1

DroneBee, Corp. Petition for Exemption , UAS Operation US DEPARTMENT OF TRANSPORTATION

1200 New Jersey Avenue

SE Room W

- 12

- 140 West Building Ground Floor Washington, DC 20590

- 0001 William Boyd

562 Cordova Ct. Lafayette, CO 80026

Phone: (808) 384.1670

Dear Administrator:

Enclo sed please find the petition from DroneBee Corporation to the Federal Aviation

Ad ministration seeking an exemption from the requ irements of Title 14 of the Code of Federal Regulations (CFR) concer ning the operation of Unmanned Aircraft System (UAS) for

commercial use and operation within the United States.

DroneBe e is a Veteran owned business in the State of Colorado with the aim of creating a

network of highly reliable licensed pilots, operators and contributors of U AS technologies who will operate UAS within all published rules, la ws and regulation s as well as adhere to a code of

ethics and standard operating procedures.

The proposed exemption, if granted, will permit DroneBee ’s commercial use of the UAS for the purpose of aerial inspections and/or promotion of land, buildings, and other man

- made infrastructure, as well as the continued research and development in leveraging UAS technologies to advance humanitarian, socia l, environmental and commercial applications.

Sincerely,

William Boyd CEO, Co

- Founder DroneBee, Corp.
10/22/20152

DroneBee, Corp. Petition for Exemption , UAS Operation TABLE OF CONTENTS

SUMMARY FOR SEEKING EXEMPTION 4

COMPANY BACKGROUND 4

NAME AND ADDRESS OF DRONEBEE CORP

. 4

BASIS FOR PETITION F OR EXEMPTION 4

SECTIONS OF 14 CFR FROM WHICH DRONEBEE SEEKS EXEMPTION 5

HOW DRONEBEE ’ S REQUEST WILL BENEF IT THE PUBLIC AS A W HOLE 8

EXTENT OF RELIEF S OUGHT AND HOW SAFETY WILL BE MAINT AINED 9

CONCLUS ION 143

DroneBee, Corp. Petition for Exemption , UAS Operation SUMMARY FOR SEEKING EXEMPTION

Company Background DroneBee, Corporation (DroneBee) was founded by two Graduate students at the University of

Color ado, Leeds School of Business in 2015 . One founder holds a M.S. in Enginee ring Management, is a U.S. Army Veteran ( honorably discharged Officer at the rank of Major, O

- 4) and has four years of Aerospace Program Management experience. The other holds a Ph

. D. in Applied Physics wit h over a decade of experience as a te chnical contributor and program manager in Aerospace.

DroneBee ’s ai m is to source highly qualified, capable pilots (operators) and broker commercial agreements with industry consumers of aerial data and imagery. DroneBee will operate UAS

consistent with all applicable published rules, laws and regulations as well as adhere to a code of ethics and standard operating procedures in the interest of good business and safe operations. DroneBee is currently ‘pre

- revenue ’ as it continues to perform independent market research and analysis pending approval of the petition for exemption herein.

Name and Address of Petitioner :

DroneBee Corporation

1949 Pearl St STE C Boulder, CO 80302

BASIS FOR PETITION FOR EXEMPTION

Sections of Title 14 CFR from which DroneBee Seeks Exemptio n DroneBee, Corp. seeks exemption to the Title 14 , Aeronautics and Space, Code of Federal Regulations §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow DroneBee’s licensed pilots and operators to operate a small UAS (55lbs or less) to perform aerial imagery, video and data collection.

Extent of Relief Sought: DroneBee believes the exemptions sought are consistent with relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 11325

.

DroneBee is familiar with , has operation manuals on hand and requests exemption with respect

to th e following small UAS platforms when weighing less than 55 pounds including payload:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D Robotics Aero4

DroneBee, Corp. Petition for Exemption , UAS Operation h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma A E j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200

Sections of 14 CFR From Which Dronebee Seeks Exemption The following excerpt of requested code exemptions is provided :

61.23(a) and (c) §61.23 Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person

—

(1) M ust hold a first

- class medical certificate:

(i) When exercising the pilot

- in

- command privileges of an airline transport pilot certificate;

(ii) When exercising the second

- in

- command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or

(iii) When serving as a required pilot flightcrew member in an operation conducted under part 121 of this chapter if the pilot has reached his or her 60th birthday.

(c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person must hold and possess either a medical certificate issued under part 67 of this chapter or a U.S. driver's

license when

—

(i) Exercising the privileges of a stud ent pilot certificate while seeking sport pilot privileges in a light

- sport aircraft other than a glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light

- sport aircraft other than a glider or balloon;

(iii) Exercising th e privileges of a flight instructor certificate with a sport pilot rating while acting as pilot in command or serving as a required flight crewmember of a light

- sport aircraft other than a glider or balloon; or

(iv) Serving as an Examiner and administerin g a practical test for the issuance of a sport pilot certificate in a light

- sport aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this paragraph must

—5

DroneBee, Corp. Petition for Exemption , UAS Operation (i) Comply with each restriction and li mitation imposed by that person's U.S. driver's license and any judicial or administrative order applying to the operation of a motor vehicle;

(ii) Have been found eligible for the issuance of at least a third

- class airman medical certificate at

the time of his or her most recent application (if the person has applied for a medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person has held a medical certificate) suspended or revoked or most recent Authoriz ation for a Special Issuance of a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make that person unable to operate a light

- sport aircraft in a safe manner.

