Page 1 of 8 June 11, 2015

Laura Heller Stratis Imaging, Inc. 3213 W. Wheeler St., Suite 27 Seattle, WA 98199 Cell: (206)853-9407

Email: laura@stratisimaging.com

U.S. Department of Transportation, Docket Operation s West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

RE : Exemption Request Section 333 of the FAA Reform A ct of 2012 (P.L. 112-95)

Attachments: 1) Stratis UAV Flight and Maintenance Manual 2) Stratis UAV Pilot Training Manual

To Whom It May Concern:

On behalf of Stratis Imaging, Inc., (herein referre d to as “Stratis”) co-founders Laura Heller and Geoffrey Heller, we request an exemption from the below stated sections of Title 14, Code of Federal Regulations. This is in accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under secti on 333 of the FAA Modernization and Reform Act of 2012. This request is submitted based on the precedence s et by and is similar to Exemptions No. 11062, 11109, 11112, and 11213.

 14 CFR 61.101(e)(4) and (5) Recreational pilot pri vileges and limitations. For compensation or hire; In furtherance of busines s. It is Stratis intent to operate the UAS for commerc ial use for compensation or hire and for the pursuance of our business.

 14 C.F.R. 61.113(a) Private pilot privileges and li mitations: Pilot in

command. As previously stated, it is Stratis intent to opera te the UAS for commercial use for compensation or hire and for the pursuance of o ur business using a private pilot to command the UAS.

 14 C.F.R. 61.23(a) and (c) Medical certificates: R equirement and

duration. As Stratis intends to utilize a private pilot or sp ort pilot license holder who has a current US drivers license, an exemption from the need a medical certificate is requested. Further, the pilots UAS operations w ill be conducted on ground on a relatively light weight UAS vs. in-air on a ma nned aircraft.Page 2 of 8  14 C.F.R. 91.7 (a) Civil aircraft airworthiness. Stratis Imaging requests an exemption since there i s currently no certificate applicable to our operation other than the Section 333 Exemption which states that the PIC shall have the responsibility to deter mine airworthiness. This requirement is stated in the Flight and Maintenance Manual as well as in the Pilot Training Manual.

 14 C.F.R. 91.119(c) Minimum safe altitudes: Genera l. Stratis UAS will operate below 400 ft. This requir ement is stated in the Flight

and Maintenance Manual as well as the Pilot Trainin g Manual.

 14 C.F.R. 91.121 Altimeter Settings. The UAS will be equipped with a barometric pressure altimeter. Altitude shall be monitored using the UAS telemetry.

 14 C.F.R. 91.151(a) (1) Fuel requirements. The UAS will be powered by battery and will operate for the intended operational time with at least five minutes remaini ng battery or with the reserve power recommended by the manufacturer if gr eater.

 14 C.F.R. 91.405(a) Maintenance required. The Pilot will perform a preflight inspection of th e UAS before each flight as outlined in the attached Flight and Maintenance Man ual document. Additionally, if there is any alteration that affec ts the flight characteristics or safety, a functional test will be conducted prior t o being deemed airworthy.

 14 C.F.R. 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration. Procedures in the Flight Manual require the pilot t o monitor the UAS during a preflight inspection for airworthiness. Any altera tion shall be minor, not affect the safety of flight, and shall not affect t he basic control and stability of the UAS. Additionally, if there is any alteration t hat affects the flight characteristics or safety, a functional test will b e conducted prior to being deemed airworthy

 14 C.F.R. 91.409(a)(1) and (2) Inspections. Procedures in the Flight Manual require the pilot t o inspect the UAS during a preflight inspection for airworthiness prior to fli ght. Additionally, a flight test is required prior to the operational flight to ensu re UAS readiness.

 14 C.F.R. 91.417(a) and (b) Maintenance Records. Pilot and Operator procedures are required to monit or, inspect, and document any issues related to the UAS operation effectivene ss. This requirement is stated in the Flight and Maintenance manual.Page 3 of 8

I. About Stratis Imaging

Stratis Imaging Inc. was founded to innovate around UAS data collection and analysis. Additionally, Stratis Imaging will provide data col lection services for multiple purposes, including mapping, surveying, inspection, analysis, and general videography. Our

mission is to enhance commercial UAS data collectio n and analysis capabilities to provide new insights for industry use. Additionall y, digital imaging data gathering service will be conducted to explore the UAS market as well as provide clients with high quality images and digital data. Stratis will be p erforming research and development around UAS digital imaging as well as operational d igital imaging.

One of our primary missions as a company is to ensu re full compliance with all regulations that govern UASs. As such, our operati ons will be conducted within the acceptable FAA regulations with the exception of th e herein requested exemptions. Additionally, the referenced flight and maintenance manual as well as the pilot training manual state these requirements in their respective context. Further, the UAS Pilot and observers engaged in operations are expected to be responsible for operating within these regulatory parameters.

