1 March	20,	2016

Patrick	Ward

GreenLeaf	Solutions

P.O.	Box	1757 Snoqualmie,	WA		98065 Email:	patrickward@yahoo.com

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	A ve.,	SE Washington,	DC	20590

Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	2012

– Safety

Information	Addendum	to	Docket FAA

- 2015

- 6331

The	information	included	below	is	in	addition	to	the	information	provided	on September	2,	2015	in	Docket FAA

- 20 15

- 6331.		This	additional	information	details why	the	exception	wo uld	not	adversely	affect	safety,	and	describes how	the proposed	exemption	would	provide	a	level	of	safety	equal	to	or	greater	than	the rules	for	which	I	am	seeking exemption.

A ddendum A

– E quivalent	Level	of	Safety

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety because	operations	will	further	enhance	the	safety	of	the	persons	and/or	property

than	if using	conventional	aircraft.	These	limitations	and	condition s	to	which	the applicant	agrees	to	adhere	to	when	conducting	commercial	operations	under	the FAA	issued	exemption	include:

• The	UAS	will	weigh	less	than	55	lbs.

• The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	50mph.

• Flights	will	be	operated	wit hin	line

- of

- sight	of	the	Pilot	in	Command	(PIC) and/or	Visual	Observer	(VO).

• Maximum	flight	time	for	each	operational	flight	will	be	30	minutes.		Flights will	be	terminated	at	25%	battery	power	reserve	or	30	minutes	of	flight	time

- whichever	occurs	first.

• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground Level	(AGL).

• Minimum	crew	for	each	flight	will	consist	of	the	UAS	Pilot	and	the	Visual

Observer.

• The	UAS	pilot	will	be	a	designated	Pilot	in	Command	and	hold	a	Private,

Recreati onal	or	Sport	Pilot’s	License	along	with	a	Third	or	higher	Class Medical	Certificate,	or	state	issued	driver’s	license	if	the	PIC	holds	a	Sport

Pilot	License.2 • A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to each	day’s	flight	con sisting	of	all	the	days’	production	activities.

• All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions (VMC)	only.

• The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic center/Airport	Reference	Point	(ARP)	of	a	tower	c ontrolled	or	uncontrolled airport	without prior	communication	with	the	airport	and	control	tower before	flying.

• The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with the	planned	operation	and	ensure	that	only	consenting	persons	will be allowed	within	100	feet	of	the	flight	operation,	and	the	radius	may	be reduced	to	30	feet	based	upon	an	equivalent	level	of	safety	determination. With	the	advanced	permission	of	the	FSDO,	operations	at	closer	range	may be	approved.

• The	PIC	and	VO	will	h ave	been	trained	in	operation	of	UAS	and	receive	up

- to

date	information	for	the	particular	UAS	to	be	operated.

• The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all

times.

• If	the	UAS	loses	communications	with	the	remote	controller or	loses	GPS signal,	the	UAS	will	have	the	capability	to	return	to	a	pre

- determined	location within	a	designated	location	and	land	autonomously.

• The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted obstacles,	weather,	or	emergencies.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a) (1) Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural requirements	for	the	issuance	of	airworthiness	certificates	as	required	by	FAR §91.203	(a)	(1). G iven	the	size	and	limited	operating	area	associated	with	the aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	meets the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of

the	Reform	Act. The	Federal Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed, operational	capability,	and	proximity	to	a irports	and	populated	areas	of	the particular	UAS. In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS operated	without	an	airworthiness	certificate,	in	the	restricted	environment	and under	the	conditions	proposed	will	be	at	least	as	sa fe,	or	safer,	than	a	conventional aircraft	(fixed	wing	or	rotorcraft)	operating	with	an	airworthiness	certificate without	the	restrictions	and	conditions	proposed.

The	UAS	to	be	operated	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor

passe nger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates exclusively	within	a	secured	and	designated	area.	Unlike	other	civil	aircraft, operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	both3 the	operator	and	un der	the	requirements	and	in	compliance	with	local	public	safety requirements.	These	safety	enhancements	provide	a	greater	degree	of	safety	to	the public	and	property	owners	than	conventional	operations	conducted	with

airworthiness	certificates	issued	under 14	C.F.R.	Part	21,	Subpart	H. Additionally

, application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to

nat ional	security	posed	by	the	UAS due	to	its	size,	speed	of	operation,	location	of operation,	lack	of	explosive	materials	or	f lammable	liquid	fuels,	and	inability	to carry	a	substantial	external	load.

