U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: CyPhy Works, Inc. Petition for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 

112-095, (the "Act") and 14 C.F.R. Part 11, CyPhy Works, Inc. ("CyPhy Works"), the 

manufacturer and operator of the Persistent Aerial Reconnaissance and Communication 

System ("PARC"), a tethered aerial device, hereby petitions for an exemption from the following 

Federal Aviation Regulations ("FARs"): 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 

91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 1 CyPhyWorks 

also requests that the FAA grant it a blanket Certificate of Waiver or Authorization ("COA") for 

PARC flights at or below 200 feet pursuant to the FAA's recently announced interim policy.2 

CyPhy Works seeks an exemption to enable it to operate its PARC tethered aerial 

device in the National Airspace System ("NAS"). PARC will be utilized to conduct a range of 

activities, including aerial inspection, agricultural management and research, construction site 

management, law enforcement, emergency first responder communications, asset surveillance 

and observation, energy and mining facilities monitoring and inspection, and unmanned aircraft 

system ("UAS") testing. In addition to being the manufacturer of PARC, CyPhy Works plans to 

utilize the requested exemption in order to operate PARC on behalf of its customers. During 

such operations, CyPhy Works will retain operational control of PARC at all times while PARC is 

1 CyPhy Works' PARC is a tethered aerial device. Until recently, the FAA specifically excluded "tethered aircraft" 

from its definition of "unmanned aircraft." See Integration of Civil Unmanned Aircraft Systems (UAS) in the National 

Airspace System (NAS) Roadmap, First Edition 2013, at 8 and 49 ("[Unmanned Aircraft] UA do not include .. . 

tethered aircraft."); see also Unmanned Aircraft Systems (UAS) Operational Approval, FAA Order 8900.227, July 30, 

2013, at A-5 ("UA do not include ... tethered aircraft."). CyPhy Works believes that the unique features of PARC's 

tethered operations differentiate it from unmanned aircraft that operate unrestricted and untethered, which clearly fall 

within the FAA's definition of "unmanned aircraft." CyPhy Works is submitting this petition to the extent that the FAA 

may require the operators of tethered aerial devices to obtain exemption authority to operate such devices in the 

NAS. CyPhy Works hereby reserves and does not waive its legal right to assert that its PARC aerial device does not 

constitute an "unmanned aircraft." 

2 FAA Press Release, FAA Streamlines UAS COAs for Section 333, March 23, 2015. 

16271 Street, NW Suite 1100 Washington, D.C. 20006 

202.912.4800 800.540.1355 202.861.1905 Fox cozen.com 
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PARC is a small aerial, hex-rotor, tethered device that may elevate up to 400 feet, but at 

all times remains securely tethered to the ground. The tensile tether, in addition to securing the 

aerial device to the ground, is both a power source and a data communications transmission 

mechanism. PARC is unusual not only due to the tether feature and its unique properties and 

functions, but also because it is typically stationary once it reaches its desired altitude and is 

designed to remain in place at that elevation for extended periods of time. The device is 

designed to initiate an automatic landing in the event that the tether is cut, the power to the 

device is lost, or communications with the base station are interrupted. In such situations, 

PARC makes a controlled descent and gently lands in place. Because PARC receives its 

power from the ground, it does not rely on fuel. It also is not battery-operated (although it does 

have a small onboard battery, which is a safety feature to enable a controlled descent and 

landing in the unlikely event that the tether is compromised, or if ground-based power or 

communications with the operator are interrupted). Thus, the operation of PARC does not 

involve any of the safety risks associated with airborne fuel or battery operations. 

PARC is a unique and highly innovative product that is quite different from untethered 

unmanned aircraft, in terms of its features, the way that it operates, and its safety functions. 

Unlike untethered devices that could easily lose wireless or broadcast communication with their 

ground-based operator, thereby potentially compromising control of the device, PARC is subject 

to more direct, physical control modality via its tether to its base station. In addition, tetherbased command and communication is a wired function, and is not subject to radio interference 

interruption. PARC weighs approximately 21.75 lbs. when operating with its full payload 

capacity of 3.6 lbs. It carries neither a pilot nor passengers. It carries no explosive materials 

nor flammable liquid fuels, and will operate in a stationary position exclusively within a secured 

area as set out in the PARC Operator's Technical Manual, attached as Exhibit 1 (hereinafter, 

"the Manual"). 3 The hex-rotor feature also offers additional safety protections because the 

device can maintain its altitude/position even if one or two of the individual rotors were to cease 

functioning. PARC's operations under this exemption will be tightly controlled and monitored at 

all times by the operator, pursuant to the Manual's requirements, and, to the extent applicable, 

in compliance with local public safety requirements. Finally, PARC does not pose any threat to 

national security due to its size, speed of operation, location of operation, tether-limited range, 

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external 

load. Additional information regarding PARC and its operations is provided in Appendix A 

hereto. 

