## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

_

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



### Cochrane Technologies, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIR EMENTS OF TITLE 14 OF

THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

3DR X8

- M OCTOCOPTER UNMANNED AIRCRAFT SYS TEM PURSUANT TO SECTION 333

OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on December 10th, 2015

Rod Reed, Chief Surveyor



### Cochrane Technologies, Inc.

3913 Highway 90 East

Broussard La., 70518

Tel: (337) 837

- 3334

Fax : (337) 837

- 7134

Email: r.reed@cochranetech.com

### TABLE OF CONTENTS

GLOSSARY O F ABBREVIATIONS 3

SU MMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 4

NAME AND ADDRESS OF PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Cochrane Technologies, Inc. SEEKS

EXEMPTION 7

THE EXTENT OF RELIEF Cochrane Technologies, Inc. SEEKS AND THE REASON Cochrane

Technologies, Inc. SEEKS THE RELIEF 10

THE REASONS WHY GRANTING Cochrane Technologies Inc.’s REQUEST WOULD BE IN THE

PUBLIC INTEREST

. 12

THE REASONS WHY GRANTING THE EXEMPTION WO ULD NOT ADVERSELY AFFECT SAFETY 15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Cochrane

Technologies, Inc.’s REQUEST 27

CONCLUSION 28

2GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorizat ion

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

OEM Original Equipment Manufacturer

P IC Pilot In Command

RTH Return

- t o

- Home

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visua l Observer

VTOL Vertical Takeoff and Landing

3SUMMARY

Cochrane Technologies, Inc. (hereinafter referred to as “ CTI ”) seeks exemption from the

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA).

This exemption will permit Cochrane Technologies, Inc. to operate an Unmanned Aircraft

System (UAS) for the commercial purpose of conducting aerial acquisitions within the National

Airspace System (NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER

CTI is a leading offshore surveying firm offering precise navigation and positioning

services. Our primary servi ce location is the Gulf of Mexico. We also offer near shore and land

surveying services for Texas, Louisiana, Mississippi, Alabama and Florida. We are

headquartered in Broussard Louisiana.

BACKGROUND

Unmanned Aircraft System: 3DR X8

- M Octocopter

CTI s eeks an exemption to operate the 3DR X8

- M O ctocopter UA S for compensation or

hire within the NAS. The 3DR X8

- M Octocopter UA is comprised of a vertical takeoff and

landing (VTOL) and a transportable Ground Control Station (GCS). The 3DR X8

- M

O ctocopter UA has a maximum gross weight of approximately 7.7 pounds wi th battery;

measures approximately 14 inches in length, 20 inches in width, and 12 inches in height; and

has a maximum speed of approximately 25 mph. The 3DR X8

- M O ctocopter UA is equipped

with four rotors, each being driven by a Lithium Polymer battery powered electric motor.

The 3 DR X8 -M Octocopter UA S th at will be operated by CTI will be r egistered in

accordance with 49 U.S.C. 44103, Registration o f Aircraft

, as well as 14 C.F.R Part 47, Aircraft

R egistration

, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Marking

.

BASIS FOR PETITION

Petitioner, C TI

, by and through undersigned r ep r esentative , pursuant to the provisions of the

Federal Aviation Regulations (1 4 C.F .R. § 11.61) and the FAA Modernization and Reform Act

of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems

, hereby petitions the

4Administrator to operate the 3DR X8

- M O ctocopter UA S within the National Airspace System

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

I n consideration of the size, weight, speed, an d limited o p erating area associated with th e

u nmanned aircraft and its operation, C TI ’ s operation of the 3DR X8 -M O ctocopter UA S meets

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate

in a ccordance with 14 C

. F.R. Part 21, Subpart H

.

Accordingly, CTI req u ests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only

apply to a ircraft w ith an a irworthiness c ertificate.

CTI su b mits that the requested r elief is proper since an equivalent level of safety will be

ensured. All main tenance, alterations, or preventive maintenance of the 3DR X8 -M Octocopter

UA S p erformed by CTI will be in accordance with the methods, techniques, and practices

prescribed in the operating documents (i.e., the 3DR X8- M O ctocopter UA S User Manual, the

3DR X8- M Octocopter UAS Quick Start Guide, the 3DR X8- M Octocopter UAS Checklists,

the Smart Flight Battery Safety Guidelines and the 3DR X8- M Octocopter UAS Pilot Training

Guide). Furtherm ore, only the Original Equipment Manufacturer (OEM) or qualified OEM

maintainers will p erform higher -l ev el inspections and maintenance per the operating

documents an d OEM standards. CTI will document and maintain all maintenance r ecords for

the 3D R X8-M Oc tocopter UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private p ilot

p rivileges and limitations: Pilot in Co mma nd

, (PIC), is requested by CTI to the extent

necessary to allow the proposed UAS flight operations to be conducted by a PIC holding a

private pilot certificate, as well as an airman medical certificate, and who has demonstrated, by

meeting minimum flight -hour and currency requirements, that the PIC is able to safely operate

the 3DR X8- M Octocopter UAS in a manner con sistent with this exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

CTI seeks relief from Section 91.7(a), entitled Civil Ai rcraft Ai r Worthiness, because the

3 DR X8 -M Octocopter UAS does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. As such, CTI submits that it will ensure that the 3DR X8 -M

Octocopter UAS is in an airworthy condition, prior to every flight, by determining tha t the UAS

is in compliance with the operating documents (i.e., the 3DR X8- M Octocopter UA User

Manual, the 3DR X8- M Octocopter UA Quick Start Guide, the 3DR X8

- M O ctocopter UA

Checklists, the Smart Flight Battery Safety Guidelines and the 3DR X8- M Octocopt er UA Pilot

Training Guide), and that the aircraft is in a condition f or safe f light.

