### 1 UNITED STATES OF AME RICA

DEPARTMENT OF TRANSP ORTATION

FEDERAL AVIATION ADM INISTRATION

WASHINGTON, DC

REGULATORY DOCKET NO

. ______________



### IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DRONESTHATWORK,LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

CONCERNING OPERATION OF UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request

Dear Sir or Madam,

DRONESTHATWORK, LLC respectfully submits that the proposed operations detailed within this petition

for exemption qualify for expedited approval under Section 333 of the Reform Act of 2012 . The

operations outlined herein, and in the Petitioner's manuals, clearly define UAS operations in the NAS

that are under appropriately controlled conditions and within secure and sterile zones of operation

. Further, the proposed operati ons pose no significant safety risk to persons or property on the ground,

no risk to National Security, and woul d not constitute as an invasion of any persons reasonable

expectation of privacy.

Submitted on January 26 , 2015

Leisa Adkins, President

DRONESTHATWORK, LLC

240 Trumpet Drive

West Carrollton, Ohio 45449

Tel: (937)474

- 2790

### 2 

### TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS............................................................................................................. .....................3

SUMMARY.................................................................................................... ..............................................................4

INTRODUCTION.................................................................................................................

.......... ...............................4

BACKGROUND..............

.................................................................................................................... ..........................4

BASIS FOR PETITION..............................................................................................

...................... ...............................5

A) CONTACT INFORMATION OF PETITIONER..

.................................................................................... .........5

B) THE SPECIFIC SECTIONS OF 14 C.F.R . FROM WHICH DRONESTHATWORK, LLC

SEEKS EXEMPTION. ...................................................................................................... ...............................5

C) THE EXTENT OF RELIEF DRONESTHAT WORK, LLC SEEKS AND THE REASON

DRONESTHATWORK INC. SEEKS THE RELIEF AND EQUIVALENT LEVEL OF SAFETY

.. ........... ..... ................. ...9

D) THE REASONS WHY GRANTING DRONESTHATWORK, LLC 'S REQUEST WOULD

BE IN THE PUBLIC INTEREST.......................................................................................

.... ..............................14

E) PRIVACY...................................................................................................................... ..............................15

F) SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

.............................. ........................ . .....15

G) ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT DRONESTHATWORK, LLC 'S REQUEST....................................................... ..............................15

C ONCLUSION....................................................................................................................

............. ........................... ..16

### 3 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FOMM Flight Operations & Maintenance Manual

FSDO Flight Standards District Office

JSA Job Safety Analysis

NAS National Airspace System

NERC National Am erican E lectric Reliability Corporatio n

NTSB National Transportation Safety Board

MOC Management of Change

PIC Pilot In Command

RF Radio Frequency

Section 333 FAA Modernization and Reform Act of 2012, Section 333

UAS Unmanned Aircraft System

VFR Visu al Flight Rules

VLOS Visual Line

- of

- Sight

VMC Visual Meteorological Conditions

VO Visual Observer

### 4 SUMMARY

DRONESTHATWORK, LLC seeks exemption from the requir ements of part 21, subpart H: part 27 and

Sections 45.23(b), 61.113(a) and (B), 91.7(a), 91.9(b)(2), 91.103(b), 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), and 91.417(a) and (b) of 14 C.F.R.

. This exemption would permit

DRONESTH ATWORK, LLC to op erate the LB700 Unmanned Aircraft System (" U AS ") for the special purpose of aerial

inspection of elevated structures for the electric utility industry (or similar clients/ uses) while always operating

under the core premise that ALL aviation related acciden ts are preventable.

INTRODUCTION

DRONESTHATWORK, LLC 's UAS Program is directed by one of the World's most skilled , safe and

experienc ed small UAS pilots. Wendell J. Adkins has served as a Leader Member and Contest Director for the

Academy of Model Aerona utics and, in addition, has represented the United States in the FAI

- F3C Helicopter

World Aer omodeling Championships, helping win a World Title for Team USA in 1993 in Velden Austria . Wendell

has flown in 22 U.S. FAI

- F3C Helicopter National Championships and has made approximately 15 ,000 unmanned

sport aviation flights over the last 35 years, all without ever inflicting injury to any person or damaging the

property of another. Wendell has also worked as a small UAS consultant to both Veridian Engineering /G eneral

Dynamics assisting with UAS sensor R&D projects and Northrop Grumman in support of No r throp's Beyond Line

of

- Sight Tactical UAV Communications Relay Project.

