June 18, 2015

Exemption No. 11856 Regulatory Docket No. FAA

– 2015

– 0009

Mr. Mark Ingle 325 Sand Paver Way Fort Mill, South Carolina 29708

Dear Mr. Ingle :

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 December 31, 2014 , you petitioned the Fe deral Aviation Administration (FAA) for an exemption. The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial imaging, videography, and surveillance

.

See Appendix A for the petition submitted to the FAA describing the prop osed operations and the regulations that the petitioner seeks an exemption

.

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

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot 650M.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products

and parts, Subpart H

— Airworthiness Certificates . 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 in2

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 finds that the requested relief from

14 CFR part 21

, Certification procedures for products and p arts, 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 similar 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

− 20 14

− 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 peti tioner and carrying no passengers or crew, rather than 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 i nterest.

Having reviewed your reasons for requesting 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.

Ther efore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mark Ingle 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 lis ted below.

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

Conditions and Limitations

In this grant of exemption, Mark Ingle is hereafter referred to as the operator.

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 Tarot 650M when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to ame nd this exemption

.

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 calib rated 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 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 ;

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.4

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 Admi nistrator 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 affec t the 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 operatin g 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 unde r 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 propert y.

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 ne cessary 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 com ponents.

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 a lso 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 be5

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

1 4 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (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 exemption 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 ope rations 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 b e 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/Facili ty Directory (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

hori zontally 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 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 cond ucted in accordance with an AT O

- issued 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

.

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

n umber, registered in accordance with 14 CFR part 47, and have identification6

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

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 e nforcement 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 ens ure 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 nonpa rticipating 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 op eration 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.7

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

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exempt ion must submit a written Plan of Activities to the 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 incl ude at least the following:

a. Dates and times for all 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. Ma ke, model, and serial or N− Number of UAS to be used;

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 the 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 productio n, as specified in the exemption holder’s MPTOM.

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 91.8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresExemption for Petition Page 1

December 31 , 2014

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

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Mark Ingle, would like to apply for a n exemption from t he following Code of Federal Regulations (C.F.R ) to allow commercial operation of lightwei ght Unmanned Aircraft Systems (sUAS) for aerial imaging, video , and surveillance . This

video and image data will be used for survey analysis, safet y and/or damage inspection , aerial photography

, as well as search and rescue. These a re services that

will be offered and safely executed to various clients or industries with these types

of needs . The operations of the service (s) will only be carried ou t with the proper approval from property owners and any other agencies requiring approval. Safety will be top priority before, during

, and after operations of the services. Described herein, along with request for exemption, are details on how my operati ons will be equal to

, or more safe than use of traditional rotorcraft.

Part o f my request, herein, for exemption will contain technical terms and components that make up the typical s UAS. These terms and definitions can be found at the end of this petiti on under the section Terms and Definitions

.

My name and address :

Mark Ingle 325 Sand Paver Way Fort Mill, South Carolina 29708

Cell Phone: 803.412.1958

I am requesting exe mption from the following CF R s

14 C.F.R. Part 21 Subpart H 14 C.F.R. 45.27(a)

14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h) 14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.103

14 C.F.R. 91.119Exemption for Petition Page 2 14 C.F.R. 91.121

14 C.F.R. 91.203

14 C.F.R 91.151



### C.F.R. REGULATIONS

- REQUEST SPECIFIC EXEMPTION.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 1 4 CFR § 91.203

Due to the length and number of regulation with Part 21 Subpart H I am not list ing all of the text but affirming that I have read all of the regulations in preparation for the request below.

I seek to request exemption from 14 C.F.R. Part 21, Subpart H Airw orthiness

Certificates 14 CFR to the extent of not requiring a traditional airworthiness

c ertificate for the operation of a s UAS. The reason I am requesting the exemption is

due to the fact the Form 8130

- 6 does not support applicable en try to provide data about my s UAS and is not applicable to sUAS characteristics . The information requested is based on a typical aircraft. T he mechanical , electronic

, and capacity

characteristics for a sU AS are very different from a typical aircraft made for passenger or cargo transportation. As such

, the current qualification process for the

airworthiness certificate does not make sense at this time

. Once a form or process is available to support s UAS airworthiness

, I will be more than happy to submit one for processing and inspection of s UAS. I also encourage the FAA to develop a n airworthiness certification process for s UAS. Until a formal FAA process is in place

, the petitioner and pilot will follow the process es and procedures describe d herein

to obtain the same level of safety expected under the current regulation of Part 21 Subpart H

.