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in

Command. Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non

- commercial	operations.	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	a	private	pilot’s	license	rather	than	a	commercial	pilot’s	license

to	ope rate	this	small	UAS. 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	a dvance	as	set	forth	in	the	Manual. The	level	of	safety	provided	by	the requirements	included	in	the	Manual	exceeds	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	Part	61	when	drafted,	that allowing	operations	of	the	sUAS	as	requested	with	a	private	pilot	as	the	PIC	exceeds the	present	level	of	sa fety	achieved	by	14	C.F.R.	§61.113	(a)	&	(b).

14	C.F.R.	§91.119:	Minimum	safe	altitudes Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft. Section 91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed, provided	the	person	operating	the	helicopter	complies	with	any	route	or	altitudes prescribed	for	helicopters	by	the	FAA. As	this	exemption	is	for	a	sUAS	that	is	a helicopter	and	the	exemption	requests	authority	to	oper ate	at	altitudes	up	to	400
AGL, an	e xemption	may	be	needed	to	allow	such	o perations. As	set	forth	herein the UAS	will	never	operate	at	higher	than	400	AGL.	It	will	however	be	operated	in	a restricted	area	with	security	perimeter,	where	buildings	and	people	will	not	be exposed	to	operations without	their	pre

- obtained	consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the permission	of	the	property	owner	or	local	offici als.	Because	of	the	advance	notice	to the	property	owner	and	participants	in	the	filming	activity,	all	affected	individuals will	be	aware	of	the	planned	flight	operations. Compared	to	flight	operations	with aircraft	or	rotorcraft	weighting	far	more	than	t he	maximum	55lbs.	proposed	herein and	the	lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less4 than	those	presently	presented	with	conventional	aircraft	operating	at	or	below	500 AGL	in	the	movie	industry. In	addition,	the	low

- alt itude	operations	of	the	sUAS	will ensure	separation	between	these	small

- UAS	operations	and	the	operations	of conventional	aircraft	that	must	comply	with	Section	91.119.

14	C.F.R.	§91.121	Altimeter	Settings This	regulation	requires	each	person	operating an	aircraft	to	maintain	cruising altitude	by	reference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure airport	or	an	appropriate	altimeter	setting	available	before	departure.” As	the	sUAS may	not	have	a	barometric	altimeter,	but	instead a	GPS	altitude	read	out,	an exemption	may	be	needed. An	equivalent	level	of	safety	will	be	achieved	by	the operator,	pursuant	to	the	Manual	and	Safety	Check	list,	confirming	the	altitude	of the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight

.

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions Section	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane under	VFR	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	after	that	for	at	least	30	minutes; or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.”

The	battery	powering	the	sUAS	provides	approx imately 3 0	minutes	of	powered flight.	To	meet	the	30	minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights

would	be extremely	short in	length. Given	the	limitations	on	the	UAS’s	proposed flight	area	and	the	location	of	its	proposed	operations	within a	predetermined	area, a	longer	time	frame	for	flight	in	daylight	or	night	VFR	conditions	is	reasonable.

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope of	prior	exem ptions.	Operating	the	small	UAS with	less	t han	30	minut es	of	reserve

fuel in	a	tightly	controlled	area ( where	only	people	and	property	owners	or	official representatives	who	have given	prior	consent will	be	allowed) does	not	engender the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the size	and speed	of	the	small	UAS.

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting flights	to	30	minutes	or	25%	of	battery	power	whichever	happens	first.	This

restriction	would	be	more than	adequate	to	return	the	sUAS	to	i ts	planned	landing zone	from	anywhere	in	its	limited	operating	area.

14	C.F.R.	§91. 405	(a);	407	(a)	(1);	409	(a)	(1 ) &	(2) ;	417(a)	&	(b):	Maintenance Inspections These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft inspe cted	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required5 inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or

maintain	the	air craft	in	compliance	with	Part	43.

Given	that	these	section s and	Part	43	apply	only	to	aircraft	with	an	airworthiness certificate,	these	sections	will	not	apply	to	the	applicant. An	equivalent	level	of safety	will	be	achieved	because	maintenance	and	inspections	will	be	performed	in

accordance	with	the	UAS	Manufacturer's	User	Manual. Additionally,	the UAS	is	very limited	in	size	and	will	carry	a	small	payload	and	operate	only	in	restricted	areas	for a	limited	period	of	time. If	mechanical	issues	arise	the	UAS	can	land	immediately and	will	be	operating	from	no	higher	than	400	feet	AGL. The	operator	will ensure that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required maintenance,	and	keep	a	log	of	any	maintenance	performed. Moreover,	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.