Safety of flight is a primary objective at all time s for our company operations with a high standard of safety awareness. Stratis has taken se veral steps to ensure safety of flight in UAS operations: First, is to be fully compliant to the relevant UAS regulations as stated above, as these regulations are in place to enhance public safety. Second, is to train all pilots and observers as outlined in the referenced pilot training manual to ensure the pilot and observer are fully qualified on Stratis Imaging UASs. Third, is to conduct flights according the flight manual as stated in the Flight and Maintenance Manual, including safe abort procedures if an unsafe condition arises . Fourth, is to ensure the UASs are operationally safe as per the inspection and mainte nance requirements as stated in the Flight and Maintenance Manual. Finally, Stratis Im aging sets the expectation that all UAS operators and participants are held to high sta ndard of safety awareness while operating a UAS.

The Co-founders of Stratis Imaging have extensive t echnology experience in both imaging as well as in aviation to help ensure a saf e, mature and experienced approach to digital imaging and technology development on a UAS platform. Co-Founder Laura Heller has over 12 years experience with aviation E ngineering and Management of commercial airplane flight controls and avionics sy stems development. She has also completed ground school training for a private pilo t’s license and has hobbyist flight hours on several small UASs. Co-Founder Geoffrey H eller has over 20 years of Engineering Management and Software Engineering exp erience as well as experience with commercial software and hardware development. Additionally, he has extensive hobbyist hours designing, building, operating and m aintaining UASs. As such, our qualifications, along with a certified pilot for UA S operation, provide the necessary qualifications for safe, compliant UAS operations.Page 4 of 8

II. UAS Description

Stratis Imaging requests Section 33 exemption for t he following UASs:

• Stratis Model 1: A quadcopter built on a DJI Flame wheel F450 frame and running the Pixhawk flight controller

• Stratis Model 2: A hexacopter built on a Tarot Iron Man 680 Pro frame and running the Pixhawk flight controller

The weight of these UAS shall be compliant with the regulations stated as less than 55 lbs in the Section 333 Exemption guidance. Please see the Flight and Maintenance Manual for a detailed description and flight characteristi cs. As stated in the Flight and Maintenance manual as well as in the Pilot training manual, the pilot is responsible for UAS airworthiness which includes following the site check list, the UAV inspections, preflight checklist, and flight test.

III. UAS Operations

When conducting Stratis Imaging operations, the fol lowing requirements will be met. These requirements are embedded in the Stratis Flig ht and Maintenance Manual, where both the Pilot and Visual observers have full respo nsibility for compliance.

• Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and

raise awareness of the beneficial uses of small unm anned air systems so long as such operations are conducted within and under the condi tions outlined herein or as may be established by the FAA as required by Section 33 3 Exemption.

• The UAS will not be operated at a speed exceeding 8 7 knots (100 miles per hour). The PIC and/or VO will use either groundspeed or ca librated airspeed to determine compliance with the 87 knot speed restriction. In n o case will the UA be operated at airspeeds greater than the maximum UAS operating ai rspeed recommended by the aircraft manufacturer as required by Section 333 Ex emption.

• Operations will be conducted below 400 feet AGL, wi th instrumentation and telemetry set to report in feet AGL as required by Section 333 Exemption

• The UAS will be operated within visual line of sigh t (VLOS) of the PIC at all times. This requires the PIC to be able to use human visio n unaided by any device other than corrective lenses, as specified on the PIC’s FAA-is sued airman medical certificate or U.S. driver’s license as required by Section 333 Ex emption.

• All operations will utilize a visual observer (VO). The UAS must be operated within the visual line of sight (VLOS) of the PIC and VO a t all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOSPage 5 of 8

capability. The VO and PIC will be able to communic ate verbally at all times, where electronic messaging or texting will not be used du ring flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC will ensure that th e VO can perform the duties required of the VO. These shall be as required by S ection 333 Exemption.

• Operate and land the UAS prior to the manufacturer’ s recommended minimum level of battery power or with 5 minutes of remaining bat tery power, whichever is greater, as required by Section 333 Exemption.

• Operating documents will be immediately accessible to the PIC and/or VO during operations. We will be responsible for ensuring th ese documents are updated as

necessary.

• Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the rem ote control pilot is lost.

• Conduct all operations under the flight safety prot ocols contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance safety protocols.

• Contact respective airports if operations will be w ithin 5 miles to advise them of his estimated flight time, flight duration, elevation o f flight and other pertinent

information.

• Upon any changes that affect UAS operations or flig ht characteristics, a functional flight test will be conducted prior to any further operations. The functional flight test will be conducted by a PIC with a VO and shall be a t least 500 feet from other people, with no undue hazard to people or property.