5CTI also seeks an exemption from the r equirements of Section 91.121, entitled Altimeter

Settings

, because the altitude reporting equipment of the 3DR X8 -M Octocopter UA S set to

zero feet above ground level ( AGL), r ather than local barometric pressure or field altitude, before

each flight. The altitude information of the 3 DR X8 -M Octocopter UA S is provided to the PIC

via a b arometric p r essure sensor, Global Positioning Sys tem (GPS) equipment, and a r adio

communications telemetry data link, which downlinks from the UA S to the GCS for active

monitoring of the f

light path. A level of safety equivalent to Section 91.121 will be ensured as the

altitude of the 3DR X8 -M Octocopter UA S will be reported to air traffic control (ATC ) in feet

AGL, and to zero f

eet above ground level (AGL), r ather than local barometric pressure or field

altitude, before each flight. The altitude information of the 3DR X8 -M Oc tocopter UA S is

provided to the PIC v ia a b arometric pressure sensor, Global Positioning System (GPS)

equipment, and a r adio communications telemetry d ata link, which downlinks fromthe UA S to

the GCS for active monitoring o f the flight path. A level o f safety equivalent to Section 91.12 1

will be ensured as the altitude of the 3DR X8 -M Oc tocopter UA S will be reported to air traffic

control (ATC) in f

eet AGL, and CTI will operate the 3DR X8 -M Oc tocopter UA S within

visual l ine of s igh t, a t

o r below 400 f

eet A GL.

Additionally, CTI seeks an ex emp tion f rom r equirements of Section 91.151(b), entitled

Fuel req uirements for flight in VFR conditions

. CTI submits that safety will n ot b e af fected by

operation of the 3 DR X8 -M Oc to co pter UA S during daylight hours in visual meteor ological

conditions (VMC) under visual flight rules ( VFR), with en o u g h b attery p o wer to fly fo r a total

duration of 1 2 minutes to the first point of intended landing and, assuming normal cruising

speed, to fl y af

ter th at fo r at le ast two minutes (i.e., 20 pe r cent ba ttery po wer remaining).

In accordance with 14 C.F.R. § 11.81, C TI provides the fo llowing information in support

of its p etition f

or exemption:

A. Na me a nd Address of t he Petitioner.

The name and address of the Petitioner is:

Cochrane Technologi es, Inc.

3913 Highway 90 East

Broussard La., 70518

The point of contact for this Petition and specific contact information is as follows:

Rod R eed, Chief Surveyor

Cochrane Technologies, Inc.

3913 Highway 90 East

Broussard La., 70518

Tel: (337) 837-3334 Fax: (337) 837-7134

Email: r.reed@cochranetech.com

6B. The Specific Sections of 14 C

. F. R. fr o m wh ich CTI Seeks Exempt ion.

1. C TI Seeks Exemption f rom t he Requirements of Section 61.113(a) a nd (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

,

subsections (a) and (b) prescribe the following, in relevant part:

No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying pa ssengers or property for compensation or hire;

nor may that person, for compensation or hire, act as PIC of an aircraft.

( a) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and the

aircraft does not carry passengers or property for compensation or hire.

2. C TI Seeks Exemption f rom t he Requirements of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness

, subsec tion (a), states the following:

(a ) No person may operate a civil aircraft unless it is in an airworthy condition.

3. C TI Seeks Exemption f rom t he Requirements of Section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following

, in part:

( a) Each person operating an aircraft shall 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 s etting 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

before departure;

4. C TI Seeks Exemption f rom t he Requirements of Section 91.151(b).

Section 91.151, entitled Fuel require ments for flight in VFR conditions , subsection

(b), states the following:

(b ) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to

7the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 20 minutes.

5. CT I Seeks Exemption f rom t he Requirement of Section 91.405(a).

S ection 91.405, entitled Maintenance required , subsection (a), states the following:

Each owner or o perator of an aircraft

—

( a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of th is chapter[.]

6. C TI Seeks Exemption f rom t he Requirements of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration , subsection (a)(1), states the following:

( a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless

--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. C TI Seeks Exemption f rom t he Requirements of Sections 91. 409(a)(1) a nd

91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of

this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of thi s chapter.

8. C TI Seeks Exemption f rom t he Requirements of Sections 91.417(a) and

91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the

following:

( a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

8specified in paragraph of this section:

(1 ) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include

-- (i) A description (or reference to data acceptable to the Administrator)

of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2 ) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a spec ified time basis.

(iv) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which

the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness dire ctives (AD) and

safety directives including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next

action is required.

(vi) C opies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines,

rotors, propellers, and appliances.

(b ) The owner or operator shall retain the following records for the periods

prescribed:

(1 ) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

(2 ) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3 ) A list of defects furnished to a registered owner or operator under § 43.11

of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

9C. The Exte nt of Relief CTI Seeks a nd the Reason CTI Seeks The Relief.

1. Ext ent o f Relief CTI Seeks an d th e Reason CTI Seeks Relief f rom Section

61.113(a) an d ( b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in comma nd

, is requested to the extent necessary to allow a PIC

holding a private pilot certificate, as well as an airman medical certificate, and who

has met certain flight

- hour and currency requirements, to conduct the proposed UAS

flight operations for compensa tion or hire.

Th is relief is requested since the limitations set forth in Section 61.113(a) and

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if:

(1 ) The flight is only incidental to that business or employment; and

(2 ) The aircraft does not carry passengers or property for compensation or hire.

As set f o rth more fully below, C TI su bmits that an equivalent lev el o f safety will

be maintained because no PI C will be allow ed to operate the 3DR X8- M Octocopter

UAS unless that PIC has met certain flight -hour and currency requirements,

demonstrating that the PIC is able to safely operate the 3DR X8- M Octocopter UAS

in a manner consistent with the operations specifications as set forth herein, including

evasive and emergency maneuvers, as well as maintaining appropriate distances from

people, vessels, ve hicles and structures.

