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9 November 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Petition of lntelinAir, Inc. for Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 To whom it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, lntelinAir, Inc. hereby applies for an exemption from Federal Aviation Regulations (FARs), identified below, to allow commercial operations of a small unmanned aerial system (UAS). This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, and any other requirements established by the FAA pursuant to Section 333 ofthe Reform Act. This exemption would permit commercial operation by lntelinAir, Inc., which uses all versions of the lntelinAir SafeSmart RD-100 UAS, lntelinAir SafeSmart RD-200 UAS, DJI Phantom 3 UAS, DJI S900 UAS, DJI Matrice 100 UAS, 3D Robotics IRIS+ UAS, and 30 Robotics Solo UAS to conduct UAS imaging, videography, inspections (agricultural and commercial), public safety demonstrations, and test flights. lntelinAir, Inc.'s operation underthe exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.2
. lntelinAir, Inc. will be operated under controlled VFR conditions at low altitude in airspace that is permitted in accordance with lntelinAir, Inc.'s approved Certificate ofAuthorization (COA). They will operate the UAS's with pilots who are current and qualified with a FAA Pilot Certificate and only after completing lntelinAir, Inc
.'s training program . Finally, when operating within controlled airspace, the controlling FAA ATC will approve the airspace in which the UAS will operate in advance
. lntelinAir, Inc. respectfully submits this request for an exemption because it operates UAS's. The operations of lntelinAir, Inc. will be conducting will be in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have confidence that the operations will be conducted at an equivalent level or greater level of safety
. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAAAdministrator's) responsibilities under Section 333(c) ofthe Reform

90 Great Oaks Blvd #202 1 San Jose
. CA 9511911ntelinAir.com

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Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system ." For your convenience, lntelinAir, Inc
. has organized this Exemption request as follows: I. Petitioner's Description II. Relevant Statutory Authority Ill. Qualifications forApproval Under Section 

### 333 ofthe Reform Act IV. Description of Proposed Operations V
. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Federal Registry Summary IX. Conclusion


### I. Petitioner's Description lntelinAir, Inc
., headquartered in San Jose, California, is a company that provides custom drone & autopilot technology designed forflight research and various commercial applications. The contact information for Petitioner is as follows: lntelinAir, Inc
. 90 Great Oaks Blvd., Suite 202 San Jose, CA 95119 

### II. Relevant Statutory Authority This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 

### 333 ofthe Reform Act, the FAAAdministrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion ofthe formal UAS rulemaking, based on the following considerations: A. The UAS's size, weight, speed, and operational capability

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B. Operation ofthe UAS in close proximity to airports and populated areas; and C. Operation ofthe UAS within the visual line of sight ofthe operator. Ifthe Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements forthe safe operation of such aircraft in the National Airspace System"
. Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). 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 §401 01 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any of sections. Ill
. Qualifications for Approval Under Section 333 ofthe Reform Act The proposed operations in this petition for exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteria and other relevant factors are satisfied
. The proposed operations would permit lntelinAir, Inc. the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. lntelinAir, Inc. uses UASs that are multirotors, weighing less than 55 pounds including payload
. They operate, under normal conditions, at speeds not to exceed 5 m/s. The multirotor has the capability to hover and move in the vertical and horizontal plane. lntelinAir, Inc.'s UASs will operate in line of sight, during daylight hours, and will only operate within a sterile area. lntelinAir, Inc
. will operate at or below 400 feet AGL and will file a NOT AM and follow any FAA requirements ifflight in controlled airspace is required. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies priorto operating a UAS. Given the small size ofthe UAS's involved and the restricted sterile environment within which they will operate, this lntelinAir, Inc.'s exemption falls within the zone of safety and demonstrate an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion offormal rulemaking
.Also, due to the size ofthe UAS's and the confined area in which these UAS's will operate, approval ofthe application presents no hazard.

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Considering the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant ofthe requested exemptions is also in the public interest. 

### IV. Description of Proposed Operations To assist the FAA in its safety assessment of lntelinAir, Inc.'s proposed UAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: 1. The UAS will weigh less than 55 pounds. 2. Flights will be operated within line of sight ofthe Pilot in Command (PIC) and/or visual observer. 3. Maximum total flight time for each operational flight will be limited to the amount oftime the UAS can be flown and still maintain a reserve battery power of no less than 25%
. 4
. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance ofthe operation
. 6. Minimum crew for each operation will consist ofthe UAS Pilot in Command and a Visual Observerwhen operating with the use of FPV equipment. Additional crewmembers may consist of a Pilot and a Camera Operator
. 7. The UAS PIC will hold 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 possession, orthe Federal government. The PIC will also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate." 8
. lntelinAir, Inc. will designate a PIC for each mission
. 9
. The UAS will operate only within a confined sterile area. 10
. Prior to the operations at a particular location, a site inspection will have been conducted
. On the day ofthe mission the PIC and any required crew members will concur on dispatching ofthe mission.

