in contact during the flight operation 8. The UAS operator will perform a check of the flight area and make certain of the safety of all persons in the area 9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violating anyone's privacy 10. AII required FAA clearances, will be obtained and distances from airports strictly observed 11. AII UASs will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working 12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned to operate the UASs at a safe distance from the main fishing boat 13. Flights will only operate in VFR conditions 14. UAS has a function on the control to tell the operator the distance away from the operator and its battery power remaining 15. Flight team will communicate by voice and the use of two-way radio if the area is too big to hear voice from all team members 16. UAS will be used for data collection for the AEC industry 17. When operating over or near water the UAS will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table 14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for CTC's UAS flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. As of March 23, 2015 the FAA has stated that it will automatically grant a"blanket" COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption. 14 CFR 91.203(a&b) provides for carrying of civi) aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at CTC. 14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable. 14 CFR 91.9(b)(2) Civi) Aircraft Flight Manua) in Aircraft requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS this regulation is

www.cadtechnologycenter.cominapplicable. An equivalent level of safety will be achieved by maintaining such certifications and

registrations at CTC. The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. CTC will only operate its UAS at or below 200AGL. Compared to flight operations of conventional and traditional aircraft weighing far more than 50 Ibs., operating below 500 AGL with flammable fuel UAS operations present a far smaller risk to the public. Approval of these 333 Exemptions allowing commercial operations of small UAS in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UAS the risk of injury of people on the ground or the crew has been reduced or almost erased. CTC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by CTC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT). Thank you for your time in reviewing this information, please feel free to contact us with any questions or concerns about this petition.

Sincerely,



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Daniel Swearson CAD Technology Center, Inc. 8101 34 t " Ave South, Suite 100, Bloomington, MN 55425 DanielS@cadtechnologyicenter.com 952-941-1181

www.cadtechnologycenter.com