# ORO NOS

The Honorable Michael P. Huerta Office of the Administrator Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591 August 21 , 2015 Jacob Andrew Longhurst Dmnos CEO



### The Honorable Anthony R. Foxx Offi ce of the Secretary US Department of Transportation 1200 New J ersey Ave. , SE Washington , DC 20590 Dronos Inc. 377 E. Newsome Park Ln. South Salt Lake, UT 84115



### RE: Dronos Inc. sUAS Petition for Exemption Pursuant to FMRA Sec 333 and 14 CFR Part 11 Dear Administrator Huerta: Drono s In c. (' Dronos') h ereby petitions the FAA for regulatory relief pursuant to Section 333 of P .L. 112

- 95 and 14 C.F.R. Sec. 11.81 to conduct commercial flights using the DJI Inspire 1 a.nd the senseFly eXom sUAS for the following applications:

• Liv e Flare Stack Thermal Inspection • Wind Turbine Inspection • Solar Panel Thermal Inspection • Wedding Venue Cinematography • High Voltage Lin e Inspection • Gas Pipeline Inspect ions • Actions Sports/ Event Cinematography • Bridge Inspection Dronos , therefore, seeks a request for exemption from airworthiness and the following specific Title 14 C.F.R. provisions:

• 14 C.F.R. Part 21 • 14 C.F.R. 45.23

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• 14 C.F.R. 61.113(a) (b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(a) • 14 C.F.R. 91.9 • 14 C.F.R. 91.109(a) • 14 C.F.R. 91.119 • 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203 • 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 4 17 (a) (b) The FAA has issu ed grants of exempt ion in circumst ances simil ar in all material respects to those presented in this petition, specificall y Exemptions No. 11062 to Astraeus Aerial, 11109 to Clayco, In c . , and 11213 to Aeryon Lab s, In c . ; and we therefore request that our petition be granted without delay. Additional similar exemptions include (cinematography) o. 11806 , 11751 , 11541, 11488, 11477 , 11440 , 11401 , 11362 , and 11270 , (v ideography) No. 11842 , 11843, 11845 , 11 848, 11850 , 11820, 11822 , 11825 , 11826, 11829 , and 11833 , and (infrastructure insp ect ion , including bridges) No. 11171, 11185, 11209 , 11216 , 11230, 11224, 11237, 11278 , 11277 , 11376 , 11603, 11799 and 11835, 11564, and 11422 . Drono s has also provided supporting documentation to include; a General Operations Manual (Dro no s Manual') which is composed of (1) an operations manual , (2) flight manuals for each of the Dronos mod e ls; (3) an Op erator Tra ining Manual, (4) a Maintenance and Inspection Manual , and (5) an sUAS motion picture and television operations manual (MPT O M) . Please note that all the Dronos Manual (including all of the above listed components) are clearly marked "Confidential" on each page and contain confidenti al commercial and proprietary information that Dronos has not and will not share with others who are not subject to a. "No ndisclos ure Agreement" (NDA) . Therefore, the Dronos Manual (incl uding all components) are not available to the public and contain operating conditions, procedures and other information that are protected from public release or disclosure under the Freedom of Information Act 5 USC Sec. 552 et seq. 

### 1 Comp a n y D es cription This section responds to the specific requirements of 14 CFR Sec 11.81. Drono s In c . specializes in aerial cinematography and industrial inspections ranging from live flare stack thermal and visual inspect ions to wedding videos uti lizing the latest in drone technology. Mailing address and other contact information. ATT : Jacob Andrew Longhurst Drono s Inc.

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### 2 Re le v an t S tat u t o ry Aut ho ri ty 3

This exemption applicat i on is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the P.L . 112

- 95, the FAA Modernization and Reform Act ('Reform Act'). This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before comp letion of t h e rulemaking requ ired under Sect ion 332 of the Reform Act . In making this determinat ion, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS's size, weight, speed, and operational capability; • Operat ion of the UAS in close prox imity to airports and populated areas; and • Operati on of the UAS within vis u al line of sight of the operator. 1 Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system , the Secretary sha.ll establish r equ irements for the safe operat ion of suc h a ircraft in the national airspace system . " 2 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft , as the term is defined under §40101 of the Act , that includes sUASs, from the requirement that all civi l aircraft must have a current airworthiness certificate . 