Further, C TI su b mits that all f lig h ts of the 3DR

X8 -M Octocopter UAS,

conducted b y the PIC pursuant to the g rant o f this Petition: (1) will be incidental to

CTI’s business; and (2) will not carry passengers or property fo r compensation or

h ir e.

2. E xtent of Relief CTI Seeks a nd t he Reason CTI Seeks Relief From Section

91.7(a).

Relie f fro m Sectio n 91.7(a) entitled Civil a ircraft airworthiness , is requested to

the extent required to allow CTI to d etermine that the 3DR X8 -M Octo copter UAS is

in an air worthy condition prior to every flight b y ensuring that the UAS is in

compliance with the operating documents (i.e., the 3DR X8- M Octocopter User

Manual, the 3DR X8- M Octocopter Quick Start Guide, the 3DR X8

- M Octocopter

Checklists, the Smart Flight Battery Safety Guidelines and the Phantom Pilot

Training Guide).

10CTI seeks the r equested r elief b ecause the 3 DR X8 -M Octocopter UAS d o es not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, CTI

wi ll ensure th at the 3DR X8-M Octocopter UAS is in an airworthy

condition b ased upon its compliance with the operating documents prior to every

f light and further, determine th e aircra ft is in a condition f or safe f light, as stated in

th e conditions and limita tions below.

3. Ext ent of Relief CTI Seeks a nd t he Reason CTI Seeks Relief f rom Section

91.121.

Relief f rom Section 91.121, entitled Altimeter settings , may b e required to allow

flight operations of the 3DR X8- M Octocopter UAS, because the 3DR X8

- M

Octocopter UA’s altitude r eporting equipment may b e set on the ground to zero feet

AGL, rather than l ocal barometric pressure or field altitude, before each flight. The

3DR X8- M Octocopter UAS utilizes a barometric pressure sensor, GPS equipment,

and a radio communications telemetry d ata link to downlink altitude informatio n

f romthe U A S to the P I C a t the ground c o ntrol s tation ( GCS).

Considering the limited altitude of the proposed operations, relief from 14

C .F.R. §91.121 is sought to the extent necessary to comply with the applicable

conditions and limitations stated below. As more fully set forth here in, a level of

safety equivalent to Section 91.121 will be ensured as the altitude of the 3DR X8 -M

Octocopter UA S will be reported to air traffic control (ATC ) in feet above ground

lev el (AGL), and CTI will o p erate the 3 DR X8 -M Octoc opter UAS within visual line

of s ight, a t or

below 400 f

eet A GL.

4. Ext ent of Relief CTI Seeks a nd t he Reason CTI Seeks Relief From Section

91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions , is r eq u ested to th e extent required to allow flights of th e battery p o wered

3 DR X8 -M Octocopter UA S during daylight hours in visual meteorological

conditions (VMC), under visual flight r u les (VFR) f or a total duration of 12 minutes

to the f irst point of in tended

landing and, assuming normal cruising speed, to fly after

that for at least two minutes (i.e., 2 0 percent b attery power remaining). CTI seeks the

r eq uested r elief because without an exemption f r o m Section 91.151(b), the f light time

duration of the b attery p o wered 3DR X8 -M Octo copter UA S will severely

constrain the p r acticality of any aerial acquisition and research flight operations that

C TI proposes

11to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR X8- M

Octocopter UAS, the 3DR X8- M Octocopter U AS operating documents, and CTI ’s

proposed operating limitations, ensure t hat C TI will safely operate the battery powered

3DR X8- M Octocopter UA S during daylight hours in visual meteorological conditions

( VMC) under visual f

light r ules (VFR), with enough b attery power to fly fo r a total

duration of 12 minutes to the fir st point of intended landing and, assuming normal

cruising speed, to f

ly af ter th at for at least two minutes (i.e., 2 0 p er cent b attery power

remaini ng).

5. E xtent of Relief CTI Seeks a nd t he Reason CTI

. Seeks Relief From Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 9 1.407(a)(1), 91.409(a)(1) & (a)( 2)

, and 91.417(a) &

( b) only apply to aircraft with an airworthiness certificate, CTI r equests relief f r om

these Sections because the 3DR X8- M Octocopter UAS does not require an

airworthiness certificate. As set forth more f ully below, the 3DR X8- M Octocopter

UAS meets the conditions of Section 333 of th e FMRA for operation without an

airworthiness c ertificate.

All maintenance, alterations, o r preventive maintenance on the UAS of the 3DR

X8 -M Octo co p ter UAS p er formed b y CTI will b e in accordance with the methods,

techniques, and practices prescribed in the operating documents (i.e., the 3DR X8- M

Octocopter User Manual, the 3 DR X8 -M Octocopter Quick Start Guide, the 3DR X8

-

M Octo copter Checklists, the Smart Flight Battery Safety Guidelines and the 3DR

X8-M Octocopter Pilot Training Guide). Furthermore, only the Or iginal Equipment

Manufacturer ( OEM) o r qualified OEM maintain ers will performhigher lev el

inspections an d maintenance per the operating documents and OEM standards. C TI

will d ocument and maintain all maintenance records f or the 3D R X8 -M Octo copter

UAS.

D. Th e Reasons Why Granting CTI ’s Request Would Be in t he Public Interest; That Is,

How It Would Benefit t he Public as a Whole.

Granting the p resen t Petition will further the public interest by allowing CTI to

safely, efficiently, and economically p erform aerial acquisitions and r esearch within th e

NAS, co mmercially, in support of government entities, agriculture, scientif ic studies,

r ailroad industry, and the oil and g as industries. Additionally, use of the 3DR X8 -M

Octoco p ter UAS wi ll decrease congestion of th e NAS, r ed u ce pollution, and provide

sig n ificant benefits to the economy. Notably, the b enefits of CTI 's proposed o p eration of

the 3 DR X8

- 12M Octocopter UAS will be realized without implicating any privacy issues.