The operation of PARC will provide significant enhancements to surveillance, area 

management, and observation operations. As the FAA has found, an unmanned aerial device 

3 CyPhy Works confidentially submits its PARC Operator's Technical Manual under seal and requests that it be 

withheld from public disclosure pursuant to 14 C.F.R. § 11 .35(b). The Manual contains proprietary information 

regarding PARC's operating conditions and procedures that are confidential, not made available to the public, and 

are protected from release under the Freedom of Information Act, 5 U.S.C. §§ 552 et. seq. 
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or communication with its operator, thereby compromising control of the device. Allowing 

CyPhy Works to operate PARC in the NAS would promote Congress' mandate to the 

Department of Transportation and the FAA to" ... establish requirements for the safe operation 

of [unmanned] aircraft systems in the national airspace system" in accordance with Section 

333(c) of the Act. 5 Accordingly, CyPhy Works respectfully submits that this petition satisfies the 

FAA's criteria for granting an exemption pursuant to section 333 of the Act. 

Grant of an Exemption to CyPhy Works Would be Consistent With Recent FAA 

Exemption Approvals. 

The FAA's grant of the exemption requested herein would be consistent with recent FAA 

exemption approvals. The FAA has granted relief similar to that requested by CyPhy Works for 

aerial devices that are similar in terms of their limited size and weight as PARC, finding that the 

operation of such devices would not adversely affect safety compared to similar operations 

conducted with aircraft that have been issued an airworthiness certificate under 14 C.F.R. Part 

21, Subpart H.6 PARC, however, has the added safety advantages in terms of its design 

features and mode of operation (always tethered and in a stationary position with essentially no 

risk of loss of control). The FAA has found that an aerial device similar to PARC with limited 

weight "significantly reduces the potential for harm to participating and nonparticipating 

individuals or property in the event of an incident or accident" and that the risk of any harm to an 

on board pilot or flight crew during an incident or accident is completely eliminated with the use 

of similar unmanned aerial devices.7 The FAA has also confirmed that while manned aircraft 

could spill fuel, potentially resulting in a fire in the event of an incident or accident, aerial devices 

such as PARC, which carry no fuel, pose no fuel spillage or fire risk following an incident or 

accident. 8 In addition, the FAA has found that the enhanced safety achieved using an 

4 See Petition of Aerial Mob, LLC for Exemption, Exemption No. 11066, Regulatory Docket No. FAA-2014-0353, 

September 25, 2014 ("Aerial Mob Exemption"), at 2; Petition of Pictorvision Inc. for Exemption, Exemption No. 11067, 

Regulatory Docket No. FAA-2014-0357, September 25, 2014 ("Pictorvision Exemption"), at 2; Petition of HeliVideo 

Productions LLC for Exemption, Exemption No. 11065, Regulatory Docket No. FAA-2014-0354, September 25, 2014 

("HeliVideo Exemption"), at 2. 

5 To the extent necessary, CyPhy Works will notify FAA Flight Standards District Offices (FSDOs) prior to operating 

flights that are subject to such notification requirements. 

6 See Petition of Astraeus Aerial for Exemption, Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, 

September 25, 2014 ("Astraeus Exemption"), at 12-13; Aerial Mob Exemption at 2; Pictorvision Exemption at 2. 

7 Astraeus Exemption at 13; Petition ofCiayco, Inc. for Exemption, Exemption No. 11109, Regulatory Docket No. 

FAA-2014-0507, December 10, 2014 ("Ciayco Exemption"), at 10; Petition of Douglas Trudeau for Exemption, 

Exemption No. 11138, Regulatory Docket No. FAA-2014-0481, January 5, 2015 ("Trudeau Exemption"), at 11; 

Petition of Advanced Aviation Solutions LLC for Exemption, Exemption No. 11136, Regulatory Docket No. FAA2014- 0508, January 5, 2015 ("Advanced Aviation Solutions Exemption"), at 12. 

8 Astraeus Exemption at 13; Clayco Exemption"), at 1 0; Trudeau Exemption at 12; Advanced Aviation Solutions 

Exemption at 12. 
Request for Exemption. 