### 3 Qualificat ion for Approval Under Section 333 of th e Reform Act The proposed operations in th is petition for exempt ion qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory cr i teria and other potent ially re l evant factors are satisfied. The requested exemption would permit Drones to perform commercial operations under controlled conditions in airspace that is 1) limited 2) predetermined 3) restricted , limited, or contro ll ed as to access and 4) woul d provide sa f ety enhancements to the a lready safe operations in these industries present l y using convent ional aircraft . Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibili

ties to "estab l ish requirements for the safe operation of such aircraft systems in the national airspace system." Secti on 333(c) of the Reform Act . Each Dr onos sUAS we i ghs 55 lb . or less including pay load . Each Dronos sUAS operates under normal conditions at a speed of no more than 87 knots. Each Dronos sUAS has the capability to operate in either Automatic' or Manual' mode as described in the Dronos Manual. 1 Public Law 112

- 95 , ' FAA Modernization and Reform Act ' Section 333 (a) 2 Id. §333(c) .

Do c 1 0: 8962f255f0 a 996efd57dfcfbfa 9291 1ef6 ba18d c4 Generally Dronos sUAS operations will be below an altitude of 400ft. AGL, within specific access restri cted areas, e ither within C lass G airspace or wi th t h e permission of the ATC , using sUAS operated by Dronos-qualified sUAS pilots, and within the visual line of sight of the operator and observer. Such operations will insure that the sUAS will "not create a hazard to users of the National Airspac e System or the public " as per the FMRA 2012 Section 333. Given the size of the sUAS and the operating environment , this petition for exemption meets an equival ent leve l of safety, in which Congress envi sioned that the FAA must , by exemption allow commercial operations of UASs to commence immediately. Also due to the size and environment, approval of the application presents no national security issue. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act , as amended , the equ iv al ent level of safety surrmmd ing the proposed operations , and the signifi cant public benefit described herein, the grant of the requested exemptions is also in the public interest . 

### 4 D ronos Description of Propo sed Operations Dronos operations will provide a level of safety that is equivalent to current aviation standards. Drono s safety procedures , risk assessments , and flight operatiom; standards are described in detail in the accompanying Dronos Manual. In brief , the following procedures that apply durin g operations conducted under this exemption request, estab lish an equival ent level of safety (ELOS) as follows: 1. The sUAS will weigh less than 55 lb. 2. Flights will be operated within lin e of sight of a pilot and/ or observer. 3. Flights will occur during daylight hours . 4. Flights will occur during Visual F light Rules Meteorological Conditions (VMC) . 5. Flights will generally be operated at an altitude of no more than 400 feet AGL and within Class G airspace. Op erations in controlled B , C, or D airspace will be conducted in coordination with the proper FSDO and ATC with prior permission. 6. Flights will be terminated at 25 % battery power reserve shou ld that occur during the operation. 7. All Dronos sUAS will be U .S. registered and display marks eith er in accordance with 14 C.F.R. Part 45, Subpart C or approved alternative markings. 8. Operations will be conducted in defined regions and over property authorized for this use by the landowner. All operations will remain within the geographic bmmdaries of the operating area. Most operations may be conducted within the limitations of the b l anket COA authorization provided with 333 grants as of 3/ 23 / 2015. 9. All required permissions and permits will be obtained from territorial , state , county or city jurisdictions, including l ocal law enfor cement , fir e, or other appropriate governmental agen cies. 10. The operator will obtain the consent of all persons involved and ensure that only consenting persons will be allowed wi thi n 100 f eet of the fli g ht operation , and this radius may be reduced to 30 feet based upon an equivalent level of safety determination.