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11. A briefing will be conducted in regard to the planned UAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe sterile area be present for this briefing. 12. All UAS's will be maintained in compliance with the manufacturer's and Company guidelines. 13. In the event of an accident orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COAwill be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the NTSB. 14. Pilot in Command and Visual Observerwill at all times be able to communicate by voice
. 15. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will have been trained and tested in accordance to lntelinAir, Inc.'s UAS Aircraft Operating Manual. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies
. 17
. Ifthe UAS loses communications signal, the UAS will have the capability to return to a pre-determined location within the Sterile Area and land. 18. Contingency plans will be in place to safely terminate flight ifthere is a loss of communication between the pilot and the observer. 19. The UAS has the capability to abort a flight in case of unpredicted obstacles or emergencies. 20. lntelinAir, Inc
. will assure no individuals' privacy is violated. 21
.ATC will be contacted priorto operating in airspace otherthan G. V. Regulations From Which Exemption is Requested A. 14 CFR 

### § 91.103: Preflight Action B. 14 CFR 

### § 91.113: Right-of-Way Rules C. 14 CFR 

### § 91.119(c): Minimum Safe Altitudes D. 14 CFR 

### § 91.121: Altimeter Settings 

### E. 14 CFR 

### § 91
.151 (b): Fuel Requirements for Flight in VFR Conditions F
. 14 CFR 

### § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

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A. 14 CFR 

### § 91.103: Preflight Action lntelinAir, Inc
. requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions underwhich aircraft may operate: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. (a) Flight under IFR or a flight not in the vicinity of an airport,weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraftfor which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required ,the takeoff and landing distance data contained therein; and (2) For civil aircraft otherthan those specified in paragraph (b)(1) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance underexpected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. lntelinAir, Inc. will not operate UAS's under IFR conditions orwhen the ceilings are below 1000 feet and the visibility is below 3 statute miles. lntelinAir SafeSmart RD-100 UAS, lntelinAir SafeSmart RD-200 UAS, DJI Phantom 3 UAS, OJI S900 UAS, OJI Matrice 100 UAS, 30 Robotics IRIS+ UAS, and 30 Robotics Solo UAS have a maximum takeoff and landing radius of 5 meters. Equivalent Level of Safety lntelinAir, Inc. will ensure that the weather will be adequate to complete the mission in VFR conditions
.When lntelinAir, Inc
. operates at a high altitude location, the UAS will be test flown at gross weight to check performance limitations prior to conducting commercial operations
. B. 14 CFR 91.113: Right-of-Way Rules lntelinAir, Inc
. requests an exemption from 14 CFR 91
.113 Right-of-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule ofthis section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear
. lntelinAir, Inc
. operates small pilotless UAS's and cannot comply with these rules as they have been written. Equivalent Level of Safety lntelinAir, Inc
. operates UAS's at or below an altitude of400 feet AGL, well below the normal

90 Great Oaks Blvd #202 1San Jose, CA 95119 jl ntelinAir.com

# @lntelinAir. operating altitude of other aircraft. An lntelinAir, Inc. A PIC with extensive aeronautical experience and with knowledge ofthe avoidance rules will oversee each mission. A Visual Observerwill assist the PIC in looking for aircraft entering the operations area. It's the responsibility ofthe PIC to cease operations and land the UAS immediately whenever any aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until the threat is clear. 

### C. 14 CFR. 

### § 91.119: Minimum Safe Altitudes lntelinAir, Inc
. requests an exemption from the minimum safe altitude requirements of 14 CFR 91
.119 that prescribes the minimum safe altitudes underwhich aircraft may operate: 1. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. 2. Over otherthan congested areas at an altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Section 91.119 (d) allows for a helicopterto operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA
." To provide the intended operations, the UAS is normally operated below 400 feet AGL. Additionally, due to the nature ofthe proposed operations, the UAS will maintain a lateral distance of at least 1 00 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation. Equivalent Level of Safety lntelinAir, Inc
.'s multi-rotor aircraft weighs a maximum of 15 pounds, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated
.The UAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre-obtained consent. Because ofthe advance notice to the property owners and participants, all affected individuals will be well aware ofthe planned flight operations. Furthermore, by operating at such lower altitudes,the UAS will not interfere with aircraft that are subject to the minimum safe altitude regulations
. Finally, the lntelinAir SafeSmart RD-100 UAS and lntelinAir SafeSmart RD-200 UAS incorporate a high level of safety because both have an autopilot that leverages L1 robust adaptive control license from University of Illinois, which has been validated by NASA and the Air Force
.The DJI Phantom 3 UAS, DJI S900 UAS, DJI Matrice 100 UAS, 30 Robotics IRIS+ UAS, and 30 Robotics Solo UAS have a strong safety record as shown by the previous Section 333 Exemption approvals from the FAA.

