# ~HALIDE SOLUTIONS
14 November2015 

### Section 333 Petitionfor Exemption to Allow Commercial Use ofUnmanned AircraftSystem

U.S. DepartmentofTransportation, Docket OperationsWest Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590



### Petitioner: Halide Solutions LLC Attn: Sara Pandiyan 534 Appaloosa Avenue Shakopee MN 55379 Email: Sara.Pandiyan@halidesmart.com Website: www.halidesmart.com

Dear Sir/Madam:

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal · Aviation Regulations from: 14CFR 21 subpart H; 14CFR 45.23(b); 14CFR 61.113(a); 14CFR 91.7(a); 14 CFR 91.9(b)(2); 14CFR 91.103; 14CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b) and any other rules the FAA deems necessary, to enable Halide Solutions LLC to operate unmanned aircraft systems ("UAS") for aerialvideo and/or photographyand training as mentioned below using DJI Phantom Ill Quad copter, DJI Phantom Ill Advanced, DJI Phantom Ill Professional, 3DR Solo and Yuneec QSOO+

. Because this petition is similar in all material respects to previously-granted Section 333 petitions, Halide Solutions LLC requests expedited approval pursuantto the FAA's summarygrant process.



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# ~ HALID.E SOLUTIONS

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Halide Solutions LLC, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein oras my be established by the FAA as required by Section 333. Commercial operation UAS, as described herein, which are equipped with cameras and sensors, would operate in the following manner: 1. Aerial photography and/orvideo for public and/or private use including real 

### estate, architecture, land surveying, engineering and other related professional and marketing activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering. 3. Aerial inspection/photography of residential/commercial structures undercontract with the owners or local government authority. 4. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities orgovernment has requested it by contract ordonation. 5. The abilityto offertraining to persons individually or belonging to both private and/or public organizationsthat have interests in the use and application of UAS forthe purpose ofthe safe operation of UAS to enhance the safety ofthe National Airspace System (NAS) as well as forthe protection ofthe persons and property.

As described fully below, the requested exemption would permitthe operation ofsUAS under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) will provide safety enhancementsto the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would therebyenhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

The name and address ofthe applicant: Halide Solutions LLC Attn:Sara Pandiyan Ph: 763.350.7751 Email: Sara.Pandiyan@halidesmart.comAddress: 534 Appaloosa Avenue, Shakopee MN55379

Device: DJI Phantom Ill Quad copter, DJI Phantom Ill Advanced, DJI Phantom Ill Professional, 3DR Solo, Yuneec Q500+



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# .'2 HALIDE SOLUTIONS and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh less than 55lbs. 2. Flights will be operated within line ofsight ofa pilot and/orobserver. 3. Maximum flight time foreach operational flight will be 30 minutes. Flights will be terminated at25% battery power reserve or30 minutesofflighttime whichever occurs first. 4. Flights will be operated atan altitude ofno more than 400feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist ofthe UAS Pilotthe Visual Observer (VO) and may include but not limited to a Camera Operator. 6. The UAS pilotwill be a designated Pilot in Command (PIC) and hold a currentThird or higherClass Medical Certificate, along with avalid state driver's license. Ifthe PIC feels anotheroperatorto be qualified with the necessary skills to be PIC 

### &possess aThird or higherClass Medical and avalid state driver's license, that person may be designated PIC provided they have a minimum of20 hours offlight time withthe UAS. 7. A briefing will be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities. 8. The operatorwill obtainverbal/written consent ofall persons involved withthe planned operation and ensure thatonlyconsenting persons will be allowed within 100feetofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM. Withthe advanced permission ofthe FSDO, operations atcloser range may be approved. 9. The PIC and VO will have been trained in operation ofUAS and receive up-to-date information forthe particular UAS to be operated. 10.The PIC and VO will be able to communicate byvoice, radio, and/ortext atall times. 11. Written and/orverbal permission and permits will be obtained from territorial, state, county orcity jurisdictions, including lawenforcement,fire orotherappropriate governmental agencies. 12. Ifthe UAS loses communications or loses GPS signal, the UAS will have the capabilityto return to a pre-determined locationwithin a designated location and land autonomously. 13. The UAS will have the capability to abort aflight in case ofunpredicted obstacles, weather, or emergencies.

14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

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# ~ HALIDE SOLUTIONS •associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft} operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 551bs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations underthis exemptionwill be tightlycontrolled and monitored by both the operatorand underthe requirements and in compliance with local public safety requirements. The FAAwill have advance notice ofall operations. These safetyenhancements provide agreaterdegree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstratesthatthere is no credible threatto national security posed bythe UAS, dueto its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14C.F.R. § 45.23 (b). MarkingoftheAircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilotstation, in letters not less than 2 inches nor morethan 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on thefuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14C.F.R. § 61.113 (a}: Private Pilot Privileges and Limitations: Pilot in Command. Pursuantto 14CFR 61.113 (a), no person who holds a private pilotcertificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire. Our UAS do not carry any pilots or passengers nor propertytherefore I am seeking an exemptionto 14CFR 61.113(a). Although helpful, a pilot's license will notensure remote control piloting skills. The risks attendanttothe operation of UAS is far less than the risk levels inherent in the commercial activities


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# ~ HAI.IDE SOLUTIONS outlined in 14CFR 61. Ifeel the operation and limitations set forth in the FOM will equate to the safe operation ofthe UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

### The regulation requires that no person may operate acivil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

### Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft.The equivalent level of safety will be maintained by keeping the flight manual atthe ground control point where the pilotflying the UAS will have immediate access to it. 14 C.F.R. § 91.103: Preflight Action. 