In addition

, the proposed multi

- rotor vehicle was built by the petitioner using

proven parts available from the sUAV market. The sUAS weight is limited to 2.1Kg

and the size is limited to 650mm. The sUAS maximum flight speed is 25 mph. In the

event of communication failure

, the sUAS will return to home position (established before flight). In the event of catastrophic failure

, the onboard parachute will be deplo y ed by pilot in command. The s UAS will be operated in a n approved restricted environment under safety procedures describe d later in this petition. Because of the small size this sUAS is safer than the typical rotorcraft.

For 91.203

, there is no cockpit or cabin

, and a s UAS does not run on fuel. I would like to be exempt from all of 91.203 as well since this regulation is not applicable to

a s UAS

. However the intent of 91.203 is applicable to sUAS to the extent of proving airworthiness for battery, frame, and motor c omponents. For this reason, recorded logs for sUAS inspection will always be in possession of the pilot in comma nd . The operations of my s UAS will have a battery maintenance plan and a rotatio n plan along with current battery telemetry information provided to the pilot. Also an yExemption for Petition Page 3

documents that are required in the future wi ll be with the s UAV pilot operating the

s UAS.

14 C.F.R. 45.27(a) : Location of marks; non fixed

- wing aircraft.

1. Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23.

I request exemption from 14 CFR 45.27 (a) to the extent of not following this regulation since it is applicable to a typical aircraft. There is no fuselage, cabin

, or boom on a multi

- rotor s UAS. However the intent of assigning a unique identifier to

a s UAS for the purposes of country and owner identification will be followed. The unique ID will be th e owner’s phone number until further direction from the FAA.

14 C.F.R. 45.29 (3) (c) (d)(e)(f) (h): Size of Marks

(3) Rotorcraft, must be at least 12 inches high, except that rotorcraft displaying before April 18, 1983, marks required by §45.29(b)(3) in effect on April 17, 1983, and rotorcraft manufactured on or after April 18, 1983, but before December 31, 1983, may display those m arks until the aircraft is repainted or the marks are repainted, restored, or changed.

(c) Width. Characters must be two

- thirds as wide as they are high, except the number “1”, which must be one

- sixth as wide as it is high, and the letters “M”

and “W” whi ch may be as wide as they are high.

(d) Thickness. Characters must be formed by solid lines one

- sixth as thick as the character is high.

(e) Spacing. The space between each character may not be less than one

fourth of the character width.

(f) If either one of the surfaces authorized for displaying required marks under §45.25 is large enough for display of marks meeting the size requirements of this section and the other is not, full size marks must be placed on the larger surface. If neither surface is l arge enough for full

- size marks, marks as large as practicable must be displayed on the larger of the two surfaces. If no surface authorized to be marked by §45.27 is large enough

for full

- size marks, marks as large as practicable must be placed on the

lar gest of the authorized surfaces. However, powered parachutes and weight

- shift

- control aircraft must display marks at least 3 inches high.Exemption for Petition Page 4 (h) After March 7, 1988, each operator of an aircraft penetrating an ADIZ or DEWIZ must display on that aircraft temp orary or permanent nationality and registration marks at least 12 inches high.

I request exemption from 14 CFR 45.29 (3) (c) )(d)(e)(f)(g)(h) to the extent of not requiring identification marks of 12 inches and applicable width, spacing

, and

thickness. I dentification (phone number or FAA unique ID requirement) will be displayed on the mo tor arms of all multi

- rotor s UAS as lar ge as possible without

e ffecting performance of the sUAS. A rough estimate would be about 3⁄4 inch font.

1 4 CFR 61.113 (a) & (b) : Pr ivate pilot privileges and limitations: Pilot in

command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an

aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employme nt 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.