61.101(e)(4) and (5) §61.101 Recreational pilot privileges and limitations. (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— (4) For compensation or hire; (5) In furtherance of a business;

61.113(a) §61.113 Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying

passen gers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

61.315(a) §61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section.

91.7(a) §91.7 Civil aircraft airworthiness.

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

91.119(c) §91.119 Minimum safe altitudes: General. (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.

91.121 §91.121 Altimeter settings.6

DroneBee, Corp. Petition for Exemption , UAS Operation (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case ma y be, by reference to an altimeter that is set, when operating

—

(1) Below 18,000 feet MSL, to

—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the f ollowing table:

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the cur rent reported altimeter setting:

91.151(a)(1) §91.151 Fuel requirements for flight in VFR conditions.7

DroneBee, Corp. Petition for Exemption , UAS Operation (a) No 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.

91.405(a) §91.405 Maintenance required.

Each owner or operator of an aircraft

—

(a) Shall have that aircraft inspected as prescribe d in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

91.407(a)(1) §91.407 Operation after maintenance, preventive maintenance, re building, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter.

91.409(a)(1) and (2) §91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calen dar months, it has had

—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certifica te in accordance with part 21 of this chapter.

91.417(a) and (b) §91.417 Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods sp ecified 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 th e airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include

—8

DroneBee, Corp. Petition for Exemption , UAS Operation (i) A description (or reference to 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 containing 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 program 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 revision date. 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 this chapter for each major alteration to the airframe and currently installed engines, 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 superseded 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.

(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 ser vice.

H ow DroneBee ’s Request Wil l Benefit the Public As a Whole

DroneBee ’s request is in the public interest because Dro neBee ’s ultimate goal is to provide

ethical and safe data collection services to its customers , research centers and to the public

. DroneBee understands the rapidly evolving commercial and research application potential of small UAS. Emerging technolo gies however, create uncertainty, confusion and can lead to9

DroneBee, Corp. Petition for Exemption , UAS Operation mishaps in the worst case as safety standards and regulations lag behind innovation and technology. DroneBee will aid th e public in closing this information gap in its role as a n information resource and connection hub for UAS services. DroneBee will maintain on pace with updating regulations and will strive to anticipate improvements to safety as it affects further

restrictions and constraints.

As a Veteran owned company, DroneBee will seek to enable transitioning military Veterans, their spouses and our Nation ’s treasured disabled Veterans in the vast and rapidly changing UAS industry. DroneBee considers this to be its most significant contribution and benefit to the public.

Safety and Summary of Exemption Sought DroneBee is a safety conscious and focused organization. Our p ilots will maintain standard operating procedure s on hand in addition to all applicable flight checklists . In addition, the following considerations, notably published b y the Administrator ’s office will be strictly complied with:

1. DroneBee is familiar with , has operation manuals on hand and requests exemption with

respect to th e following small UAS platforms when weighing less than 55 pounds including payload:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D Robotics Aero

h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma A E j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200

2. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemp tion holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft

manufacture r.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.10

DroneBee, Corp. Petition for Exemption , UAS Operation 4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

5. All operations must utilize a visual observer (VO). The UA must be operated within the

visual l ine of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

6. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be

accessible duri ng UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take prec edence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present upd ated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator

determines tha t any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding u pdates or revisions to the operating documents.

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations . Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an

un due hazard to persons and property.

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

9. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS

is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is proh ibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.11

DroneBee, Corp. Petition for Exemption , UAS Operation 10. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requireme nts for the aircraft and aircraft components.

11. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

12. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a stat e, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must 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.

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining

appr opriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficie ncy, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only b e conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from no nparticipants in accordance with 14 CFR § 91.119.

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SV FR) are not authorized.

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denot ed on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made ava ilable to the Administrator or any law enforcement official upon request.

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.12

DroneBee, Corp. Petition for Exemption , UAS Operation 18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC is prohibit ed from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by t he manufacturer if greater.

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to co nduct operations that

cannot be conducted unde r the terms of the attached COA.

21. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

Numb er) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be av ailable to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official

upon request.

23. The UA must remain clear and give way to all manne d aviation operations and activities

at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structu res unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and,

b. The owner/controller of any vessels, vehicles or st ructures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present

an undue hazard.

26. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission13

DroneBee, Corp. Petition for Exemption , UAS Operation from property owner/controller or authorized representative will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applica ble COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov

.

For cl osed

- set motion picture and television filming and production, the following additional

c onditions and limitations apply:

28. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

29. A t least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notificati on may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N

- Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

30. Flight operations may be conducted closer t han 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.14

DroneBee, Corp. Petition for Exemption , UAS Operation Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations mu st comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

CONCLUSION

Under the au thority granted to the FAA by 14 CF R § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, DroneBee hereby requests Exemption to commerc ially operate the following UAS:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D Robotics Aero

h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma A E j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200

If granted, DroneBee ’s operations will provide a positive economic impact to the public as well as advance not only UAS innovation and technology but also the widespread adoption of UAS commercial operation standards an d ethics.