• A preflight inspection will be conducted by the PIC and/or VO prior to operations. Any condition that may affect the safe operation of the UAS will not be flown in operations until the UAS has been restored to a saf e flight condition. The PIC is responsible to ensure that the UAS is airworthy as part of the preflight inspection.

Refer to the UAS User’s Manual.

• The UAS operators will follow the manufacturer’s re commended maintenance; overhaul, replacement, inspection, and life limit r equirements for the UAS’ and will comply with all manufacturer safety bulletins as de scribed in the UAS Flight and

Maintenance manual.

• Have procedures in place to abort flights in the ev ent of safety breaches or potential danger.

IV. UAS Pilot in Command (PIC)Page 6 of 8

• The UAS will be operated by a PIC who holds either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a p ossession, or the Federal Government. The PIC will also meet the flight revie w requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rate d on his or her pilot certificate.

• The operators will ensure that the PIC demonstrates the ability to operate the UAS safely and within regulations under this requested exemption. This includes including evasive and emergency maneuvers and maintaining app ropriate distances from persons, vessels, vehicles and structures. PIC qual ification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b).

• Dedicated training sessions will be conducted as ne cessary to ensure the PIC is qualified to operate the UAS. During training, pro ficiency, and experience-building flights, all persons not essential for flight opera tions are to be considered nonparticipants, and the PIC will operate the UA wi th appropriate distance from nonparticipants.

Additional Requirements:

• The PIC shall successfully complete the pilot train ing as described in the pilot training manual prior to operation of the UAS’. Th is includes a minimum of 20 hours of flight hours on either Stratis Imaging's UAS and /or UAS of similar configuration.

• The VO shall successfully complete the VO training as described in the pilot training manual prior to the operation of the UAS.

V. RF Communications

The UAS’ will operate under the following Radio Fre quencies. All frequencies are used in compliance as per FCC Part 18 rules for operatin g in the specified ISM frequency

bands.

Flight Control:

 Control frequency / Working Frequency: 2.4 GHz ISM

 Control Channel Numbers of Transmitter: 16

 Communication Distance: >1.5km

 Receiver Sensitivity: > - 100 dBm

 Power Consumption of Transmitter: < 20 dBm

 Working Current/Voltage: 100mA @ 5V

Telemetry (Bi-Directional):

 Telemetry Transmitter Frequency: 915 Mhz ISM

 Communication Distance: >1.5km

 Receiver Sensitivity: > - 100 dBm

 Power Consumption of Transmitter: <= 20 dBmPage 7 of 8

 Working Current/Voltage: 100mA @ 5V

Camera / Live Video to Monitor:

 Video Transmitter Frequency: 5.8 Ghz ISM

 Communication Distance: >200m

 Receiver Sensitivity: > - 100 dBm

 Power Consumption of Transmitter: <= 20 dBm

 Working Current/Voltage: 100mA @ 5V

VI. Public Benefit

Utilizing UAS for the purposes of aerial image data gathering and analysis is a growing industry that takes advantage of the small, lightwe ight, and less expensive technologies. Contrasted with manned aircraft, there is substanti al more versatility, far less cost, and significant reduction in risk to the public by util izing UASs. Additionally, more extensive research and development can be conducted to enhance image data gathering and analysis technologies. This is one of Stratis Imaging’s primary intentions. Because of this research and development, valuable new tech nologies will be developed. This can add jobs to the economy, improve industry efficienc y, and increase awareness of our environment in ways not previously possible. By gra nting this exemption, these benefits can be achieved to the betterment of public overall

.

VII. Confidentiality

We request that the FAA refrain from publishing any of the Stratis Imaging’s provided documents to the public. This includes the UAS Fli ght and Maintenance Manual as well as the UAS Flight Training Manual. These documents are intended for Stratis employees and the FAA personnel only who are responsible for the evaluation and determination of this exemption request.

VIII. Summary

Stratis Imaging requests an exemption from the belo w list of regulations for UAS commercial operations, including data collection an d analysis services as well as research and development.

14 C.F.R 61.101(e)(4) and (5) 14 C.F.R. 61.113(a) 14 C.F.R. 61.23(a) and (c) 14 C.F.R. 91.7 (a)
14 C.F.R. 91.119(c)

14 C.F.R. 91.121 14 C.F.R. 91.151(a) (1) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(1) and (2) 14 C.F.R. 91.417(a) and (b)Page 8 of 8

The public will benefit by virtue of additional emp loyment, safer methods of data gathering, and potentially new technologies availab le to industry. It is our commitment to comply with all of the conditions and limitation s stated within the exemption, should it be granted.

Please contact the undersigned for any further info rmation or questions regarding this petition. Thank you for your consideration.

Respectfully,

Laura Heller Founder, Stratis Imaging, Inc.