Doc 10: 8962f255f0a996efd57dfcfbfa92911 ef6ba18dc5 11. A briefing will be conducted in regard to the planned sUAS operations prior to each day 's activ it ies. It will be mandatory that a ll personnel who will be performing d ut ies within the boundaries of the safety perimeter b e present for t his briefing . 1 2. l\.1 in imum c rew for each operation will cons ist o f the sUAS P ilot , the V isual Observer, and/ or the Camera Operator. 1 3. sUAS operat ion s un der th is exempti on will be con ducted under t he super vis ion of a des i gnated p i

lot in command (P I C) who has fina l responsibi li ty for th e operation and i n accordance with 14 C .F. R. 91.3 . All sUAS op erators must have completed train ing on the normal , abnorm al , a n d emergency proced u res i n the Dro n os Manual and demons trated profici ency with the sU AS bein g operated. The PIC will meet at l east t he m inimum FAA sUAS reg11lations for li ce n sure . Currently, therefore, Dronos PICs must posses s at least a s port pilot certificate and hold a valid U.S . driver 's license . 1 4 . s UAS Pilot will be Pilot in Command (P I C) . If a pilot certificate ho lder other than the sU AS Pi lot , who possess the n ecessa ry PIC qualifications , is also present (i . e. the Visual Obs erver) , that person can also be designated as the PI C . 1 5. Obs erver and pi lot will at all times b e abl e to maintain verbal communication , either directly or through electronic means. 1 6 . Operators and engineers will maintain t h e sUAS system in a condition for sa fe operation acco r ding to the Dronos Manu al and assoc iated man ufacturer ' s mai nte n a n ce manuals, in cluding pre-flight and post- fl ight inspections . 1 7. T h e P IC and observer s will maintain situati onal awareness a n d perceive , process , a nd perf orm risk management prior to and during each operation as described in the Dronos Manual . The PIC will terminate the operation in accordance with the Drono s Manual if hazards that cannot be acceptab l y mitigated are observed . 18. sUAS will safely stop op e r ating and either return home or auto- land at a sa fe location along the fl i ght path if the control l i nk is lost . 19. For each s UAS, the PIC will have the ability to force a controlled l anding at any time . Op e rat io ns fo r t h e purpo se of 

### clo s ed- se t mot io n pictu re an d t e l ev i s ion filming a nd produ c tion. 1. The Dron es sUAS s pecific motion picture and television operations manu al (M P T O M) will app l y to closed-set mot ion picture a n d te levision operations conducted un der the ex empt ion. 2. At least 3 days before aeri al fi lm ing, Dro n os w ill subm it a writte n P lan of Activities to the l ocal Flight Standards District Office (FSDO) >'lith jurisd i ction over the area of proposed filming . Th e plan of activities wHl include the following: • D ates and times for all flights. • Name and phone number of the Dronos point-of-contact for the UAS aerial film i ng to b e conducted . • Narne a n d phone number of t he perso n re sponsible f or the on-scene operation of the UAS . • Ma k

e, mod el , and seria l or N

- Number of UAS to b e us ed .

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• Name and certificate number of UAS PICs involved in the aerial filming. • A statement that Dronos has obtained permiss i on from property owners and/ or lo cal officials to conduct the filming production event; the list of those who gave permission must b e made available to the inspector upon request. • Signature of Dronos CEO or representative. • A d escription of the flight activit y, includin g maps or diagrams of any area, city, town, county, and/ or state over which film ing will be conducted and the altitudes essential to accomplish the operation . 3. Flight operations may be conducted closer than 500 feet from partic ipat ing persons consenting to be involved and necessary for the filming production, as specified in the Dronos sUAS MPTOM. In add it ion to the above, Dronos has implemented a Safety Management System. The Dronos Safety Manager is responsible for conducting safety audits, investigations, and inspections and is authorized to stop or prohibit any activity or operations which is considered unsafe. Full details are avail able in the Dron os Manual. 