### This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.109: Flight Instruction. 

### Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions forflighttraining without fully functional dual controls for a numberofaircraft and forflight instruction in experimental aircraft. The equivalent level ofsafety provided by the fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. 

### Section 91.119 establishes safe altitudes foroperation ofcivil 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 oraltitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

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# u. HALIDE SOtUT.IONS may be needed to allow such operations. As set forth herein, the UAS will neveroperate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100' above the highest point on the structure. 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 ofsafetywill be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owneror local officials. Because ofthe advance notice to the property ownerand participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these small- UAS operations and the operations ofconventional aircraft that must complywith 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 altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimetersetting available before departure." As the UAS may not have a barometric altimeter, but instead aGPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude ofthe 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 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 afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes." The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertimeframe for flight in daylight ortwilight VFR conditions is reasonable. Applicant believes that an e·xemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or25% of battery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 

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# ~ HALIDE SOLUTIONS

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

. 

### The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate acivil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section oraspecial flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no morethan 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilotflying the UAS will have immediate access to them, to the extentthey are applicable to the UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### & (b): Maintenance Inspections. 

### These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will notapply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediatelyand will be operating from no higherthan 400 feetAGL. The operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthycondition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight and perform required maintenance needed.



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# ~ HALIDE SOLUTIONS

PUBLIC INTEREST The Reasons Why Granting Halide Solutions, LLC's Request Would Be In The Public Interest; That

### Is, How ItWould BenefitThe PublicAs A Whole. Consistent with the requirements of 14 C.F.R. 11.81(d), Petitioner offers the following reasons why grantingthis petition for exemption is in the public interest, i.e., howgranting itwould benefitthe public as a whole. Granting the present Petition will furtherthe public interest by allowing Halide Solutions, LLC to safely, efficiently, and economically perform aerial video and photography within the NAS. Additionally, use of the UASs will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy

• The operation significantly improves safety and reduces risk by alleviating' human exposure to danger associated with current aerial video and photography, namely, full-size helicopters. Manned helicopters performing aerial video and photography can experience accidents and fatalities. The public's interest is furthered by reducing human exposure to death orserious injury associated with manned aircraft performing such aerial video or photography.

• Petitioner's small UASs are battery powered and create no emissions. If Petitioner's UAS crashes, there is no fuel toignite and/orexplode. Any impact of Petitioner's lightweight UASs is, obviously, far less than afull size helicopter.The public's interest is furthered by minimizing ecological impact ofan accident and by reducing human exposure to potentially harmful emissions associated with manned aircraft.

• Aerial video and photography are valuable tools foraerial inspections. However, problems with safety, cost, statistical integrity, and logistics continue to impede aerial surveys and inspections from conventional manned aircraft. The use ofsmall UAS addresses these problems and is a powerful tool for performing awide range of roofing inspection applications. The public as a whole will benefitfrom the safer and more cost effective aerial inspection services that small UAS operations provide.

• In addition to being safe and efficient, the UASs are also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation ofthe UASs will allow United States based companies, like Halide Solutions, LLC's, to remain competitive and contributeto growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternativetechnology in order to remain competitive. Operating the battery powered UASs is one such technologythat not only allows companies greateroperational flexibility compared to manned aircraft, but provides such flexibility withoutthe high operational cost ofatraditional manned aircraft. By operating
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# ~ HALIDE SOLUTIONS UASs, companies such as Halide Solutions, LLC's, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use ofthe UASs, provides astable workforce that increases consumer spending; improves local, state, and federal tax revenues; and, allows companies to invest in research and development in orderto remain competitive in the United States.

• The Public Will Benefit From Decreased Congestion OfThe NAS. The requested UASs are battery powered and serve as asafe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use of UASs would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraftwill be reduced.

• The requested UASs do not require an airportto takeoffor land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in feweraircraft that must be handled by airtraffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations.

• Conducting aerial acquisitions with the UASs, instead of manned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated duringtraditional aerial video and still photographyflight operations. By using battery power and electric motors, the UASs produce no air pollution, and are the mostviable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hourof leaded aviation fuel. The UASs, while reducing the carbon footprint ofaerial acquisitions, also eliminate noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraftflight operations, will be substantially reduced orcompletely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the UASs have less physical potential for collateral damage to life and propertyon the ground, and in the air, compared to the manned aircraftthattypically conduct similar operations (weighing approximately 6,000 pounds with awingspan ofapproximately42 feet, a length of34 feet, and afuel capacity of 180 gallons).

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# llHALIDE SOLUTIONS

CONCLUSION 

### & REQUEST FOR APPROVAL Because this petition is similar in material respects to previous petitionsthe FAA has granted, Halide Solutions LLC requests thatthe FAA issue a summary grant ofexemption pursuant to the agency's expedited summary grant process. Specifically, the public interest and safety benefits Halide Solution LLC operations will achieve are materiallysimilarto those recognized in Grants of Exemption Nos. 13519 to Bird Eye Photography LLC (see Docket No. FAA-2015-3546), 13532 to Ghostriders Aerial Photography LLC (see Docket No. FAA-2015-2787), 13513 to DT Aerial Photography (see Docket No. FAA-2015- 3504), and 13199to Creative Dog Media, LLC (see Docket No. FAA-2015-3113). Halide Solutions LLC will adhere to a series ofoperating parameters that will offerthe same level ofsafety as the conditions the FAA currently requires in its summary grants. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequate justification forthe grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UASs.



### Sincerely, 

# f**~**

# Ha~ionsLLC Attn: Sara Pandiyan 534 Appaloosa Ave Shakopee MN 55379 763.350.7751 Sara.Pandiyan@halidesmart.com

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