Street Smart Rental, LLC

7526 4th Ave.

Lino Lakes, MN. 55014

bgreiner@streetsmartrental.com

TF| 888­653­6800

1/27/2016

To Whom it May Concern:

This petition is being submitted on my behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act),

and 14 C.F.R. Part 11, Street Smart Rental, LLC, Intelligent Transportation Systems (ITS)

consultants hereby applies for an exemption from the Federal Aviation Regulations (FARs)

listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are

conducted with and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

The requested exemption would permit Street Smart Rental, LLC to pursue providing services

to clients using a small advanced sUAS in the following capacity: state highway surveying for

maintenance, construction, project management, progress reporting, special events, and other

intelligent transportation initiatives. Street Smart Rental, is a market leader in providing new

technologies to Transportation Departments around the country. These technologies help to

improve the safety of workers as they work within live traffic. These technologies also improve

the safety and mobility for the general motorists. Street Smart works closely with State

Transportation Departments, which are very interested in renting sUAS’s as a benefit to overall

public safety.

Street Smart Rental, LLC states that all sUAS flights will occur over private or controlled access

property and will do so with the property owner's consent and knowledge and that only people

who have consented or otherwise have agreed to be within the UAS’ radius during filming and

photography applications.

Street Smart has demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 3

Professional which will be used for all commercial and private purposes. Street Smart complies

with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and

environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

Street Smart Rental, LLC is seeking this exemption because we am committed to complying

with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. We agree
to operate the sUAS in the manner that I have described, and for the purposes that we have

described. Without the exemption request granted, I would be unable to safely and effectively

run a business, and it is my intention to comply with the FAA and obtain an exemption of the

following regulations.

The following contains our list of regulations from which we are seeking exemption, and a

complete list of responsibilities I assume as operator; it also contains information regarding the

aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 ­ 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3

Professional when weighing less than 25 pounds including payload. Proposed operations of any

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed­set motion picture and television filming are not

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either ground speed or calibrated airspeed to determine compliance

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than

the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL).

Altitude must be reported 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 human vision unaided by any device other than corrective

lenses, as specified on the PIC’s FAA­issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual

line of sight (VLOS) of the PIC and VO at all times. 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 messaging or texting is not permitted during

flight operations. The PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the VO can perform the

duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter

referred to as the operating documents. The operating documents must be accessible during

UAS operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and 4 limitations in this exemption and the procedures outlined in the

operating documents, the conditions and limitations herein take precedence and must be

followed. Otherwise, the operator 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 or any law enforcement official upon request. The operator must also present

updated and revised documents if it petitions for extension or amendment to this grant of

exemption. 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 an amendment to its

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions

arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional

test flight prior to conducting further operations under this exemption. Functional test flights may

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The

functional test flight must be conducted in such a manner so as to not pose an undue hazard to

persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre­flight inspection and determine the UAS is in

a condition for safe flight. The pre­flight inspection must account for all potential discrepancies,

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that

affects the safe operation of the UAS, the aircraft is prohibited from operating until the
necessary maintenance has been performed and the UAS is found to be in a condition for safe

flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer's safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial,

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia,

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on

his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under this

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training

the operator’s PICs and VOs (training, proficiency, and experience­building) and determining

the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption are permitted under the terms of this exemption. However,

training operations may only be conducted during dedicated training sessions. During training,

proficiency, and experience­building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights under

special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an

ARP, the center of the airport symbol as denoted on the current FAA­published aeronautical

chart, unless a letter of agreement with that airport’s management is obtained or otherwise

permitted by a COA issued to the exemption holder. The letter of agreement with the airport

management must be made available to the Administrator or any law enforcement official upon

request.

17. 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.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre­determined location within the private or controlled­access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough available power for the UA to conduct the intended operation and to

operate after that for at least five minutes or with the reserve power recommended by the

manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations

shall be conducted in accordance with an ATO­issued COA. The exemption holder may apply

for a new or amended COA if it intends to conduct operations that cannot be conducted under

the terms of the attached COA. 6

22. All aircraft operated in accordance with this exemption must be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practical.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the

Ground Control Station of the UAS any time the aircraft is operating. These documents must be

made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at

all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently

protect nonparticipating persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately in a manner ensuring the safety of nonparticipating

persons; and b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not present an undue

hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating

persons under this exemption.
27. All operations shall be conducted over private or controlled­access property with permission

from the property owner/controller or authorized representative. Permission from property

owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the operational area as defined by the applicable COA must be reported to the FAA's UAS

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System, UAVs are often seen as superior to helicopters as an aerial video

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced

noise and as such, a much smaller environmental impact which promotes public safety. Street

Smart intends to use these devices in a manner that would replace the need for highway

workers, surveyors, and project managers, to enter live traffic situations, that are dangerous to

the workers and create traffic hazards for the motorists.

Street Smart Rental, LLC is petitioning for an exemption to operate a DJI Phantom 3

Professional with a built­in stabilized HD camera and GPS safety features which limit its ability

to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from

the operator and to exclude it from operations within designated Class B, C and D airspace

including a no­fly zone feature. The DJI Phantom 3 Professional also has a failsafe function that

is triggered in the event communication is lost between the UAS and the main controller

transmitter. At that time, the UAS will return to its point of takeoff and land safety. If the

connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

­ The petitioner will only operate its sUAS in line­of­sight of a pilot and/or observer and will

operate at sites that are `sufficient distance' from populated areas within the sterile area

described in the FOPM. Such operations will ensure that the sUAS will "not create a

hazard to users of the national airspace system or the public."

­ When flying the sUAS within three (3) miles of an airport, airport operators will be notified

and the operator will give the right­of­way to avoid flying in the proximity of full­scale

aircraft. Maximum flight time for each operation will be 30 minutes.
­ Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight

time to safely land the sUAS.

­ The sUAS will be programmed so it will not be operated at an altitude that exceeds 400

feet AGL, and not more than 200 feet above an elevated platform from which

videography is planned. Minimum crew for each operation shall consist of: sUAS pilot, a

visual sUAS observer, and the camera operator.

­ The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot

certificate and a current FAA medical certificate.

­ The sUAS operated by the petitioner weighs less than 25 pounds, including all payload

(i.e. camera, lens, and stabilized gimbal).

­ The sUAS will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

­ Given the small size of the sUAS and the restricted sterile environment within which it

will operate, SkyVideoCT’s operations adhere to the Reform Act's safety requirements.

Brady Greiner

Technology Manager

Street Smart Rental, LLC.