1. The Public Wi ll Benefit From The Aerial Acquisition And Research Performed.

CTI submits th is Petition to commercially o p er ate the 3DR X8 -M Octo copter

UAS an d perform aerial acquisitions within the NAS, in support of government

entities, agriculture, scientific studies , mining, and industry (e.g., railroad, g as, and oil

industries). The 3DR X8- M Octocopter UAS will provide safe, efficient, and

economical aerial acquisition and research operations to further each of these fields,

all of which a re c ritical to the well

- bei n g of the general public.

The specific operations th at CTI will perform with the 3DR X8 -M Octocopter

UAS demonstrate how the requested exemption will directly benefit the abovereferenced

industries an d the public. I n the railroad, oil, and gas industrie s, the 3DR

X8- M Octocopter UAS will be used to: aid in facility inspections; survey and plan

new worksites; survey of damage cause by storms, natural disasters, and accidents;

and perform right of way a nalysis. The 3DR X8- M Octocopter UAS may also further

environmental management by mapping deforestation and surveying point source

pollution.

2. The Public Will Benefit f

rom Decreased Congestion of t he NAS.

The 3DR X8

- M Octocopter UA S is battery powered and serves as a safe,

efficient, and economical alternat ive to the manned aircraft traditionally utilized to

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform

aerial acquisitions, an exemption allowing the use of a 3DR X8

- M Octocopter UAS

would reduce the amount of manned airc raft in the NAS, reduce noise and air

pollution, and increase the safety of life and property in the air and on the ground.

Fu rthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and depa rting aircraft will be reduced.

The 3DR X8

- M Octocopter UA S does not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial survey missions would

result in fewer aircraft that must be handled by air traffic cont rol during the ground,

takeoff, departure, arrival, and landing phases of flight operations.

3. The P ublic Will Benefit f rom t he Safety a nd Efficiency of t he 3DR X8

- M

Octocopter UAS.

Conducting aerial acquisitions with the 3DR X8

- M Octocopter UAS, instead o f

manned aircraft, will greatly benefit the public by drastically reducing the levels of

13air and noise pollution generated during traditional aerial survey flight operations. By

using battery power and electric motors, the 3DR X8- M Octocopter UAS produces

no air pollution, and is the most v iable environmentally conscious alternative to the

cabin class, six cylinder internal combustion twin engine aircraft that are t ypically

u tilized for aerial acquisitions, and b u rn approximately 20-30 gallons p er hour of

leaded aviation f

u el. The 3 DR X8 -M Octocopter UA S

, while reducing the carbon

f ootprint of aerial acquisitions, also r edu ces noise pollution, as the UA S is propelled

b y b attery p owered e lectric motors, r ather t h an a n i n ternal combustion e ngine.

By using the 3DR X8- M Octocopter UAS to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually

associated with traditional manned aircraft flight operations, will be substantially

r ed uced o r

completely el imin ated. Aside f rom the lack of flight cr ew members

located onboard the aircraft, the 3 DR X8 -M Octocopter UA S (weighing

approximately 7.7 pounds at its maximum gross weight; measuring approximately 20

inches diagonally; and carrying no fuel on board), ha s less physical p otential for

collateral damage to life and property on the ground, and in the air, compared to the

manned aircraft that typically conduct aerial acquisitions (weighing approximately

6,500 pounds with a

wingspan of approximately 40 feet, a length of 34 feet, and a

fuel c apacity of 180 g allons).

4. Perf orming Aerial Acquisition Operations w ith t he 3DR X8

- M Octocopter UAS

Will Benefit t he Economy.

I n addition to being safe and efficient, the 3DR X8- M Octocopter UAS is also

an economical alternative to using manned aircraft to conduct aerial acquisitions. As

such, operation of the 3DR X8 -M Octo copter UAS will allow United States b ased

co mpanies, lik e CTI

, to r emain co mp etitive and contribute to g r o wth of the U.S.

economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Ag ency (“EPA”) regulatory a ctions p h asing out leaded aviation fuels, U.S.

owned and operated companies must adopt new and alternative technology in order

to remain competitive. Operating the ba ttery po wered 3DR X8- M Octocopter UAS is

one such technology that not only allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility without the high

operational cost of a traditional man ned air craft. B y op erating the 3DR X8 -M

Octocopter UAS, co mp an ies such as CTI

, can remain competitive and p r o f itable, and

therefore, provide greater job stability to employees and contractors, which will

ultimately contribute to g rowth of the U.S. economy. Improved financi al

performance of U.S. companies, through commercial use of the 3DR X8- M

Octocopter UAS, provides a stable workforce that increases consumer spending;

improves local, state, and federal tax revenues; and allows companies to invest in

14research and developm ent in order to remain competitive both in the United States

and abroad.

5. T here Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have b een

conducted for d ecades, C TI ’ s proposed operation of the 3DR X8 -M Octocopter UAS

will not implicate any privacy issues. Specifically, the 3DR X8- M Octocopter UAS

will only b e operated pursuant to the specific conditions and limitations set forth

herein, and in accordance with the Federal Aviation Regulations, including the

minimum al titude requirements of 14 C.F.R. § 91.119. Most significantly, the 3DR

X8- M Octocopter UA S will not be operated closer than 500 feet to any person,

vessel, ve hicle, or structure, w hich i s not directly involved in the operation.

E. Th e Reasons Why Granting t he Exemption Would Not Adversely Affect Safety, or

How The Exemption Would Provide a Level o f Safety at Least Equal t o That

Provided by t he Rule f rom Which CTI Seeks Exemption.

1. R easons Why The 3DR X8

- M Octocopter UAS Meets t he Conditions of t he FAA

Modern ization and Reform Act of 2012 (FMRA) Section 333.