BACKGROUND

Unmanned Aircraft System: LB700 Rotorcraft

DRONESTHATWORK, LLC seeks an exemption to operate the LB700 UAS, Serial #001, # 002, etc., for

compensation or hire within the n ational airspace ("NAS"). The LB700 UAS is comprised of a custom built

, single

rotor

, lithium

- polymer battery

- powered unmanned aircraft system and portable gr ound control station. The LB700

UAS has a maximum gross weight of approximately twenty (20 ) pounds, while having a main rotor diameter of

sixty

- three (63) inches. The LB700 UAS derives it s f lig ht power from a single lithium

- polymer battery

- powered

brushles s electric motor and has a max imum airspeed of 5 0 knots.

NOTE: This request for exemption is in accordance with the proprietary procedures detailed in the

Peti tioner's FOMM document enclosed. The FOMM is submitted as confidential under 14 C.F.R. § 11.35(b), as

the entire Manual contains confidential commercial information that the Petitioner has not and will n ot share

with others. The FOMM contains operating conditions and procedures that are not availabl e to the public and

are protected from release under the Freedom of Information Act 5 U.S.C. § 552 et.seq.

BASIS FOR PETITION

Petitioner, DRONESTHATWORK, LLC , pursuant to the provisions of the Federal Aviation Regulations (14

C.F.R. § 11.61) and the FAA M odernization and Reform Act of 2012, Section 333, Special Rules for Certain

Unmanned Aircraft Systems, hereby formally petitions the Administrator for an exemption from the requirements

of part 21, subpart H: part 27 and Sections 45.23(b), 61.113(a) and (B ), 91.7(a), 91.9(b)(2), 91.103(b), 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), and 91.417(a) and (b) of 14

C.F.R..

The proposed operations detailed within this petition for exemption qualify for expedited a pproval under

Section 333 of the Reform Act. The operations outlined herein, and in the Petitioner's manuals

, clearly define UAS

### 5

operations in the NAS that are under appropriately controlled conditions and within secure and sterile zones of

operation and pose no significant safety risk to pe rsons or property on the ground , no risk to National Security, and

would not constitute as an invasion of any persons reasonable expectation of privacy.

In accordance with 14 C.F. R. § 11.81, DRONESTHATWORK, LLC pr ovides the following information in

support of its petition for exemption:

A. Name and Address of The Petitioner.

The name and address of the Petitioner is:

DRONESTHATWORK, LLC

Leisa Adkins, President

240 Trumpet Drive

West Carrollton, Ohio 454 49

Tel: (937) 474

- 2790

Email: boomstrike@aol.com

B. The Specific Sections of 14 C.F.R. Parts 21

, 27, 45 and 91 From Which DRONESTHATWORK, LLC Seeks

Exemption.

1

. DRONESTHATWORK, LLC Seeks Exemption From The Requirement of Section 14 C.F.R. §

45.23(b) entitled Display of marks; general, states the following:

Section § 45.23 subsection (b), When marks include only the Roman capital letter "N" and the

regis tration number is displayed on limited, restricted or light

- sport category aircraft or ex perimental or

provisiona lly certificated aircraft, the operator must also display on that aircraft near each entrance to the

cabin, cockpit, or pilot station, in letters no less than 2 inches nor more than 6 inched high, the words

"limited," "restricted ," "light

- sport ," "experimental," or "provisional," as applicable.

2

. DRONESTHATWORK, LLC Seeks E xemption From 14 C.F.R. § 61.113(a) &

(b): Private Pilot Privileges and Limitations: Pilot in Command

, states the following:

(a) no person who holds a private pilot certificate may act as pilot in command of any aircraft that is

carrying passengers of property for compensation or hire; nor may that person, for compensation or

hire, act as pilot in command of an aircraft.

