### May 11, 2015

Exemption No. 11519 Regulatory Docket No. FAA

– 20 15

– 0329

Mr. Michael Cook M2 Flight Solutions, LLC 2690 Bald Eagle Ct. #A North Pole, AK 99705

Dear Mr. Cook :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated February 9, 2015 , you petitioned the Federal Aviation Administration (FAA)

on behalf of M2 Flight Solutions, LLC ( hereinafter petitioner or operator ) for an exemption

. The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photogrammetry for the purpose of 3d reconstructions

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summ ary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a Sk ywalker Aero

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

### 2

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances s imilar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather t han a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesti ng an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, M2 Flight Solutions, LLC is granted an exemption

from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data

collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limit ations

In this grant of exemption, M2 Flight Solutions, LLC is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Skywalker Aero when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exem ption

.

2. Operations for the purpose of closed

- set 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 groundspeed 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 UA 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 FAA

- issued 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 time s. 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 ;

e lectronic 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 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, th e 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 Administ rator or any law enforcement official upon request. The

### 4

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 th e basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating do cuments.

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 th is 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 pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight 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 necess ary 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 compone nts.

12. Each UAS operated under this exemption must comply with all manufacturer 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew 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

### 5

(traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated

under this exe mption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building 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 conduc ted 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 Direc tory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published 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 sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access 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 operat e 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 cond ucted in accordance with an ATO

- issued C OA. 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

.

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

### 6

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 no nparticipating 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 control led

- access 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 FA A'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

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to th e local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for al l flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be use d;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and t he altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unles s otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresFebruary 9 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Request for Summary Grant of Exemption Under Section 333 of the FAA Reform

Act and Part 11 of the Federal Aviation Regulations

D ear Madam/ Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, M2 Flight Solutions LLC, developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to condu ct aerial photogramatry for the purpose of 3d reconstructions, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the c onditions outlined herein or as may be established by the FAA as required by Section 333.1 As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the Oil and Gas industry presently using conventional aircraft. Approval of this exemption would thereby

enha nce safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name a nd address of the applicant is:

M2 Flight Solutions, LLC
Attn: Michael Cook

Ph:907

- 987

- 0900 Email: mike@m2flightsolutions.com Address: 2690 Bald Eagle Ct. #A North Pole, AK 99705

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113(a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F. R. 91.11914 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ g oal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to con sider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a haza rd to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333( c) (emphasis added)2.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes sUASs , from the requirement

that all civil aircraft must have a current airworthiness certificate.

The requested exemption would authorize comm ercial operations using the Skywalker Aero for mapping and survey applications as well as a monthly mission to

map o ut a n open pit mining for gold located in Fairbanks, Alaska . These operations will be subject to strict operating requirements defined in the Aero user manual in order to ensure at least an equivalent level of safety to currently authorized operations usin g manned aircrafts.

The Aero will be operated by an individual who fulfill the following requirements:

 Ha s s ucce s sfully pa s s e d a ma nufa cture r’s tra ining program for the Aero ; as well as pass flight requirements put forth by M2 Flight Solutions.

 Has at a minimum, a Ground School Certification and a third /first class medical
certificate.

1. CHARACTERISTICS OF THE AIRCRAFT

The Aero is a small (37.8 inches wingspan) and ultra

- light (maximum take

- off weight of 6.8 lbs, platform made of molded foam that performs pre

- programmed precision aerial mapping missions thanks to the on

- board GPS and the related fli ght management software ( Ardupilot ) that allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in real

- time.Th anks to the embedded camera, the Aero takes a collection of high

- definition still images / videos that are used later to generate maps and contour lines of the surveyed

area. The four main characteristics of the Aero are:

a. Very light weight

The Aero is so light that the operator can launch it by hand and let it land on almost any surface without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a controlled emergency landing) also significantly reduces the risk of

ha zardous situations. Finally, the wings of the Aero are detachable and made of flexible foam with no sharp or hard edges and almost no internal strengthening structure.

b. Electric

- powered

The Aero is electric powered. One brushless engine technology makes it silent and reliable. The propeller is attached with a lock tight nut to the base of the motor and is made of plastic so that it can easily break away in case of contact with any object.

c. Semi

- automatic flight The artificial intelligence incorporated within the Pixhawk autopilot system continuously analyzes data from the Inertial Measurement Unit (IMU) and from the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator.

d. Option for Manual control Additionally, the Aero provides an override capability that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and take manual control of the aircraft should it become necessary to respond emergent circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS M2 Flight Solutions intends to use the Aero to conduct imaging flights for the purpose of

prec ision mining and land survey

, and open mining pit mapping . The aircraft will be used over controlled access property and only be used to image property for which we have been contracted by the landowner to do so. Images will be used to increase mining prod uction, identify environmental land issues and allow for land use planning

.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents whic h is a fixed

- wing aircraft weighing approximately 6.8 pounds: Aero . Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. The UA may not be flown at an indicated airspeed exceeding 40 knots.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of si ght (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 FAA

- issued airman medical certificate.5. All operations must utilize a visual observer (VO). 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. The PIC must be designated

before the, t he PIC must ensure that the VO can perfo rm the functions prescribed in the operating documents.

6. The operating documents and this grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the

conditions and 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 upon request. The operator must also present updated and revised documents if it petitions for ex tension 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 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.

7. P rior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. 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 f ound to be in a condition for safe flight and proper documentation in the maintenance handbook is complete . The Ground Control Station must be included in the preflight inspection.

8. Any UAS maintenance or alterations that affect the UAS operation or fl ight characteristics, e.g. replacement 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.

9. The pre

- flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10. The operator must follow the UAS aircraft/component, maintenance, overhaul, replac ement, inspection, and life limit requirements.

11. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection,

and alterations must be noted in the aircra ft records, including total flight hours, description of work accomplished, and the signature of the PIC returning the UAS to

service.

12. Each UAS operated under this exemption must comply with all manufacturer System and Safety Bulletins.13. The PIC must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

14 . A record of training must be documented and made available upon request by the Administrator. Flights for the purposes of tr aining the operator’s PICs and VOs (training, proficiency, and experience

- building), are permitted under the terms of this exemption. However, said training operations may only be conducted during dedicated training

sessions.

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).

16 . The UA may not operate within 5 nautical miles of the airport reference point as

denoted on a current FAA

- published aero nautical chart.

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 UA loses communications or loses its GPS signal, it must re turn to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

20 . The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operatin g documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

24 . Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

25 . The 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 a vailable to the Administrator or any law enforcement official upon request.

26 . The UA must remain clear and yield the right of way to all other manned aviation operations and activities at all times.

29. The UA may not be operated over congested or dens ely populated areas.

30. 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 operatio ns must cease immediately and/or;

b. T he aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determi ned that it does not present an undue hazard, and

c. O perations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlle d

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be

conducted.

32. Any incident, accident, or flight opera tion 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 Safe ty Board (NTSB) per instructions contained
on the NTSB Web site: www.ntsb.gov . Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

c. Operator Requirements

The Pilot

- In

- Command of the Aero will hold, at a minimum, a ground school Certificate

and a third class medical certificate.

3. CONCLUSION Myself the CEO Michael Cook has a very large amount of experience in the UAS field, I have listed below references to the work that I have done in the past and the people I have worked for to gain this knowledge. I hold three different certifications in UA V systems, as well as help in the past to set up the test site for the University of Alaska Fairbanks. I have well over 8 years of UAV experience and have conducted UAV flight operations with ZERO incidents or accident. This request is designed to follow u p on previous efforts by the Federal Aviation Administration to determine equivalent levels of safety for UAS operations. By requesting a summary grant of exemption we hope to achieve expedited approval for UAS operations to the public’s benefit.

http://www.adn.com/article/20140505/fairbanks

- alaska

- drone

- program

- gets

- ground

http://www.newsminer.com/news/localnews/drone

- test

- site

- officially

- opens

- at

uaf/article371af416

- d4f3

- 11e3

- b978

- 0017a43b2370.htmlYours sincerely,
Michael Cook
CEO M2 Flight Solutions

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY
SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

M2 Flight Solutions requests an exemption from the following regulations as well as any additional regulations that may technically apply to th e operation of the Aero fixed

winged UAV :

14 CFR 61.133: Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any busi ness 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. To obtain a commercial pilot certificate a candidate must demonstrate a level of a eronautical knowledge and aircraft handling beyond what is required to operate a UAS. Our proposed operations would require that a Pilot

- In

- Command have the aeronautical knowledge and aircraft handling skills currently required to obtain a private pilot

ce rtificate. Given the lack of passengers or cargo on board the UAS, controlled access operations area we operate in and the simplicity of the UAS we believe that an equivalent level of safety can be ach ieved by requiring the pilot in command hold, at a

mini mum, a ground school certificate and a third /first class medical certificate.

14 CFR 91.7(a): Civil aircraft airworthiness This regulation requires that no person may operate a civil air craft unless it is in airworthy condition. Should the exemption be granted a llowing commercial operation of

the Aero UAV without an airworthiness certificate, no standard w ill exist for airworthiness

of t he Aero

. An equivalent level of safety will be achieved by insuring compliance with

the Aero manuals prior to each flig ht.

14 CFR 91.119: Minimum Safe Altitudes The regulation provides that over sparsely populated areas the air craft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 40 0 feet AGL, the Aero cannot comply with this requirement. The equivalent level of safety w ill be achieved because the Aero will only fly over private property with the permission of the landowner. The operator will define before every flight a working area radius and a flight a rea ceiling, preventing the

Aero to go beyond the flight area. The landowner and the persons who may be on the ground in the flight area will be briefed of the expected route of flight and the associatedrisks to persons and property on the ground. Due to the small size of the Aero and the

material with which the Aero is built of , the hazard to persons, vessels, vehicles, and structures is not comparable by far to manned aircraft and should be considered in granting the exemption. More over, the aircraft will not be operated over congested areas

nor over any open

- air assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the su rface.

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions The regulation provides that no person may begin a flig ht in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Given the area of operation for the Aero

, M2 Flight Solutions believes that an equivalent level of safety is already achieved with the specific procedure preventing the Aero to accept a takeoff order if the battery level is below a given value. Moreover, 3D Robotics has integrated “low” and “critical” battery level warnings and implemented a “return to Home” (and “Go Land”) actions in these

situations to the ground station preventing any hazards of the c raft to continue to fly.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, and

Alterations The regulation provides that the operator is primarily responsible for maintaining

the aircraft in an airworthy condition, including compli ance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. M2 Flight Solutions proposes that the maintenance of the Aero will be accomplished by the owner/operator according to the maintenance manual, provided by 3D Robotics . An equivalent level of safety will be achieved because the Aero is small in size, it is not a complex mechanical device, it will carry no external payload, and it will operate only in

restricted predetermined areas. Moreover, the operator is the person most familiar with

the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. Finally, before every flight, the Aero runs automatically a sequence of pre

- flight tests to make sure that every sensor and every critical part is running properly. If a probl em is detected, the Aero will not be able to be

switched

- on and a message error is displayed on the main screen of t he flight management software. The operator can then refer to the maintenance manual to troubleshoot this issue. Several parts of the Aero a re easily in terchangeable (propellers, Legs antenna ), which allows the operator to make sure the landing gear and propulsion system are always airworthy when a mission is initiated.