I n consideration of th e size, weight, speed, and limited o perating area asso ciated

with the unmanned aircraft and its operation, CTI ’s operation of the 3DR X8 -M

Octocopter UAS meets the conditions of FMR A Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section

333 provides authority f

or a UAS to operate without airworthiness certification and

sets f orth requirements for considering whether a UAS will create a hazard to users of

the NAS or the public, or otherwise pose a threat to national security. Specifically,

FMRA Section 333 s tates the f o llowing, in part:

(a ) In General.

-- Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required by

section 334 of this Act.

(b ) Assessment of Unmanned Aircraft Systems.

-- In making the determination under

subsection (a), the Secretary shall determine, at a minimum

--

(1 ) which types of unmanned aircraft systems, if a ny, as a result of their size,

weight, speed, operational capability, proximity to airports and populated

15areas, and operation within visual line of sight do not create a hazard to

users of the national airspace system or the public or pose a threat to

national security; and

(2) w hether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems

identified under paragraph (1).

(c) R equirements for Safe Operation.

-- If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe

operation of such aircra ft systems in the national airspace system.

I n seeking this exemption, CTI submits that the 3DR X8 -M Octocopter UAS can

ope rate safely in the NA S pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the 3DR X8- M Octocopter UAS; (b) the pilot certification

requirement; a nd ( c) the specific operating limitations.

a. The S pecifications Of The 3DR X8

- M Octocopter UAS Demonstrate Its

Safe Characteristics.

The 3DR X8

- M Octocopter UAS does not create a hazard to users of the NAS or

the publ ic, or otherwise pose a threat to national security considering its size,

weight, speed, and operational capability.

i. Tec hnical Specifications of t he 3DR X8

- M Octocopter UAS.

The technical specifications of the 3 DR X8 -M Octocopter UAS are

attached h ereto as Exhibit A - Technical Specifications

. Exhibit A

contains proprietary in f o rmation an d is to be held in a separate file

pursuant to 14 C .F.R. § 11.35(b).

ii. The 3 DR X8

- M Octocopter UAS Autonomous Flight And Navigation

Mode s Enable The UAS To Remain Within A Defined Operational

Area.

The 3DR X8

- M Octocopter UAS may be operated in both semi and fully

autonomous flight modes. The 3DR X8

- M Octocopter UAS autonomous

features include the following: a GPS Position and Altitude Ho ld when

the GCS controls are released to their neutral positions; a Return -to- Home

(RTH) function; and Flight Limits (i.e, pre

- set limitations that restrict the

distance and height of the UAS flight operations).

16iii. The 3DR X8

- M Oct ocopter UAS Is Designed for Automatic Return t o

Home Point o r Auto

- Land in t he Event of Loss of t he Control Link o r

Navigation.

A complete description of the Failsafe Functions of the 3DR X8 -M

Octocopter UAS is set forth at pages 20 and 21 of the 3DR X8 -M

Octocopter User Manua l, attached hereto as Exhibit B

. Exhibit B

contains proprietary information and is to be h eld in a separate file

pursuant to 14 C

. F.R. § 11.35(b).

iv. The 3DR X8

- M Octocopter GCS a nd Its Operation.

A complete d escription of the o p eration and specifications of the 3DR X8

-

M Octocopter GCS is provided o n p ages 2 through 34 of the 3DR X8 -M

Octocopter Operation Manual attached hereto as Exhibit C

. A copy o f the

3 DR X8 -M Octocopter Operation Man ual, which contains proprietary

information, is attached hereto as Exhibit C

, and is to be h eld in a se p arate

f ile pursuant to 14 C .F.R. § 11.35(b).

b. Flight Opera tions of t he 3DR X8

- M Octocopter UAS Are Limited to t he

Line of Sight of a Certificated Pilot in Command w ith a Safety Observer.

CTI will only u tilize certificated pilots who possess a current and valid FAA

issued airman medical certificate to act as a pilot in command (PIC) of the 3DR

X8- M Octocopter UAS. Additionally, a safety observer will assist all pilots

during flight

operations.

c. Flights Of The 3 DR X8

- M Octocopter UAS Will Be Conducted Pursuant

t o Specific Operating Limitations.

I n seeking this exemption, C TI proposes to commercially o p erate the 3DR X8

-

M Octocopter UAS for the special purpose of conducting aerial acquisitions

within t he N AS, pursuant to the follow ing s pecific operating l imitations:

Operations authorized b y this grant of exemption are limited to the following

aircraft d escribed in the o p erating documents, which is a quad-rotor aircraft

weighing l ess than 7.6 pounds a t m aximum g ross w eight: 3 DR X8 -M

17 1.Octocopter Unmanned Aircraft System. Proposed operations of any other

aircraft will require a new petition or a petition to amend this grant.

2

. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial acquisit ions.

3

. The UA S may not be flown at an indicated airspeed exceeding 30 knots.

4

. The UA S 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 repo rted to ATC must be in feet AGL.

5

. The UA S 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

- is sued

airman medical certificate.

6

. The use of first person view (FPV) by the PIC or visual observer (VO) is not

permitted.

7

. 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.

Electronic messaging or texting is not permitted during flight operations. The

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

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

perform the functions prescribed in the operating documents.

8

. The VO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground base d obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9

. The operating documents and the grant of exemption must be accessible during

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

discrepancy ex ists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption 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 Administrato r upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to the 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.

1810

. Prior to each flight the PIC must 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 fo und to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

1 1

. Any UAS that has undergone maintenance or alterations t hat affect the UAS

operation or flight 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.

1 2

. The pre

- flight insp ection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

1 3

. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

1 4

. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of rep lacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description

of work accomplished, and the signature of the authorized person returning the

UAS to service.

1 5

. Each UAS operated under this exemption mus t comply with all manufacturer

Safety Bulletins.

16

. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

1 7

. The PIC must possess at least a private pilot certificat e and at least a current

third

- class medical certificate. The PIC must also meet the flight review

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is

rated on his or her pilot certificate.