(c) A private pilot may not pay less than the pro rata share of the operating expenses of a fli ght with passengers, provided the expenses involve only fuel, oil, airport expenditures, or rental fees.

I request exemption f

rom 14 CFR 61.113 (a) to the extent of not requiring a pilot’s

certificate at this time to operate a sUAS as pilot in command. I request the acceptance of Ground School Certificate and completing the petitioners tr aining program (describe d in this document) as a means of meeting (61.113) (a). In combination to Ground School Certificate I request the acceptance of Academy of

Model Aeronautics membership. This organization has a significant history with providing education for remote control devices including aircraft. Members have access to a centralized knowledge base for beginning and continuing education in aerodynamics. The m embership number for Mark Ingle is 1063718. Academy of

Model Aeronautics is located at:

5161 East Memorial Drive

Muncie IN 47302

Phone: 765.287.1256Exemption for Petition Page 5 In addition, I request that the acceptance of a complete d and approved Federal Background Check be inclu ded as a means of granting pilot in command

status. The latest background check for Mark Ingle is included in this document as

an embedded file. Click the pdf icon below to view

I request exemption from 14 CFR 61.113 (b) to the extent of receiving some portion of payment for sUAS services but not to the extent of carrying passengers or cargo since it will be impossible for my s UAS to carry more than 6 kg without significantly e ffecting flight time

. The reason I am see king this relief is to offset operational expenses until the sUAS market matures to yield profit and final regulations

. In addition, to the extent of using a remote controlled device, a secured area, and no passenger involvement, the risk of hazardous con ditions and risk to life are significantly reduced. My sUAS operation will be equally or more safe than

traditional rotorcraft. Before any services are rendered

, the pilot will be required to complete a s UAS flight training program of 100 hours total (in the air) flight time

- 60 hour s in manual mode and 40 in self

- leveling mode. The sUAS will be controlled remotely with a radio transmitter operating a t 2.4 Ghz or 5.8 Ghz

. For redundancy purposes, there will be two radio transmitters paired

, in series

, during operations

– the pilot and co

- pilot will each have one radio transmitter with the device s connected via the training port. The pilot will maintain control until verbally handing over control to the co

- pilot , if needed

. The c ertified s UAS pilot will also be required to pass a flight test demonstrated ability to fly the sUAS manually as well as

self

- level (autonomous) and show the ability to switch between flight modes at

request . The certification test will include a flight course simu lating typical flying challenges during service operations

.

The exemption from this regulation will benefit the public by providing an opportunity for developing a market in sUAS services at a lower risks and lower

startup costs t han tr aditional rotorcr aft services . And the same level of safety provided from pilot certification will be reached via the sUAS train in g program describe herein.

14 C.F.R. 91.103 (b)(1), (b)(2) : Preflight Action

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must

include

—

(a)...Exemption for Petition Page 6 (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for wh ich an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this

secti on, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

I request exemption from 14 CFR 91.103 (b)(1) and (b )(2) to the extent of not requiring landing and takeoff distance calculation since there is no runway required

for a sUAS . However, for safety, preflight calculations do apply to the operation of a

sUAS and will be adhered to:

Below is the current propos ed preflight checklist for multi

- rotor sUAS and includes preflight calculations : (Prefligh t Check list is carried out by c o

- pilot with pilot giving confirmation by the verbal response of “Check”)

Preflight Checklist

1. Confirm weather conditions

. 2. Check lock nuts on each prop.

3. Check each prop for damage or wear.

4. Check frame for cracks or loose screws.

5. Ensure motors are level.

6. Check landing gear is locked.

7. Secure battery with straps and connect/lock XT

- 60 power cord to power

distribution board

. Check for gree n indicator (LED) on electronic speed controllers while connecting.

8. Check voltage indication from flight controller and make note of current voltage and ampe rage

. 9. Co

- pilot determines E stimated Flight Time Capacity and compares to Required Flight Time from flight plan

. 10. Check operating temperature of flight controller.

11. Check receiver and transmitter controller for yaw, pitch and roll.

12. Check sub

- trims are set to zero.