(b) a p rivate pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with

any business or employment if:

(1) The flight is only incidental to that business or employment: and

(2) The aircraft does not carry passengers or pr operty for compensation or hire.

3

. DRONESTHATWORK, LLC Seeks E xemption From 14 C.F.R. § 91.7(a): Civil

Aircraft Airworthiness which states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

### 6 (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical,

electrical, or structural conditions occur.

4

. DRONESTHATWORK, LLC Seeks Exemption F rom 14 C.F.R. § Section 91.9 entitled Civil

aircraft flight manual, marking, and placard requirements, subsection (b) states the following:

(b) No person may operate a U.S.

- registered civil aircraft

--

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.15 of this chapter unless

there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the

manual provided for in § 121l141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight

Manual, approved manual material, markings, and placards, or any combi nation thereof.

5

. DRONESTHATWORK, LLC Seeks Exemption F rom 14 C.F.R. P art 21. Section 91.103 entitled

Preflight Action , subsection (b)(1) states the following:

in pertinent part, that each pilot in command sha ll, before beginning a flight, become fa miliar with all

available information concerning the flight, to in clude, "For any flight, runway lengths at airports of

intended use, and the following takeoff and landing dis tance information:...For civil aircraft for which

an approved Airplane or Roto rcraft Flight Manual containing takeoff and landing distance data is

required, the takeoff and landing distance data contained therein."

6

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.109 entitled

Flight Instruc tion; Simulated Instrument Flight and Certain Flight Tests , subsection (a) states

the following:

No person may operate a civil aircraft (except a manned f ree balloon) that is being used for flight

instruction unless that aircraft has fully functional dual c ontrols. However, instrument flight instruction

may be given in an airplane that is equipped with a single , functioning throwover control wheel that

controls the elevator and ailerons, in place of fixed, dual controls, when

-

...

7

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.1 1 9 entitled

Minimum Safe Altitudes: General

, states the following:

in pertinent part, that e xcept when necessary for tak eoff or landing, no person may operate an aircraft

below the following altitud es:

(c) Over other than congested areas. An altitude of 500 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.

8

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.1 21 entitled

Altimeter Settings, subsection (a) states the following:

in pertinent part, that e ach person operating an aircraft shall maintain the cruising altitude or flight lev el

of that aircraft, as the case may be, by referenc e to an altimeter that is set, when operating

-

...

### 7 9

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91.1 51(a) entitled

Fuel Requirement s For Flights in VFR Conditions, subsectio n (a) states the following:

(a) in pertinent p art, that n o person may begin 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.

1 0

. DRONESTHATWORK, LLC Seeks E xemption From Section 91.203(a) and 91.203 ( b) entitled

Civil Aircraft: Certifications Required , subse ctions (a) and (b) state the following:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airwor thiness certificate. Each U.S. airworthiness certificate used

to comply with this subparagraph (except a special flight permit, a copy of the applicable

operations specifications issued under § 21.197(c) of this chapter, appropriate sections of

th e air carrier manual required by parts 121 and 135 of this chapter containing that portion

of the operations specifications issued under § 21.197(c), or an authorization under

§ 91.611 must have on it the registration number assigned to the aircraft under part

47 of this chapter. However, the airworthiness certificate need not have on it an assigned

special identification number before 10 days after the number is fir st affixed to the

aircraft. A revised airworthiness certificate having on it an assigned special identification

number, that has been affixed to an aircraft, may only be o btained upon application

to an FAA Flight Standards District Office ("FSDO").

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United

States, the second copy of the Aircraft registration Application as provided for in § 47.31(c), or a

registration certification issued under the laws of a foreign c ountry.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of

this section or a special flight authorization issued under §91.715 is displayed in the cabin or cockpit

entrance so it is legible to pa ssengers and crew.

11

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91. 405(a)

entitled Maintenance, Preventive Maintenance, Alterations , subsection (a) states the

following:

in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in

subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of

the same section, have discrepancies repai red as prescribed in Part 43 of the chapter.

