### October

### 261 h, 

### 2015 

### James Pimley RPM Logistics. Inc [RPML] 33470 Chinook Plaza Scappoose, Or 97056
To whom it may concern, . )



### Pursuantto Section 333 ofthe FAA Modernization and Reform Act of

### 2012 (the Reform Act) and 

### 14 C F.R. Part 

### 11, James Pimley operator at RPM Logistics seek an exemption from Federal Aviation Regulations detailed herein forthe operation of lightweightaerial imaging equipment, also referred to throughout as Unmanned Aerial Systems (UAS), as well as their ground based operation equipment described-within. RPM Logistics, 

### INC will be referred to as 

### RPML. For photography and videography for advertising and real estate, wildlife monitoring, and wildland fire suppression and documentation efforts, in c;ompliance with all FAA and Forest Service air space rules and regulations. Ouroperation will include:
• Real Estate Photographyand Videography • Commercial Advertising Video and Photography • Wildlife Monitoring • Wildland Fire Suppression and Videography • FREE services offered to ourcommunity,firefighters, educators and lawenforcement. • RPML is afederally designated Critical Resource (Agreement AG-0248-B-14-7086 from OF-294) participating in disaster response and is on the National ROSS (Resource Ordering and Status System) list. When public and private property,watersheds and forest resources are at risk, it is in the public interestfor RPML to have UAS available for managing, monitoring and controlling incidents on a case by case basis. • RPML flies with a hand held aircraft radio set on local frequencies to keep trackof aircraftsuch as crop dusters and experimental planes.below400AGL.

' 

# .. ! ··' •. · '/ 

## '

,, •:r ,:

# RPML UAS include thefollowing: Solo 

## by 3DR Robotics (RPM 111)

The Solo system includes Solo, the Controller, and the Solo App. As the operator, you interact with the controller and app on the ground and the controller communicates with Solo during flight.

Estimated flight time Default maximum altitude Range Payload capacity

Cruise speed Maximum speed Wind speed limitation Operatingtemperature up to 

### 25 minutes* 150ft. {46 m) above ground level** 

### .5 miles*** 

### {.8 km) 

### lib. (450 

### g) 

### 18 mph 

### {8 m/s) 

### 33 mph {15 m/s)**** 

### 25 mph 

### (11 m/s) 

### 3rF- 113° F(0° 

### c to45° 

### C)

The altitude and distance are set in a geo-fence which is part ofthe Solo programming.

## Iris Plus by 3DR Robotics {RPM 333)

IRIS is a personal aerial imaging platform powered by open-source hardware, software, and firmware. Weight with battery: 1282 g Payload capacity: 400 g (.8 lbs) Radio range: up to 1 km (.6 miles) Flighttime: 16-22 minutes*

A safety fence restricts IRIS·to within 300 meters (980 feet) ofthe launch point and under 100 meters (320 feet) in altitude. If IRIS reaches the edge ofthe geo-fence itwill stop until operator returns itto the starting point.

## Phantom Vision 

## by DJI (RPML222)

The Phantom Vision is asmall quad copterthat uses GPS to maintain its location and flight direction. This quad copter has built is safety settings that keep it outof flight paths and to close to airports: Ready to Fly mode Zone Restriction DJI VISION App Notification Rear LED Flight Indicator No-flyZone Motorswill not start. Warning: You are in a No-flyzone. Take off prohibited. Ifthe Phantom enters the restricted area in Ready to Fly (non-GPS) mode but Ready to Fly mode activates, the Phantom will automatically descend to land then stop its motors after landing. Warning: You are in a No-fly zone, automatic landing has begun. (Ifyou are within 1.5 mite radius) Restricted-altitude flight zone. Ifthe Phantom enters a restricted area in Readyto Fly (non-GPS) mode and Ready to Fly mode activates, itwill descend to a safe attitude and hover 15 feet belowthe safe altitude. Warning: You are in a restricted zone. Descending to safe altitude. (Ifyou are between the range of 1.5 mile and 5 mile radius) Maximum payload 1350g Operating Frequency 5.728 GHz-5.85 GHz Communication Distance (open area) CE Compliance: 300m; FCC Compliance: 500m Transmitting Power (EIRP) CE Compliance: 2SmW; FCC Compliance: 125mW Range Extender Operating Frequency 2412MHz- 2462MHz Communication Distance**(ope~** area) 300m Transmitting Power 17dBm ·