1 8

. The operator may not permit any PIC t o operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate the

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

exemption, including evasive and emergency maneuvers and maintain ing

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). The VO is also required to complete the operator’s training

requirements. A record of training must be documented and made available

19upon request by the Administrator. Flights for the purposes of training the

operator’s PICs and VOs (training, proficiency, and experience

- building), are

permitted under the terms of the exemption. However, tr aining operations may

only be conducted during dedicated training sessions. During training,

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 C.F.R. §

91.119.

1 9

. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). Flights under special visual flight rules (SVFR) are not authorized.

20

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

denoted on a current FAA

- published aeronautical chart unless a letter of

agreement with that airport’s management is obt ained, and the operation is

conducted in accordance with a Notice to Airmen ( NOTAM ) as required by

the operator’s COA. The letter of agreement with the airport management must

be made available to the Administrator upon request.

2 1

. 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.

2 2

. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the plann ed operating area and land or be recovered

in accordance with the operating documents.

2 3

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

emergencies in accordance with the operating documents.

2 4

. The PIC is prohibited from beginning a f light 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 20% battery power

remaining.

2 5

. The operator must obtain an Air Traffic Organization (ATO ) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a

NOTAM not more than 72 hours in advance, but not less than 48 hours prior to

the ope ration. All operations shall be conducted in accordance with airspace

requirements in the ATO issued COA including class of airspace, altitude level

and potential transponder requirements.

2 6

. All aircraft operated in accordance with the exemption must be ide ntified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N - Number) markings in accordance with 14 C.F.R. part 45,

20Subpart C. Markings must be as large as practicable. Before conducting

operations, the radio frequ ency spectrum used for operation and control of the

UA must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

2 7

. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the UAS is

operating. These documents must be made available to the Administrator or any

law enforcement official upon request.

2 8

. The UA S must remain clear and yield the right of way to all manned av iation

operations and activities at all times.

2 9

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

30

. The UA S may not be operated over congested or densely populated areas.

3 1

. Flight operations must be conducted at least 500 feet from al l nonparticipating

persons (persons other than the PIC, VO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. B arriers or structures are present that sufficiently protect nonparticipating

persons from the UA S 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 S, flight operations must

cease i mmediately and/or;

b. Th e aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those ob jects and determined 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).

3 2

. All operations shall be conducted over private or controlled- 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.

3 3

. Any incident, accident, or fligh t operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be

reported to the FAA's UAS Integration Office (AFS -80) within 24 hours.

Accidents must be reported to the National Transportati on Safety Board (NTSB)

per instructions contained on the NTSB We b site: www.ntsb.gov.

212. R easons Why a n Exemption f rom t he Requirements of Section 61.113 (a) a nd (b)

Would Not Adversely Affect Safety.

CTI submits that

th e equivalent level o f

safety established b y Section 61.113(a)

and ( b) will be maintained because n o PIC will be allowed to operate the 3DR X8

- M

Octocopter UAS unless that PIC has demonstrated, b y m eeting minimum flight -hour

and currency requirements, tha t the PIC is able to safely operate the 3DR X8- M

Octocopter UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances fr om people, vessels,

vehicles and s tructures.

Considering C TI

’ s pro posed area of operations, and the operating limitations set

f orth- above; the parallel nature of private pilot aeronautical knowledge requirements

to those of co mmercial p ilo t requirements ( See Exemption No. 11062); and the

airmanship skills necessary to saf ely o p erate the 3 DR X8 -M Octocopter UAS, CTI

submits th at the additional manned airmanship experience of a co mmercially

certificated pilot would not correlate to the airmansh ip skills necessary for CTI ’ s

specific proposed flight o perations.

CTI will not allow any PIC to o perate the 3 DR X8 -M Octoco p ter UAS unless

that PI C has demonstrated, b y m eeting m inimum flight

- h our requirements o r the 3DR

X8 -M Octocopter UAS training and currency requirements, that the PIC is ab le to

safely operate the 3 DR X8-M Octocopter UAS in a man ner consistent with this

exemption, including evasive an d emergency man euvers and maintaining appropriate

distances f

rompeople, v essels, vehicles and s tructures.

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R . § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at

least 10 hours logged as a UAS pilot with a multi -rotor UAS (with a minimum of 5

hours of those hours as a UAS pilot operating the same make and model of UAS to be

used for operati ons under the exemption). In addition to the hour requirements, the

PIC must accomplish 3 take

- offs and landings in the preceding 90 days (for currency

purposes).

22As in Exemption Nos. 11062, 11138, and 11153, prior d ocumented flight

ex perience that was obt ained in compliance with applicable regulations will ensure an

equivalent level of safety during CTI ’s proposed operations. The Administrator h as

h eld th at prior documented flight experience that was obtained in comp liance with

applicable regulations would ensu re safe operations, stating as follows: I n Exemption

No. 11062, the FAA required that prior to co nducting operations for the purpose o f

motion picture filming (or similar operations), the PI C must have accumulated and

logged, in a manner con sisten t with 14 CFR 6 1 .51(b), 25 hours of total time as a UAS

rotorcraft p ilot including at least 10 hours lo gged as a UAS pilot with a multi -rotor

UAS. Prior

to operations under Exemption No. 11062, the PIC must also have

accumulated an d logged

a min imum of 5 hours as a UAS pilot operating the same

make an d model of UAS to be u sed f o r operations under the exemp tio n

. For

clarification, the FAA considers these minimum hour requiremen ts to be inclusive

rather than additive; i.e. 5 hours make and model time may b e included in the 10

hours o f multi -rotor time an d the 10 hours may be included in the total 25 hours of

UAS r o torcraft time. In addition to the hour r equirements, the PIC must accomplish 3

take -o ff s and landings in the p r eceding 90 d ay s (for currency purposes). The FA A

f inds th at at a min imu m, the flight -hour r eq u irements in Exemption No. 11062 are

appropriate to p r actice and build proficiency in the skills necessary to safely conduct

the p etitioner’s proposed operations. The FAA also finds that p rior d o cumented fligh t

ex perience that was o btained in compliance with applicable r egulations would satisfy

th is requirement. Tr aining, proficiency, and ex perience -b u ild ing flig hts can also b e

conducted under th e g rant of exemption to accomplish the required f lig h t time. Durin g

training, proficiency, an d ex perience -building f lights the PI C is required to operate

the UA S with appropriate d istances in accordance with 14 C

. F.R 91.119 Exemption

No. 11138 a t

p age 15.