13. Check low voltage alarm.

14. Check failsafe.

15. Pilot determines Estimated Flight Time Capacit y and compares to Required Flight Time from flight plan. ( This is separate from step 9. Both pilot and co

pilot calculations should match. )

16. Pilot c ompare s flight time and r oute based on flight path

17. Note w ind speed and direction. Wind must be <8 mph.Exemption for Petition Page 7

18. Che ck throttle is set to idle.

19. Arm flight controller and check for error s or warnings.

20. Stand clear no less than 10 meters and throttle up p rops to 40%.

21. Check for any vibration or note abnormal prop noise.

22. Throttle down and disarm flight controller.

23. Request pe rmission for takeoff from Safety Officer.

14 C.F. R. 91.119 (c) : Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the

aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel,
vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the

surface

—

(1) A helicopter may be operated at l ess than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- c ontrol aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

14 CFR 91.119 (a) (b) and (d)

– These regulations are applicable to the operation of a

s UAS and will be part of the flight route planning between pilot and co

- pilot to provide emergency landing area(s) and identifying restricted area(s). No flights will take place in restricted areas.

I request exemption from 14 CFR 91.119 (c) to the extent of requiring an altitude of

less than 200 feet above the surfac e unless the pilot is flying with first person video enabled equipment. Any flight route 200 feet above the surface will increase theExemption for Petition Page 8

risk of loss of sight orientation in which the s UAS pilot must recover. The pilot will comply with the flight route and altitude plans and no adjustments will be made to the route until the flight route is completed. People and property owners above flight route must also provide verbal or written permission before operations

. All public safety regulations will also be fo llowed

. Normal operations for services provided will be at very low

- altitude.

This exemption will provide for more safe operations of a s UAS since the visual line of sight limit will mitigate loss of control. The size and weight of sUAS makes this

exemp tion safer than current regulation for typical rotorcraft.

14 C.F.R. 91.121: Altimeter Settings

(a) Each person operating an aircraft shall maintain 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 altimeter setting of a station 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 setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available befo re departure; or

(2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

2 9.92 (or higher) 180 29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210Exemption for Petition Page 9 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor 29.92 (or hig her) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000

I request exemption from 14 CFR 91.121 to the extent of not following all of the regulations (91.121) as it is written due to the fact that these regulations are applicable to a typical aircraft. However the intent of the regulation does need to be

follow ed for s UAS operations. The flight controller used on my s UAS will be equipped with a micro barometer to provide altitude information via telemetry to the pilot in command . This telemetry data w ill also be visible to the copilot . The barometer will also be integrated with the configuration and operation of the flight controller to provide a way for the pilot to maintain an “ altitude hold ” automatically

. The “ altitude hold ” will be enabled by the pilot per the flight route plan that is established during pre

- flight planning. GPS altitude information will be included in telemetry information but will not be integrated with the flight con troller due to inherent risks with GPS signal loss

.

This exemption allows for further develop ment and integration of the “altitude

hold” featur e for other sUAS devices and understanding for certified pilots

. In addition, this feature will provide another architecture layer supporting public and national airspace safety during s UAS operation s . Th is specific technology, along with other advanced features, will foster other economic sector growth as a whole

. Due to the small s UAS and ability to maintain consistent altitude, this exemption will provide a safer environment than current regulations fo r full sized rotorcraft.

14 CFR 91.151 (a) and (b) : Fuel requirements for flight in VFR conditions

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to

fl y to the first point of intended landing and, assuming normal cruising speed

—

(1) During the day, to fly after that for at least 30 minutes; orExemption for Petition Page 10 (2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft und er VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

I request exemption from 14 CFR 91.151 (a) and (b) to the extent of not fol lowing these regulations (91.151 ) as it is written due to the fact that these regulations are applicable to a typical aircraft. However

, the intent of the regulation (91.151) is to

insure the safe operation of the powered aircraft while in flight and provide for extra fuel in case of emergencies. This same approach and intent will be followed for the operation of s UAS. Below is the calcu lation that will be used to determine flight time:

Flight Time Calculatio n

1. Determine the total weight of the s UAS during flight and divide weight by the

number of motors

– 4, 6, or 8. This will yield the thrust needed per motor

. 2. Multiply the thrust needed by two to p rovide lift and hover of the sUAS

. 3. Determine the amount of W atts needed to achieve hover thrust (Use manufactures specs if provided).