## I. FLIGHT 10 

## I NO.:
FLIGHT LOCATION:---------



## w~ 

## --------------------- UNMANNEDAIRCRAFT SYSTEM: MANUFACTURER:·. MODELNUMBER: PREFLIGHT CHECKLIST: U Batteries Charged & SecurA 0 Aircraft Hardvllare OK 0 Equipment &GearOK 0 Transmitter Controls OK · CREW: PILOT: SPOrreR: ----------

0 PropsOK &llght 0 SoftwareI FirmWQt'!l Update 

## d TransmitterControl PovllerON 0 Ain:rafl: PowerON 0 llompass Calibration 0 Cemlllp/FPVON 0 SatelliteConnection D Applications I OtherSystemsON OPERATIONAL CONDffiONS & PREFLIGHT NOTES: "' 

# I .. REMAAKS SESSION FLIGHT FLIGHTTIMES INTERVALS ...

**---.....,.~** - 

### ..

# ------------· ···------··-- START srOP TOTAL PROCEDURES &MANEUVFRS 1. 2. 3.



### ... 4. 5. fl. 7. 8. 9. 10. TOTAL HOURS FOR SESSION TOTAL FORWARD 

# !

TOTAL TO DATE 110

## II. 

## FLIGHT MAP Month

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' 

# .

POSTFLIGHT NOTES I JOURNAL ENTRIES:

I CERTIFY THATTHE FOREGOING ENTRIESARETRUEAND CORRECT: 

### Day

_ _.___

4

## " Year

### ~lO~------------------------------- SPOTTER:-------------------'------- 

### 109The current regulations that we seek exemption from are: A. 14CFR Part 21 (h) Airworthiness Certification Underthis part we seek exemption to apply for and maintain airworthiness certification for our UAS. Model and serial number ofour UAS will be provided within. B. 14CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness We seek exemption from this part, as we will keep our UAS in a 

### safe, reliable, and airworthy condition, it may not meet all standards as set for by this part ofthe FAR's. Operator will assume all responsibility for determiningthatthe UAS is in a condition safe for flight, as well as a condition that will not harm other people or property. This will be accomplished using specific guidelines from the manufacture 3DR robotics, DJI, as well as following any guidance set for routine maintenance. C. 14CFR Part 91 Subpart C: 91.203: Certifications Required • We seek exemption from this part as an airworthiness certificate does not apply to our specific UAS Under this part, (a) no person may operate an aircraft unless it has within itthe following; an appropriate and current airworthiness certificate. This part also includes regulations regarding the use offuel tanks, which do not apply because it operates on battery power only. D. 14CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude • We seek exemption from this part due to the nature ofthe operation, as well as the safety procedures set forth will have littleto no risk ofdamaging any person orstructure. Under this part, (a) no person may operate an aircraft below an altitude allowing, if powerfails, an emergency landing without undue hazard. (c) Over otherthan congested areas an altitude below400ft AGL. E. 14CFR Part 91 Subpart 8; 91.121 (a)(1) Altimeter Setting • This section pertains to setting an altimetersetting below 18000ftto a reported altimeter reporting station setting. • We seek expedition from this part as our UAS has no way ofsetting an alternate altimeter setting. Operating less than 400ftAGL, we feel our UAS will have little to no impact on other

. participating aircraft. Also our UAS will not need to recalibrate its altimeterwhile in flight. F. 14CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight • This section contains requirements for fuel in VFR flight for combustion engines. • We seek exemption from this part as our UAS operates offof battery power only. We feel our operations will not compromise safety to eitherthe operator or property as we have set forth a procedure to land our UAS when the battery level reaches 25%, orapproximately 5 minutes flight time remaining.