12

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91. 407(a)(1) entitled

Operation after Maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)

(1) states the f ollowing:

### 8 in pertinent part, any person from operating an aircraft that has u ndergone maintenance unless it has

been approved for return to service by a person authorized under § 43.7 of the same chapter.

13

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91. 409(a)(2) entitled

Inspections , subsection (a)(2) states the following:

in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar

months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part

21 of this chapter.

14

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 21. Section 91. 417(a) and (b)

entitled Maintenance Records , subse ctions (a) and (b) state the following:

(a) Each registered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour,

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must

include

- (i) A description ( or reference data acceptable to the Administrator) of the work performed: and

(ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the

person approving the aircraft for return to service.

(2) Records cont aining the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection pr ogram under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including,

for each, the method of compliance, the AD or safety directive number and revisions d ate. If the

AD or safety directive involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of the chapter for each major alteration to the

airframe and currently installed e ngines, rotors, propellers, and appliances. (b) The owner or

operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or super seded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with

the aircraft at the time the aircraft is sold.

### 9 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter

shall be retained until the defects are repaired and the aircraft is approved for return to service.

15

. DRONESTHATWORK, LLC Seeks Exemption From 14 C.F.R. Part 27 entitled

Airworthiness Standards for Normal Category Rotorcraft , states the following:

(a) This part prescribes airworthiness standards for the issue of type certificates, and changes to those

certificates, for normal category rotorcraft with maximum weights of 7,000 pounds or less and nine or

less passenger seats.

C. The Extent Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks The Relief.

1. Exten t Of Relief DRONE STHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From 14 C.F.R. § 45.23(b).

Relief is requested because the LB700 UAV has no entrance to the cabin, cockpit, or pilot station on

which the word "Experimental" can be placed. Further, two inch lettering would adversely affect the flight

performance and safe operation of the UAV.

Equivalent Level of Safety

An equivalent level of safety will be assured by having the LB700 UAS marked "Experimental" alon g each

side of the camera gimbal upper tube support structure in let tering as large as practicable which will

prominently inform all parties of the unm anned aircraft's overall operating status.

2. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Rel ief From Section 14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations:

Pilot in Command.

Relief is requested because it is recognized that a certificated commercial pilot is required to meet

statutory requirements to operate any aircr aft in the NAS for commercial purposes or a private pilot

certificate if "the flight is only incidental to the business or employment." Since the UAS is essential to

performing the function of inspection of elevated structures, th is exception does not a pply. Accordingly,

this petition seeks exemptions from the limitations of both § 61.113(a) & (b) in order that the LB700 UAS

may be utilized for compensation and for hire when operated by a certificated private pilot.

Equivalent Level of Safety

An equi valent level of safety will be assured by having the UAS operator hold a current private pilot's

certificate when acting as PIC. Because the UAS carries no pilot or passengers, the proposed operations

can achieve the equivalent level of safety intended by § 61.113(a) & (b) when operating as specified in the

petitioner's FOMM. The FOMM sets forth procedures to secure the area of flight operations such that no

nonessential personnel may enter the exclusion zone whi le flights are being conducted.

3. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.7(a).

Relief is requested because the LB700 UAS will not be issued a valid airworthiness certificate under this

exemption request.

### 10 Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in accordance

with the procedures detailed in the petitioner' s FOMM. The DRONESTHATWORK, LLC lead pilot has 35

y ears of experience building and maintaining fundamentally simila r unmanned aircraft as well as 4 years

of maintenance records specifically for the LB700 UAS.

4

. Extent Of Relief DRONESTHATWORK, LLC S eeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.9(b).

Relief is requeste d because the LB 700 UAS w eighs approximately twenty (20 ) pounds at is maximum

gross weight and cannot carry the approved Rotorcraft Flight Manual onboard. Furthermore, since the

LB700 UAS is unmanne d, the flight crew member s are located at the ground control station

.

Equivalent Level of Safety

An equivalent level of safety will be assured by making the petitioner's a pproved FOMM available at the

ground control station, where it is immediately avail able for reference by the flight crew any time the

LB700 UAS is being operated

.