4. Divide power by nominal battery voltage to yield amps

. 5. Divide Battery capacity (mah) by (Number of motors x amps)) and multiply this by 60 (minutes)

. 6. Multiply this number by 0.8 (20% loss of efficiency)

. 7. The result is your estim ated flight time for hovering and lift

. 8. The amount of power to reserve for RTH should be determined during flight planning between the pilot and copilot.

This same calculation can be used in reverse to determi ne the proper motor and/or battery configuration to achieve required flight times based on operational requirements per flight route

. In some cases different video or image equipment maybe required.

Example:

Motor Specifications

Max Watts 330 Watts Battery Specifications
Working Current 16 Amps Battery Mah 5200

Hover Thrust 19 Amps Battery Volts 14.8 Max current(10s) 22 Amps Battery Amps 5.2

No Load Current 0.03 Amps Battery Watts 76.96

Internal Resistence 0.091 ohmExemption for Petition Page 11

Number of Poles 16

Prop 12x3 12x6 Watts/Motor For

Hover 71.25 Max Voltage 15 Volts Amps/Motor 4.8

AUW 2100 grams
Number of Motors 4

Thrust Per Motor 525 grams Total Flight Time 16.2 min

Thrust Needed Per Motor 1050 grams Less Eff. Loss (%20) 13.0 min

Reserve battery power will be reviewed during flight planning and will be based on

th e distance from beginning location (take off) an d the end location (landing and typically the home location). The percentage of battery reserve needed will be adjusted over time as the flight route is completed . This is due to external

environmental factors that will affect the physics of lift and directly impact power consumption during flight

– wind, humidity, and heat

. The percentage of battery

power rem aining and the distance to the end location will be used in real time calculations built into the flight controller to determine when the sUAS should land at the end location. The percentage of battery power will be displayed in telemetry

information to t he pilot in command. While in manual mode the pilot must adhere to the telemetry warning and proceed to the end location

*******

T he following summary is provided for publication in the Federal Register :

Petitioner asks for an exem ption from the followi ng rules:

14 C.F.R. Part 21 14 C.F.R. 45.27(a) 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h) 14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.103

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.203

14 C.F.R 91.151

The purpose of this request is to ope rate a small unmanned vehicle (10 l bs or less)

for aerial imaging, video, and surveillance services

. Also search and rescue services will be offer to the South Carolina Search and Rescue Dog Association at no charge. For SAR services, all operations described herein will be followed in addition to following National Incident Management System protocol. No flight operations will take place during SAR services without the consent of the Incident Commander.Exemption for Petition Page 12

Exemption from the C.F.R. regulations will provide for safer operations than using

traditional methods of rotorcraft

.

Furthermore , a sUAS powered by batteries eliminates all risk s associated with larger rotorcraft

– fuselage, flight crew and fuel. sUAS do not requ ire high

- speed aerodynamics of large mechanical moving structure to achieve lift t hat is typical of

rotorcraft t h us reducing risk even further for society.

The operation of s mall sUAS, weighing less than 10 lbs., will be conducted under

very strict rul es and conditions outlined herein , will provide an equivalent or better level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial

operat ions. The sUAS operate at slow speeds, close to the ground, and in a

controlled environment and, as a result, are far safer than conventional o perations

conducted with rotorcraft operating in close proximity to the ground and people.

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.

Respon se to Section 333 (b) (1)

Section 333 (b) (1) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS.

— In making

the determination under subsection:

(b), 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, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users

of the national air space system or the public or pose a threat to national security;

I am addressing this mandate by designing a sUAS that has visual indicators to aid in determining flight orientation and enhance visual line of sight capabilities. The key design features are flu o rescent orange props in front and fluorescent yellow in rear. In addition there will bright green LEDs in front and bright red LEDs in the rear. Focus of training will be centered toward sUAS control at long parallel distances.