G. 14CFR Part 91 Subpart E; 91.405 Maintenance Required• This section contains requirementsforthe operatorto maintain and have inspected the aircraft in accordance with Part 43 ofthe CFR. Underthis section it is required to keep maintenance logbookswith the aircraft. It also requires the aircraftto contain placards ofthe

.inoperative equipment.

• We seek exemption from this part as our UAS will not be operating with inoperative equipment and is too small to carry logbooks. We also seek exemption dueto no certified maintenance technicians will workon the UAS. Underthis exemption RPM Logistics will be completing pre-flight and post-flight inspections, and any required maintenance or repairs will be completed bythe manufacturerorone ofits certified technicians. H. 14CFR Part91 Subpart E; 91.407 OperationAfter Maintenance • This part requires an aircraft that has undergone repair, rebuilding, alterations, orgeneral maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11. • We seek exemption from this part as these inspections do not pertain to ouroperation ofthe UAS. The operatorwill be responsible fordeterminingthe airworthiness ofthe UAS priorto each flight. After maintenance provided by the manufacturer, the operatorwill complete testflights before any operation in thevicinity of persons or propertyto assure all systems are functioning normally. I. 14CFR Part 91 Subpart E; 91.409 Inspections • This section provides details ofthe required inspection on an aircraft. No person will operate an aircraft unless in the preceding 12 months has had (1) an annual inspection (2) an issuance of an airworthiness certificate. • We seek exemption from this partas the inspection and airworthiness certificate to not apply to our UAS. Our operatorwill be responsible forthe inspection and airworthiness determination priorto each flight and will have the UAS repaired by the manufacturer orone ofits certified technicians, ifthe UAS is**fo~nd** to be in a state otherthan intended by the manufacturer. 

### J. 14CFR Part 91 Subpart E; 91.417 Maintenance Records • This section requires the owner/operatorto complete and retain a list ofall records pertaining to the work performed, the date ofcompletion, the signature ofthe inspector, and all work performed on the aircraft. • We seek exemption from this part as the inspections and technician workwill notapply. Our operatorwill be responsible fordeterminingthe airworthiness ofthe UAS priorto each flight and will notoperatethe UAS in any condition other**t~an** intended bythe manufacturer. The operatorwill keep records ofall work completed by the maintenance facility. K. 14CFR Part91 Subpart B; 91.103 PreflightAction • This section requires each pilot priorto flight will become familiar will all available information pertainingtothatflight including runway lengths, flight information, weather, etc. For anyflight, runway lengths at airports ofintended use, and the followingtakeoffand landing distance information include; all applicable information relatingto aircraft performance, airpo,rt elevation, runway slope, airc·raft gross weight, wind and temperature. • We seek exemption from this part as ouroperator, while utilizing all available information for the safe operation ofthe UAS, will not have the above information available for most flights. Theoperatorwill use good judgment and all resources available to ascertain the information necessary forthe safe operation ofthe UAS. A preflight inspection will be accomplished according to the manufactures instructions priorto each flight. 

### L. 14CFR Part 91 Subpart B; 91.105 Flight Crew members Stations • This section pertains to the required crew members being at their stations during all phases of flight, and requires the use ofseat belts and shoulder harnesses. • We seek exemption from this section as it pertains to aircraft with flight crew member stations. Our UAS does not have such stations. M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manual • This part states no aircraft may operate without a manual onboard the aircraft.
o Our UAS is not large enough tocarry such operating manual. We will however carry acurrent manufacturer manual in the UAS carrying case along with the operator on all flights. M. 14CFR Part 45.23 • Underthis part, it is required that each operator must display on that aircraft markings. • Our UAS is too small to attach large markings.We seek exemption from this part as we will be attaching all registration orserial number as required on the UAS itself.

Thank you for considering these exemptions. Ifthere is any additional information required please contact us.

RPM Logistics 33470 Chinook Plaza Scappoose, Or97056 503-799-8774