### 5 Regulations From Which Exemption is Requested 5.1 Part 61, C e rtification: Pilots, Flight Instructor s, and Ground In structors Extent of Relief P art 61, all sections . Reas on for R e li ef Because the UAS will not carry a pilot or passengers , the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have at least a sport pilot ' s license rather than a commerc ial pilot's license to operate these sUAS . Equi valent Level of Saf e ty Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted , and all flights are planned and coordinated in advance as set forth in the General Operations Manual (GOM) . The level of safety provided by the requirements included in the GOM exceed s that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft . The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by P art 61 when dr afted, that allow ing operations of the sUAS as requested with a sport pi l ot cert ificate as the PIC exceeds the present leve l of sa f ety ach i eved by 14 C.F.R. §61.113 (a) & (b) .

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### 5.2 61.113 Private pilot privileges and limitations: Pilot in command . Exte nt of Relief R el ief from requirement to possess a private or commercial pil ot's license for aerial work such as aerial survey and mapping. Reason for Re li ef §61.113 (a) stipulates that a holder of a private pilot certificate may not act as a pilot in command of an a ircr aft for comp ensat ion or hire; (b) states that a private pilot may act as PI C if the flight is incidental to business and does not carry passengers or property. Furthermore , - 8900 .227 "Un manned Aircraft Systems (UAS) Op erational Approval" paragraph 16(c)(2)(c) " Op erat ions without a pilot certificate" states that a operations which conform to said paragraph may be performed by a PI C that does not possess a private pilots license bu t that has complete d FAA private pilot ground instruction and passed the FAA Private Pilot written test. In add iti on, there is no means currently of obtaining a commerc ial rating for UAS . Thus, we require relief in order to perform aerial work. Public Ben e fit As described above, the public benefit includes exponential economic g row th, enhanced safety, and improved prec ision agriculture capabilit i es. In general , commercial small UAS operations provide aerial services which are affordable to small businesses, something that would no t be possible without U

AS technology. Equivalent Level of Safet y Our operations fulfill all the requirements in N

- 8900.227 16(c)(2)(c) for operations without a private pilots license.



### 5.3 91.7 Civil aircraft airworthiness. Exte nt of Relief 91.7 , all provisions. Rea s on for R e lief Should the exemption be granted allow in g commercial operation of the sUAS without an airwor

thiness certificate , no standard will exist for airworthiness of the sUAS . Equival e nt L eve l of Safety Given the size and weight of these aircraft and the requirements co nt ain ed in the GOM , an equ iv a l

ent level of safety will be achieved by insuring comp li ance with the sUAS user manuals prior to each flight .

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### 5 .4 91.119 , M in imum s af e altitud es : G e n eral. Extent of Relief Section 91.119 establishes safe alt i tudes for operation of civil aircraft . 91.119(c) l imits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas, and the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. R eas on for R e li e f To prov ide for these operat ions, the sUAS are normally operated at or below 400 feet AGL. In add ition, due to the nature of the proposed operations , the PIC and the observer may at t imes be less than 500 feet away from structures during the operation . Equiva l e nt L e v e l of S a f e t y The equivalent leve l of safety will be achieved g i ven the size , weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required permission of the property owner or local officials . Because of the advance notice to the property owner and participants in the aerial activity, al l affected individuals will be aware of the planned flight operat ions. Compared to flight operations with aircraf t or rotorcraft weighing f ar more than the maximum 55lbs. desc ri bed above and the lack of flammable fuel, any risk assoc iated with these operations is far less than those presently conducted with conventional aircraft operating at or be low 500 AGL in other industries. In addition , the low

- altitude operations of the sUAS will ensure separation between these sUAS operat i ons and the operations of conventional aircraft that must comply with Sect ion 91.119 .


### 5.5 91.121 Altime t e r S ett in gs Extent of Relief §91.121 R e a s o n fo r R e li e f As the sUAS may not have a barometric alt imeter, but instead a GPS altitude read out, an exemp tion may be needed. Equivalent Level of Saf e ty An equivalent leve l of safety will be achi eved by the operator, pursuant to the GOM and the Safety Check list , confirming the a ltitude of the launch s ite shown on the GPS altitude indicator before flight.