Accordingly, CTI will en sure safe operations b y no t allowin g any PI C to o p erate

the 3DR X8- M Octocopter UAS unless that PIC has demonstrated, by meeting

minimum flight -hour and currency requirements, that the PI C is able to safely operate

the 3DR X8- M Octocopter UAS in a manner consistent with the exemption,

including evasive an d emergency maneuvers an d maintaining appropriate distances

f rom people, vessels, ve hicles a nd s tructures.

3. R easons Why a n Exemption f rom t he Requirements of Section 91.7(a) Would

Not Adversely Affect Safety.

The equivalent level of safety establ ished b y Section 91.7(a) will be maintained

b ecause prior to every flight, CTI will ensure that the 3DR X8 -M Octocopter UAS is

in an airworthy condition based upon the 3DR X8- M Octocopter UAS’s compliance

with its operating documents (i.e., the 3DR X8- M Octocopter User Manual, the 3DR

X8- M Octocopter Quick Start Guide, the 3DR X8

- M Octocopter Checklists, the

23Smart Flight Battery Safety Guidelines and the 3DR X8-M Octocopter Pilot

Training Guide, and

a s stated in the conditions and l imitations herein.

The 3DR X8 -M Octocopter UAS h as b een th e su bject of multiple Grants of

Exemption f

rom Section 91.7(a)

. Additionally, th e FAA has previously granted r elief

f rom Sectio n 91.7(a) specific to UAS, in circumstances similar, in all material

re sp ects, to those p r esented h erein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,

11161,11166, 11167, 11170, 11171, 11172).

4. Reas ons Why a n Exemption f rom t he Requirements of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by S ection 91.121 will be

maintained b ecause the altitude of the 3DR X8 -M Octocop ter UA S will be

reported to air traffic control ( ATC) in f eet above ground level (AGL), and CTI

will o p erate the 3DR X8 -M Octocop ter UA S within v isual line of sight, at or

below 400 feet AGL. Furthermore, the altitude information of the 3DR X8-M

Octocopter UAS will be provided to the PIC via a barometric p r essure sen sor,

GPS equipment and a r adio communications telemetry data link, which

downlinks

from the UA S to the GCS for active monitoring of the flight p ath and altitude.

Prior to each flight, a zero altitude initiation point is automatically established b y

the UAS a t g r ound

l evel.

The 3 DR X8 -M Octo co p ter UAS h as been th e subject of multip le Grants of

Exemption f

r om Section 91.121. The FAA has previously g r anted r elief from

Section 91.121 specific to UAS, in circumstances similar, in all ma terial respects,

to those p r esented h erein (e. g

. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161, 11166, 11167, 11170,

11171).

5. Reas ons Why a n Exemption f rom t he Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A g rant of this exemption would ensure an equivalent level of safety

es tablished by 14 C.F.R. Section 91.151(b) as a result of (1) the technical

specifications of the 3DR X8- M Octoc opter UAS; (2) the limitations on the

proposed flight

operations; and (3) the location of the proposed flight operations.

Accordingly, CTI will ensure that it will safely operate the battery powered 3DR

X8- M Octocopter UA during daylight hours in visual metrological conditions

24( VMC) under visual f light rules (VFR), with enough b attery power to fly for a

total duration of 14 min u tes to the f irst point of intended

landing and, assuming

normal cruising speed, to f ly after that for at least two minutes ( i.e.

, 20 p ercent

b attery power r emaining). Her e, as in Exemption No. 11109, the technical

specifications of the 3DR X8- M Octocopter UAS; the limitations on the

proposed flight operations; and the location of the proposed operations, will

ensure an equivalent l evel of safety established by 14 C.F.R. Section 91.151(b).

Fu rthermore, safety will be en sured as the 3 DR X8- M Octocopter UAS p r o vides

au dible and v isual warnings to the PI C at the GCS when the UA S h as low battery

power r emainin g.

Significantly, the 3 DR X8 -M Octocopter UAS h as b een the subject of

mu ltiple Grants of Exemption from Section 91.151 and other previous

exemptions g r an ted b y the FAA concerning Section 91.151 estab lish that safety is

n ot adversely affected when the technical characteristics and operating

limitations of the UAS are considered. Relief h as been g r anted for manned

air craft to o p erate at less th an th e minimums p rescrib ed in Section 91.151,

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA h as

previously granted r elief from Section 91.151 specific to UAS, in circumstances

similar, in all material r esp ects, to those p r esented h erein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080,

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,

11161, 11166, 11167, 11170, 11171, 11172).

6. Re asons Why An Exemption f rom t he Requirements of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

A ffect Safety.

I n seeking this exemption, CTI submits that the equivalent level of safety

w ith regard to the regulatory maintenance and alteration requirements established

b y Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b)

will be met b ecause all maintenance, alterations, or p r eventive maintenance of the

3 DR X8 -M Octocopter UAS performed b y C TI will be in accordance with the

methods, techniques, and p r actices prescribed in the operating d o cuments (i.e.,

the 3DR X8-M Octocopter User Manual, the 3 DR X8 -M Octocopter Quick Start

Guide, the 3 DR X8 -M Octocopter Checklists, the Smart Flight B attery Safety

Guidelines and the 3DR X8-M Octocopter Pilot Training Guide). Furthermore,

only the Original Equipment Manufacturer (OEM) or qu alified OEM ma intainers

will p erformhigher level inspections and maintenance per the operating

documents and OEM standards. CTI will document and maintain all maintenance

records f or t he 3 DR X8 -M Octocopter UAS.