T raining plan for preparation of certification for piloting a UAS:Exemption for Petition Page 13

1. Pilot In T raining will work along side a qualified or experience RC pilot for a total of 10 hours training. (These hours DO NOT count toward require d flight time)

2. Pilot In Training will log 100 hours of computer simulated flight time before training can begin in the field. (These hours DO NOT count toward required flight time)

3. 60 hours of logged flight time manual mode for the quad sUAS

4. 40 hours of logged flight time self

- le veling mode for the quad sU AS

5. Pilot will be able to safely switch between modes while in flight.

6. Each flight training session will consist of the following:

a. Preflight checklist

b. Successful take off and landing

. Pilot must demonstrate understanding and rec overy from Ground State Hove r Effect on at least one landing per session

.

c. Recover from Vortex Ring State condition per session

. d. Left and right turn circle of UAS

.

e. Recover from loss of visual line of sight ( s UAS orientation) condition from north, east, south and west.

f. Retrie val of obj ect from a distance of 50 yards.

g. Figure eight flight path for 5 minutes.

h. Hover for no less than 5 minutes at 30, 50, 100, and 150 feet.

Maintenance Plan for sUAS:

1. Preventative main tenance will be required after 2 0 hours of total flight time for each registered sUAS

. 2. Detailed records will be kept for unplanned and planned maintenance as well as auxiliary equipment that is added or removed.

3. Equipment that is rotated from the sUAS will undergo inspection and testing by an approved inspector who will sign off on each inspected part and

component.

4. All records will be retained for the life of the sUAS while in service.

5. All parts and components will be uniquely identified for tracking purposes during inspection and rotation of parts.

6. Preventative Ma intenance Tasks:

a. Check and tighten all mechanical screws. Lock tight glue should be

used on all screws. Record inspection with digital picture and date of inspection.

b. Replace all carbon fiber motor arms with new or inspected carbon

fiber arms. Record rep lacement part and date.

c. Replace landing gear carbon fiber rods with new or inspected carbon

fiber rods. Record replacement part and date.

d. Remove all propellers and inspect for cracks or damage. Replace propellers with new props. Record replacement part and date.Exemption for Petition Page 14 e. Replace electronic speed controllers with new or inspected controllers. Confirm all controllers are operating with the latest

firmware from the manufacture. Record replacement part and date.

f. Inspect all wiring and i nsure all wiring has the appropriate twist proportion to reduce magnetic fields.

g. Replace all motors with new or inspected motors. Record replacement part and date.

h. Replace flight controller with new or inspected flight controller. Confirm the flight controller has the latest fir mware from the

manufacture. Record replacement part and date.

i. Replace all worn anti

- vibration material. j. Any part of component found defective will be removed and replaced. The defective part of component will be record.

Required components for safe oper ation of sUAS

1. Flight Controller must have the following integrated components:

a. Inertia Measuring Unit

i. 3 Axis Gyro

ii. 3 Axis Accelerometer

iii. 3 Axis Magnetometer

b. Barometric pressure sensor

c. LED status indicator

d. Low voltage alarm capabilities

2. Electronic Speed Controller (ESC) must have the following:

a. LED status indicator

b. Input Frequency > 1Khz

c. Purpose built multi

- rotor ESC!!!!

3. Propellers will be attached to threaded axil attached to motor by lock nut design. No other type of nut will be used.

4. Radio controlled deployable parachute.

5. Power distribution board with gold connectors

6. Radio Transmitter with the following:

a. 2. 4 or 5.8 ghz communication frequency.

b. Battery capacity of one hour with low voltage indicator and auditable

alarm.

c. No less than 9 channels for control and monitoring sUAS

d. Training port for redundancy durin g flight and training sessions

.

e. Telemetry display with the following:

i. Battery Mah

ii. Battery voltage

iii. Radio Signal Strength Indicator (RSSI)Exemption for Petition Page 15 iv. Active Acquired Satellite Count

Operati onal Procedures

Mark Ingle w ill abide by the following limitations, restrictions, and procedures when conducting its sUAS operations under an FAA issued exemption:

1. The sUAS will be less than 10 pounds.

2. Operations will only be conducted during daylight hours.

3. Flight operations will not occur within 5 miles of any public or private airport.

4. Flights will be operated within visual line of sight of a pilot (PIC) as well as a

Co

- pilot to aid in navigation while surveying or inspecting. For safety the PIC

mus t be focused on flying 100%.