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D. 14 C.F.R. § 91.121: Altimeter Settings lntelinAir, Inc
. seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude orflight level by reference to an altimeterthat is set to the elevation ofthe departure airport or barometric pressure. An exemption is required because the UAS do not have a barometric altimeter, but rather a GPS altitude read out. Equivalent Level of Safety An equivalent level of safety will be achieved in that lntelinAir, Inc. will confirm the altitude ofthe launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicatorto constantly monitorthe UAS's altitude, thus ensuring operation at safe altitudes
. E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions lntelinAir, Inc
. requests an exemption from 14 CFR 

### § 91.151 (a)'s fuel requirements forflight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed- (1) During the day, to fly afterthat for at least 25 minutes; or (2) At night, to fly afterthat for at least 45 minutes. The batteries powering lntelinAir, Inc.'s UAS's provide approximately 15-18 minutes of powered flight. To meetthe 30 minutes reserve requirement in 14 CFR 91.151 , UAS flights could not be conducted
. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve amount of battery life is needed
. lntelinAir, Inc. will not be conducting any UAS flights at night. Equivalent Level of Safety An equivalent level of safety will be achieved because the operations will be conducted on-site without significant transit time by the UAS. All flights will be planned to terminate with no less than 25% reserve battery power still available
. This restriction would be more than adequate to return the UAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operation ofthe UAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small UAS, and the proximity ofthe flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed
.

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F. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and {b): Maintenance Inspections lntelinAir, Inc. also seeks an exemption from the maintenance inspection requirements contained in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43
.14 and CFR 91.405(a) (stating that each owner or operator ofan aircraft "shall have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections
. . . have discrepancies repaired as prescribed in part 43 ofthis chapter")
. An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS will not have
. Equivalent Level of Safety An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with lntelinAir SafeSmart R0-100 UAS, lntelinAir SafeSmart R0-200 UAS, OJI Phantom 3 UAS, OJI S900 UAS, OJI Matrice 100 UAS, 30 Robotics IRIS+ UAS, and 30 Robotics Solo UAS User's Manuals
. The operatorwill ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety
. If mechanical issues arise, the UAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limited periods oftime during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation. VI. PUBLIC INTEREST Granting lntelinAir, Inc. an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. The vision of lntelinAir, Inc. is to help facilitate safe integration of UAS's into U
.S airspace by assuring the following goals are accomplished: Training To ensure that UAS Operators are properly trained and certified to safely operate their particular type of UAS aircraft
.Also, training will be conducted in the type of operations they will be using their aircraft. Research To help understand the flight systems of a UAS and provide research on how those systems can be approved and how safety can be maximized
. Agriculture Inspections To aid farmers of all types by assessing crops, mapping timber stands, and providing real-time data that can aid in industry that require information gathering for expansive plots of land
.

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Telecommunications Infrastructure Inspection lntelinAir, Inc. hopes to use the latest technology to perform critical inspections at the top of telecommunication tower. This will make the work of maintenance crews more efficient and safer by providing access to a real-time view ofthe systems at the top ofthe tower. Wind and Turbulence Measurement Presently it is very difficult to measure wind and otherweather variables without a tower. lntelinAir, Inc
. intends to measure these variables from a specially designed sensor mounted to the UAS. 

### VII. Privacy lntelinAir, Inc
. is committed to protecting privacy. lntelinAir, Inc. knows that many individual have concerns about privacy from the operations of UAS 's
. lntelinAir, Inc. will inform residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property. VIII. Federal Registry Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: lntelinAir, Inc. seeks an exemption from the following rules: 14 CFR 91.103; 14 CFR 91.113; 14 CFR 91.119; 14 CFR 91
.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR; 91.409(a)(2); 14 CFR 91.417 (a) & (b). Approval ofthis exemption request allows lntelinAir, Inc. to conduct commercial operations with small and lightweight unmanned aerial systems. lntelinAir, Inc
. is committed safety, education, and solutions, which enhance safety of UAS operations while reducing risk to the general public and property owners. lntelinAir, Inc.'s UAS's, weigh less than 55 pounds and are powered by batteries. This eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried on board as compared manned aircraft. The UAS is transported to the designated mission area and set up there. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofthis small UAS will provide an equivalent level ofsafety, supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight UAS's operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters. Ifadditional information is required, or ifyou have any questions regarding this Petition for Exemption, please contact the undersigned.

90 Great Oaks Blvd #2021 San Jose, CA 95119jlntelinAir.com

### Sincerely,

se VP Product (408) 972-7990 qreg@intelinair.com 

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