The a pproved FOMM will be made available within 7 days to any FAA, U.S. Department of Defense,

Department of Homeland Security, or law enforcement official upon request.

5. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.103 entitled Preflight Action.

Relief is requested because the information that the PIC is required to review prior to flight operations,

such as runway lengths and takeoff and landing distance data, do not apply to the operation of the LB700

UAS unmanned rotorcraft . Further, the FOMM will not be kept on board the aircraft as noted in the

petitioners request for relief from Section § 91.9( b) above.

Equivalent Level of Safety

An equivalent level of safety will be assured through strict adherence to the extensive preflight checklist

detailed in the petitioner's FOMM. The PIC is responsible for performing all inspections and taking all

act ions required to assure that both the UAS and the operating environment are suitable for safe

operations prior to launch

.

6. Extent Of Relief DRO NESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.109 entitled Flight Instruction

.

Relief is requested because the LB700 is a remotely piloted unmanned rotorcraft and, as such, is

not equipped with fully functional dual controls on board and carries no pilot or passengers . The

UAS is instead operated by the P IC via a single RF command and control transmitter.

Equivalent Level of Safety

An equivalent level of safety will be assured through providing flight instruction using ground based

master/slave RF command and control transmitters and performing trainin g flights in a secure and sterile

environment at least 500 feet away from any nonessential , non

- participating personnel.

### 11 7

. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.1 1 9 entitled Minimum Safe Altitudes:

Relief is requested because the primary purpose and advantage of the LB700 UAS is to perform

close proximity inspections of elevated structures that cannot otherwise be safely accomplished

using manned aircraft without risk ing damage to either the structure and/ or the manned aircraft.

The UAS will typically be positioned at a horizontal distance of approximately 25 feet from the

structure being inspected

, and so

, will be typically ope rating closer than 500 feet from the

structure being inspected and , as such, will require an exemption to this requirement.

Equivalent Level of Safety

An equivalent level o f safety will be assured due to the absence of flammable fuel, along with the

inherent small size, weight and lim ited potential kinetic energy of the LB70 0 UAS. Utilization of a UAS

for the purpose of close proximity structural inspections poses minimal risk of damage to the

structures being inspected and other equipment on the ground surrounding the area of op erations . In

addition, strict adherence to the secure and sterile exclusion zone of operations , along with the collision

avoidance procedures detailed in the petitioner's FOMM

, assure that risk to persons and property on the

ground are minimized.

As detailed in the petitioner's FOMM, flight operations will only be conducted on properties with

written approval of the owner and/ or authorized governing body. Considering the LB700 UAS will

only be operated below 400 feet AGL, and within 25 feet fr om the structures being inspected, risks to

manned aircraft is minimized . While a UAS is always required to yield to manned aircraft, conversely

manned aircraft are advised to avoid the facilities to be inspected by the UAS under contract

. Specifically,

the FAA strongly advises that

- "in the interest of national security and to the ex tent practicable, pilots

are strongly advised to avoid the airspace above, or in proximity to , such sites as power plants (nuclear,

hydro

- electric, or coal), dams, refineries, industrial comple xes, military facilities and other similar

facilities."

DRONESTHATWORK, LLC 's lead pilot , being a retired E lectric U tility M anager

, is intimately

knowledgeable of NERC best practices and clearly understands how to operate th e LB700 UAS in a

manner that will not unduly risk the reliable operation of any bulk electric generating facility.

I t must be emphasized that large industrial complexes, and in particular, large bulk electric generating

stations are inherently secure e nvironments due to NERC requirements regarding national security.

Considering this, the ability to control a secure flight operations perimeter is greatly enhanced when

compared to any other public environment.

8. Exten t Of Relief DRONESTHATWORK, LLC S eeks And The Reas on DRONESTHATWORK, LLC

Seeks Relief From Section § 91.1 21(a) entitled Altimeter Settings:

Relief is requested because the LB700 UAS is not equipped with a barometric altimeter than can

be corrected to the elevation of the departure airport or barometric pressure. Rather, the LB700

UAS will utilize either the GPS altitude indicator and/ or the physical height of the structure being

inspected as a reference not

- to

- exceed elevation.