5. Maximum total flight time for each operational flight will be 30 minutes. The flight controller used on my lightweight UAS will maintain battery life calculation and alert the pilot to return to home(RTH) when 15% of battery

l ife is remaining.

6. Flights will normally be operated at an altitude less than 175 feet AGL, never exceeding 25 0 feet. The maximum airspeed will not be more than 25 mph.

7. Based on the service provided a flight area will be d etermined ahead of operations via ground survey. The flight are a will contain the flight route and a risk assessment will be determined before proceeding with planning and operations.

8. The flight area will be defin ed by no less that four longitudinal/latitudinal coordinates using approved geo spatial software. The coordinates will be known as the geo

- fencing coordinates.

9. The flight route will have a begin location (takeoff) and end location (landing) identified in the flight plan.

10. All involved in the sUAS “services” transaction will agree to the flight area

and restrictions.

11. The owner of the property where operati ons are taking place must give permission via signed wavier for the flight area.

12. Any unauthorized persons entering the fligh t area will require the pilot in command to abort the flight operation landing the sUAS in a predetermined

location.

13. A briefing will take place with all roles involved in the operations prior to beginning ope r ations

. 14. Roles for each flight operation will co nsist of:

a. Pilot (PIC) using either FPV or VLOS . Pilot will be in control of sUAS.

b. Co

- Pilot assists with navigation and maintaining a safe flight area as well as assist with Preflight Checklist

.

c. Safety Officer will inspect all areas in the flight area as w ell as continually assess weather conditions. The Safety Officer will mark flight area appropriately for public awareness when needed . SafetyExemption for Petition Page 16 Officer will maintain visual contact with sUAS at all times and maintain awareness of surrounding s in flight are a. The Safety Officer purpose is to serve as an “Air Traffic Control” function.

15. All of the roles involved during a flight operation will review the flight route and photo/video capture plans before taking flight.

16. The sUAS will not t ravel outside the flig ht area and will be enforced by:

a. Pilot and co

- pilot adherence during manual flight modes.

b. Autonomous flight control using ground station software.

17. No other personnel will be allowed in the flight area without verbal or

written consent. Operations of the f light should stop if unauthorized personnel entry flight area.

18. Roles will have appropriate safety equipment.

19. The Pilot will be trained in manual and self

- leveling flight modes for each sUAS in use. Autonomous flight training will take place as well.

20. Pilo t will have been trained in manual flight modes and require 60 hours of flight time before certified for operations. Self

- leveling certification will require 40 hours of flight time.

21. In the event of an emergency while in manual mode, the Co

- Pilot will hav e a second controller ready to take over flight of the sUAS.

22. In the event of system or component failure while in self

- leveling or autonomous flight, the pilot or co

- pilot wil l take over in manual mode. sUAS

will also have a failsafe return to home.

23. A bat tery maintenance plan will be established that includes logging of the following:

a. Date and number of Charges with beginning and ending voltage

b. Date and number of Balance Charges with beginning and ending voltage

c. Proper disposal procedures when battery rea ches end of rotation life.

Terms and DefinitionsExemption for Petition Page 17

Flight Controller

– Used to aid the pilot in flying and steering the UAS via software program executing on a microprocessor. This device also contains an Inertia Measuring Unit (IMU).

IMU

– Accelerometer, Gyroscope, and Magnetometer

Return to Home (RTH)

– This is a setting performed before flight using GPS to record the longitude and latitude of the start location.

First Person View (FPV)

– Transmitted video from the s UAS giving a forward vie w of the UAS in real time either on a monitor of FPV goggles.

Visual Line of Sight

– The view of the UAS in clear plain sight of the operator while having 100% control.

Ground Station Software

– Software integrated with flight controller over radio

fr equency using modem to modem communication between the controller and a

computer. The sUAS is flown via GPS coordinates sent to the flight controller.

Current Federal Background Check:Exemption for Petition Page 18