25Since the 3 DR X8-M Octocopter UAS will be inspected as prescribed by the

o perating d o cuments, CTI will maintain the equivalent level of safety established

b y Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The fo llowing o p erating

d ocuments are attached hereto, identified as the following Exhibits: (A) the 3DR

X8 -M Octocopter Technical Specifications ; (B) the 3DR X8 -M Octocopter

Failsafes ; and (C) the 3 DR X8 -M Octocopter Operating Manual. The foregoing

exhibits contain proprietary information and are to be held in a sep arate file

p ursuant t o 14 C

. F.R. § 11.35(b).

Likewise, the exemption sought will not adversely affect safety because all

maintenance, alterations, o r preventive maintenance of the 3DR X8 -M

Octocopter UAS will be p erformed by CTI in accordance with the methods,

techni ques, and practices prescribed in the operating documents. Only the

Original Equipment Manufacturer ( OEM) or qualified OEM maintainers will

p erform h igher level inspections and maintenance per the operating documents

and OEM standards. C TI will document and maintain all maintenance records for

the 3 DR X8 -M Octocop ter U AS.

Furthermore, an equivalent level o f safety established b y Sections 91.407,

91.417(a) and

91.417(b), CTI will document and main tain all of the maintenance

records for the 3 DR X8

- M Octoco p ter UAS. The 3DR X8- M Octocopter UAS

h as b een th e subject of multiple Grants of Exemption from Sections 91.405(a),

91.407(a)(1) and ( a)(2), 91.409(a)(2), and 91.417(a) and (b ) and other p r evious

exemptions g r an ted b y the FA A concerning these Sections establish that safety is

n ot adversely affected when the technical characteristics and operating limitations

o f the UAS ar e co n sidered (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171,

11172).

7. The FAA May Prescribe Any Other Conditions f or Safe Operation.

I n accordance with Section 333 of the FAA Modernization and Reform Act

of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled S p ecial Conditions

, CTI

requests

that the FAA prescribe special conditions f or the intended operation of the 3DR

X8- M Octocopter UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that

established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b). Such special conditions will permit safe opera tion of the UA S for

the limited purpose of conducting aerial acquisitions within the NAS for

compensation or hire. FMRA Section 333 sets forth the requirements for

26considering whether a UAS will create a hazard to users of the NAS or the public,

or otherw ise pose a threat to national security; and further, provides the authority

for such UAS to operate without airworthiness certification in accordance with

any requirements that must be established for the safe operation of the UAS in

the NAS.

L ikewise, th e Administrator may prescribe special conditions pursuant to 14

C.F.R. § 21.16, for operation of the 3DR X8

- M Octocopter UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or

appropriate safety standards, due to the novel or unusual design features of the

aircraft. Section 21.16, entitled Special Conditions

, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft

engine, or propeller because of a novel or unusual design feature of the

aircraft, aircraft engine or propeller, he prescribes special conditions and

amendments thereto for the product. The special conditions are issued in

accordance with Part 11 of this chapter and contain such safety standards

for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety equivalent to that established in the regulations.

Se e 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C

. F.R. § 21.16,

the FAA may p r escribe sp ecial conditions for CTI's intended o p eration of the

3 DR X8 -M Octoco p ter UAS, which contain su ch safety standards that the

Administrator finds necessary to establ ish a level of safety equivalent to that

established b y 14 C.F.R. Part 21, Subpart H, an d

14 C. F.R Sections 6 1

. 1 1 3(a) &

( b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & ( b )

.

F. A S ummary That Can Be Published i n t he Federal Register, stating: The Rules f rom

w hich CTI Seeks Exemption:

CTI seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b).

A B rief Description of t he Nature of t he Exemption CTI Seeks:

This exemption will permit CTI . to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial acquisitions within the National Airspace

System (NAS).

G. A ny Additio nal Information, Views, O r Arguments Available T o Support CTI ’s

Request.

27This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

( FMRA) Section 333, which d irects the Secretary of Transportation to determine if certain

UAS may operat e safely in the NAS. As such, CTI ’ s r eq u est fo r exemption may b e g r anted

pursuant to the authority of F MRA Section 333 a nd 14 C .F.R. Part 11, a s s et f orth a bove.

FM RA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in d etail above, CTI will operate the 3DR X8 -M Octocopter UAS saf ely

in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose

a threat to national s ecurity.

CONCLUSION

As set forth h erein, CTI seeks an exemp tio n pursuant to 14 C.F.R. § 11.61 and Section 3 3 3

of the FAA Modern ization and Reform Act of 2012 (FMRA), wh ich will per mit safe o peration

of the 3DR X8- M Octocopter UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting aerial acquisitions within the National Airspace System (NAS).

B y granting this Petition, the FAA Administrator will be fulfilling the Co n g ressional mandate of

the FAA Modernization an d Reform Act of 2012, while also advancing the interests of the

public, by allowing CTI to saf ely

, efficiently, and economically opera te the 3DR X8 -M

Octocopter

U AS c ommercially within the N AS.

W HE RE FORE , in accordance with the Feder al Aviation R egulations and the FAA

Mo dernization an d R eform Act of 2012, Sectio n 333, CTI r esp ectfully r equests that the

Administrator g rant this Petition f or an exemption f

r om the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), an d p ermit CTI to operate the 3 DR X8 -M Octo copter UAS commercially fo r

the purpose of conducting aer ial acquisitions w ith in th e NAS.

28D ated: December 15 th , 2015

R espectfully submitted,

Cochrane Technologies, Inc.

Rod Reed, Chief Surveyor

Cochrane Technologies, Inc.

3913 Highway 9 0 East

Broussard La., 70518

Tel: (337) 837-3334

Fax: (337) 837 -7134

Email: r.reed@cochranetech.com

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