### 12 E quivalent Level of Safety

An equivalent level of safety will be assured by following the process detailed in the petitioner's

FOMM for altitude monitoring. The most accurate and reliable method is to verify the as

- built

elevation of the structure fr om final

, approved construction drawings. Upon re aching the vertical limit of

the structure of known height, the camera operator will alert the PIC to stop climbing and descend upon

obtaining visual confirmation from the live video downlink that the top of the structure has been reached.

9. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.151(a) entitled Fuel Requirements for Flight in VFR Conditions:

Relief is requested because the LB700 UAS is battery powered with a flight duration of

approximately 10 minutes and, as such, requires an exemption to the 30 minute reserve fuel

requirement.

Equivalent Level of Safety

An equivalent level of safety will be assured by limiting all flights to 10 minutes or 25% remaining battery

capacity, whiche ver occurs first. In addition, t he petitioner's FOMM sets forth procedures to secure the

area of flight operations such that no nonessential personnel may ent er the exclusion zone while flights

are being conducted.

10

. Extent Of Rel ief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91.203(a) and (b) entitled Civil Aircraft:

Relief is requested because the LB700 UAS is unmanned and, as such, has no cabin, cockpit, pilot station,

or entrances thereto. Therefore, the flight crew member is located at the ground control station and no

passengers are carried at any time. The petitioner has previously requested relief from the requirements

of 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness in this submittal.

Equivalent Level of Safety

An equivalent level of safety will be assured by locating the required documentation at the ground control

station , where it is immediately available to the fligh t crew member PIC of the LB700 UAS any time the

unmanned aircraft is operating.

The documents specified must be made available within 7 days to any FAA, U.S. Department of Defense,

Department of Homeland S ecurity, or law enforcement official upon request.

11

. Extent Of Relief DRONES THATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91. 405(a) entitled Maintenance, Preventive Maintenance,

Alterations.

Relief is reques ted because the LB700 UAS will not be issued an FAA airworthiness type

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in

accordance with the procedures detailed in the petitioner' s FOMM. The DRONESTHATWORK, LLC

### 13 lead pilot has 35 years of experience building and maintaining fundamentally similar

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

12. Exten t Of Relief DRO NESTHATWORK, LLC Seeks And The Reason DRONESTHAT WORK, LLC

Seeks Relief From Section § 91. 407(a)(1) entitled Operation after Maintenance, preventive

maintenance, rebuilding, or alteration.

Relief is requested because the LB700 UAS will not be issue d an FAA airworthiness type

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in

accordance with the procedures detailed in the petitioner' s FOMM. The DRONESTHATWORK, LL C

lead pilot has 35 years of experience building and maintaining fundamentally similar

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

13. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHA TWORK, LLC

Seeks Relief From Section § 91. 409(a)(2) entitled Inspections.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in

accordance with the procedures detailed in the petitioner' s FOMM. The DRONESTHATWORK, LLC

lead pilot has 35 years of experience building and maintaining fundame ntally similar

unmanned aircraft as well as 4 years of maintenance records specifically for the LB700 UAS.

14. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From Section § 91. 417(a) and (b) entitled Ma intenance Records.

Relief is requested because the LB700 UAS will not be issued an FAA airworthiness type

certificate.

Equivalent Level of Safety

An equivalent level of safety will be assured by performing inspections and maintenance in

accordance with the procedures detailed in the petitioner' s FOMM. The DRONESTHATWORK, LLC

lead pilot has 35 years of experience building and maintaining fundamentally similar

unmanned aircraft as well as 4 years of maintenance records specifically f or the LB700 UAS.

1 5

. Exten t Of Relief DRONESTHATWORK, LLC Seeks And The Reason DRONESTHATWORK, LLC

Seeks Relief From 14 C.F.R. § 21.185.