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### 5.6 91.151 , Fu e l re qui reme n ts f or fli g h t in V F R c ond itions. Extent of Relief §91.151, all provisions . R eas on for R e li e f The provision requires fuel sufficient for one half hour flight beyond the destination . These sUAS, including todays longest endurance platforms, are unable to meet this requirement because of limited max flight times. Equiva l e nt L e v e l of S a f e t y An equ i valent level of safety can be ach i eved by limi t ing fl i ghts for the sUAS according to the safety limitations described in the GOM . This restrict i on would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area .


### 5. 7 91.405 , 91.407 , 91.409 , 91.417 Ins p e ction and M a int e nan ce Progra m s Ext e nt of Relief §§91.405, Maintenance requ ired; 91.407, Operation after maintenance, preventive maintenance, rebuilding, or alteration; 91.409, Inspections; and 91.417, Maintenance records . Reas on for R e lief The part 91 provisions are not applicable to a sUAS of the described weight class. Furthermore, FAA certified mechanics for sUAS do not at this present time exist , so full compliance is not possib le . The sUAS flown are modular and as such ent ire components includ ing eng ines and prope ll ers are minor replacements rather than major repairs. Finally, continuous minor a lterat ions and payload reconfigurations of sUAS are designed and required for the operation of sUAS and do not negatively impact airworthiness. Equiva l e nt L e v e l of S a f e t y Inspection and maintenance manuals are used to maintain the sUAS in airworthy condition . Each sUAS is maintained accord ing to the manufacturer standard or higher by technicians proficient in the bui lding , repair, and maintenance of the sUAS. Inspection and Maintenance manuals utilized contain all aircraft-relevant items as described in (43 Append i x D (Scope and Detail of Items) . Finally, maintenance records are maintained in the Operations Database; either onli ne on the Skyward Platform and are therefore immediate l y aud itable by regulators on demand, or as otherwise determined by Dronos. 

### 6 Public Int eres t Dronos believes that the enhanced safety achieved using a sUAS with the specifications described in this petition and supporting documents and by carrying no passengers or crew, rather than a

D o c 1 0: 896 2 f25 5f0 a 99 6 efd57dfcfbfa92 9 11 ef6 ba 18d c10 manned aircraft of significantly greater proportions carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operations enabled by this exemption are in the public interest. The outputs of safe , reliable , and regulatory compliant operations of s UAS provide economic benefits historically unparalleled since the invention of flight, benefiting stakeholders at every level, both public and private. Lawful , safe aerial robotics operations will create new high

- tech employment that will stimulate city and state governments; improve industries, create new small and large businesses; infuse new interest in STEM for children; and increase the safety of citizens through enhanced first-responder capabilities. 

### 7 Privacy All flights will occur over private , limited , or restricted

- access areas with the property owner's prior consent and knowledge. Operations will be conducted by trained crew and all other individuals will either be a part of the operation or consent to be present at the time of operations. 

### 8 

### Federal Register Summary Pursuant to 14 C.F.R. Part 11 , the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21 , subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§61.113( a) & (b) , 6l.133(a); 91.7 (a); 91.9 (b) (2); 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate sUAS for c01mnercial use. 

### 9 Conclusion Dronos seeks this exemption to conduct commercial operations using sUAS within restricted-access areas in the NAS. Without this exemption , sUAS innovation will be suppressed , the public economic b enefits derived from increased sUAS development will be denied , and the Congressional directive to accelerate the integration of UAS into the NAS will be impeded. The sUAS physical and operational characteristics are compliant with those described in the FMRA and FAA ' s guidance for Sec 333 exemptions. Dronos respectfully requests that the FAA grant its petition for exemption from airworthiness. Please do not hesitate to contact Andrew McCollough , the Regulatory Services POC, via email at exemption @ skyward.io if you have any questions or concerns. Very Respectfully Yours,



# faco/J #rt Jacob Andrew Longhurst Dronos CEO

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