R elief is requested from the airworthiness certificate requirements of the Federal Aviation

Regulations . The p etitioner proposes to commercially operate the LB700 UAS without an

airworthiness certificate, for the special purpose of conducting inspections of elevated

structures for the electric utility industry (or similar clients and uses) . Flight opera tion s will

### 14 only be conducted on clients private property with approval , pursuant to specific operating

limitations and a Flight Operations & Maintenance Manual ("FOM M"). DRONESTHATWORK, LLC

seeks relief from the airworthiness certificate requirements of 14 C.F.R. § 21.18 5 to the extent

that the LB700 UAS

, which has not be en type certificated by the FAA, may be operated as if it

were a restricted category aircraft for a single, defined, special purpose operation, specifica lly,

(aerial inspection of elevated structures).

Equivalent Level of Safety

An equivalent level of safety will be assured because operation of the LB700 UAS will not create

a hazard to users of the NAS , or the public, or otherwise pose a threat to national security.

Further, Section 333 provided the authority for such UAS to operate without airworthiness

certification. Specifically, Section 333 states the following, in part:

(b) Assessment of Unmanned Aircraft Systems.

-- In making the dete rmination under subsection

(a), the Secretary, shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed,

operational capability, proximity to airports and populated areas, and op eration within visual line

of sight do not create a hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2)whether a certificate of waiver, certificate of authorization, or airworthiness certifica tion

under section 44704, United States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

T he proven safe operationa l history of DRONESTHATWORK, LLC 's. Lead Pilot over the past 35 years flying

fundame ntally similar unmanned rotorcraft , as well as the specific parameters of the

DRONESTHATWORK, LLC's intended operation pursuant to this exemption, demonstrate that the LB700

UAS can be operate d in the NAS without creating a hazard to other aircraft or p ersons or property on the

ground. All operations shall be performed in strict adherence to the provisions set forth in the

DRONESTHATWORK, LLC 's. Flight Operations & Maintenance Manual ("FOM M")

. Accordingly, the FAA

may approve the LB700 UAS , without an airworthiness certificate, by setting forth specific operating

limitatio ns to ensure a level of safety equivalent to what would be provided otherwise by airworthiness

certification.

D. The Reasons W hy Granting DRONESTHATWORK, LLC 's Reque st Would Be In The Public

Interest :

Granting the present Petition for Exemption will further the public interest by providing a much more

thorough and comprehensive conditional assessment of aging electric utility infrastructure (or similar

clients/ u ses). Utilities and other similar industries rely on accurate inspection data in order to make

intelligent and timely run/repair/retire decisions of critical structures. The U.S. still relies heavily on fossil

fuel powered electric generation to supply t he country's energy needs. These plants were designed for a

useful service life of 25 years on average . The vast majority have now significantly exceeded this milepost

through the use of life extension programs and EPA mandated environmental upgrades.

### 15 It is important that the large critical structures these plants rely on receive regular condition assessments

in order to prevent catastrophic failures and potential lost generation. This is vital in order for utilities to

continue to safely provide reliable energy to the nation's power grid and, consequently, enhance national

security. Additionally, use of the LB700 UAS replaces the need to put the lives of ironworkers at high risk

using rope access to provide an inspect ion that is far less thorough, yet more costly and hazardous to

human life to perform. The LB700 can typically inspect 100% of the exterior of a large structure in one

fo u rth the time required for a human to physically inspect 10% of the same area.

E. PRIVACY

Flight operations will only be performed on private property with written consent of the owner or

governing body. Since the sole purpose of each flight is to inspect a stru cture

- gathering images of any

other object, for any other purpose, is b oth unwarranted and unwanted.

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

DRONESTHATWORK, LLC seeks exemption from the requirements of part 21, subpart H: part 27 and

Sections 45.23(b), 61.113(a) and (B), 91.7(a), 91.9(b)(2), 91.103(b), 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), and 91.417(a) and (b) of 14 C.F.R.. This exemption

w ould permit DRONESTHATWORK, LLC to operate the LB700 Unmanned Aircraft System ("UAS") for the

special purpose o f performing aerial inspection s of elevated structures for the electric utility industry (or

similar clients/uses) while always operating under the core premise that ALL aviation related accidents are

preventable.

Utilities and other similar industries rely on accurate conditional assessments in order to make intelligent

and timely run

- repair

- retire decisions of critical structures. This is vital and critical in order for utilities to

continue to safely provide re liable energy to the nation's power grid and, consequently, enhance national

security. U se of the LB700 UAS replaces the need to put the lives of ironworkers at risk by using rope

access to provide an inspection that is far less thorough, yet more costly and hazardous to human

life to perform. The LB700 can typically inspect 100% of the exterior of a large structure in one fo u rth

the time required for a human to physically inspect 10% of the same area. Additionally, the close

proximity inspections prop osed in this request cannot be safely performed using full size aircraft.

DRONESTHATWORK, LLC is uniquely qualified to perform this work as its lead pilot has 35 years

experience as a professional in both designing, building, maintaining and piloting u nmanned aircraft

, combined with 35 years experience inspecting and/or managing large

- scale critical infrastructure

inspections for one of the world's largest global electric utilities.

G

. ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT DRONESTHATWORK,

LLC 'S REQUEST.

1. DRONESTHATWORK, LLC 's Lead Pilot H as Been Safely Operating UAS's for 35 Years.

### 16 The skills required to become an FAI Worl d Championship caliber unmanned a ircraft pilot are

considerable. They include s pending thousands of hours designing, building, maintaining and

remotely piloting aircraf t at the highest possible level over many years . All of these skills are

identical to those requ ired to safely o perate a UAS in an ind ustrial environment. The LB700 UAS

is fundamentally similar in design and performance to the remotely pilot ed a ircraft flown by

DRONESTHATWORK, LLC 's Lead Pilot in aeromodeling competition for 22 years between 1980 to

2002

.

2. T he Specifications Of The LB700 UAS Demonstrate Its Safe Characteristics.

The LB700 UAS does not create a hazard to users of the NAS or the public considering its size,

weight, speed, and intended operation. Further, these same operational charact eristics assures

that its operation poses no threat to national security. The specifications of the LB700 are

detailed within the FOMM submitted as part of this petition.

Petitioner submits the FOMM manual as a confidential document under 14 C .F.R. 11.35(b) as

the entire manual contains proprietary information that the petitioner has not and will not

share with others. The manual contains non

- public informa tion and is protected from release

under the Freedom of Information Act 5 USA 55 2 et.seq.

3. The secure and sterile flight operations zone maintained clear of all non

- essential personnel

.

Electric Generating Stations

, for example

, are typically very space

- limited. Establishing large 500

foot exclusion zones is not always practicable as it would shut down critical plant operations. A

200 foot exclusion zone exceeds that used by 250 foot tall construction cranes making OSHA

defined " critical lifts " of hundreds of tons. This distance is more than d ouble th e minimum

distance spectators must be spaced away from a n aerobatic flightline at a n RC aerobatic event as

sanctioned by the Academy of Model Aeronautics . This distance has been used for decades at

thousands of AMA sanctioned events and has been proven r easonable for remotely piloted

aircraft of larger size performing aerobatic maneuvers

. The petitioner's FOMM details

administrative procedures for assuring the safety of persons and property on the ground while

employing a continuously monitored 200 foot exclusion zone for nonessential personnel.

CONCLUSION

DRONESTHATWORK, LLC lead pilot has literally accumulated a lifetime of practical experience in all

aspects of small unmanned aerial vehicles. While procedures and processes are critical components to

safely operating a UAS in an industrial environment, e xperience and good judgment play equally

important roles. In a rapidly growing industry, where the trends all point towards reliance upon "plu g and

play" technology

, rather than demonstrated p iloting skills and technical experience, DRONESTHATWORK,

LLC believes that the airman's knowledge it has accumulated co uld prove beneficial to the FAA 's efforts

going forward.

DRONESTHAT WORK, LLC has a pplied the principles of Stop Work Authority, Management of Change,

Continuous Improvement and Near

- Miss Tracking to great advantage with tangible results on safe UAS

operations. DRONESTHATWORK, LLC would welcome the opportunity to share these processes,

procedures, operating data, or any o ther information

, that is non

- proprietary in nature

, in an effort to

advance the goal of safe integration of small commercial unmanned aerial systems into the NAS.