In support of its exemption petition, and as required under 14 C.F.R. § 11 .81, CyPhy 

Works states the following: 

1) The name and address of the petitioner is: 

CyPhy Works, Inc. 

16C Electronics Avenue 

Danvers, MA 01923 

Telephone: 980-329-0972 

Contact person: Kristen Helsel, Vice President - Commercial Systems 

E-mail: kristen.helsel@cyphyworks.com 

2) Regulations from which the exemption is requested: 

CyPhy Works requests an exemption from the following sections of the FARs: 14 C.F.R. 

§ 61.113(a) & (b); 14 C.F.R. § 91 .7(a); 14 C.F.R. § 91 .119; 14 C.F.R. § 91 .121; 14 C.F.R. § 

91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); and 14 

C.F.R. § 91.417(a) & (b). 10 

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

CyPhy Works requests an exemption from sections 61 .113(a) & (b), which limit private 

pilots to non-commercial operations. Section 61.113 states that "(a) no person who holds a 

private pilot certificate may act as a pilot in command ("PIC") of an aircraft that is carrying 

9 Aerial Mob Exemption at 2; Pictorvision Exemption at 2; HeliVideo Exemption at 2. 

10 When considering the size, weight, speed, and limited operating area associated with aerial devices similar to 

PARC and its operations, the FAA has determined that such devices meet the conditions of Section 333, and that 

previous petitioners' requested relief from 14 C.F.R. Part 21 (Airworthiness Certificates), and any associated noise 

certification and testing requirements of 14 C.F.R. Part 36, was not necessary. See Astraeus Exemption at 14; 

Clayco Exemption at 1 0; Trudeau Exemption at 11 ; Advanced Aviation Solutions Exemption at 12. The FAA has also 

previously determined that an exemption from 14 C.F.R. § 45.23(b) (Display of Marks) is unnecessary for aerial 

devices such as PARC that are not certificated. See Astraeus Exemption at 14; Clayco Exemption at 11 ; Advanced 

Aviation Solutions Exemption at 13. Similarly, when previous petitioners sought relief from 14 C.F.R. § 91.9(b)(2) 

(Civil Aircraft Flight Manual in the Aircraft) and 14 C.F.R. § 91.203(a) and (b) (Civil aircraft: Certifications), the FAA 

stated that based on its Memorandum "Interpretation regarding whether certain required documents may be kept at 

an UA's control station," dated August 8, 2014, the requested relief from§§ 91.9(b)(2) and 91.203(a) and (b) was not 

necessary, and that relevant materials could be kept in a location accessible to the PIC in compliance with the 

regulations. See Clayco Exemption at 14; Advanced Aviation Solutions Exemption at 16. In addition, the FAA has 

said that it is unnecessary for operators of unmanned aerial devices to seek an exemption from 14 C.F.R. § 91 .103 

(Preflight Action). See Clayco Exemption at 14; Astraeus Exemption at 20. The FAA has also determined that an 

exemption from 14 C.F.R. §91 .1 09 (Flight Instruction) is not required. See Advanced Aviation Solutions Exemption at 

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passengers, PARC is remotely controlled with no living beings on board. The device operates 

autonomously and no pilot skills are needed to fly it. Its area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the Manual. 

The level of safety provided by the requirements included in the Manual exceeds that provided 

by a single individual holding a pilot's certificate operating a conventional aircraft. The risks 

associated with the operation of PARC are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 that allowing operations of PARC as requested 

with a private pilot as the PIC exceeds the present level of safety required by 14 C.F.R. § 

61.113 (a) & (b). 

The FAA has recently exempted operators of aerial devices similar to PARC from the 

requirements of 14 C.F.R. § 61.113(a) & (b). As the FAA has found, the areas of knowledge 

specified in 14 C.F.R. Part 61 for that of a commercial pilot versus a private pilot cover the same 

fundamental principles. 11 In its approval of an exemption for Astraeus Aerial, the FAA 

determined that a PIC with a private pilot certificate operating an unmanned aerial device would 

not adversely affect operations in the NAS or present a hazard to persons or property on the 

ground. 12 The FAA found that the flight experience obtained by an operator of an unmanned 

aerial device beyond that required for a private pilot certificate in pursuit of a commercial pilot 

certificate in manned flight "does not necessarily aid a pilot in the operational environment [of an 

unmanned aircraft]" and the FAA considered the "overriding safety factor" for unmanned aerial 

device operations to be "the airmanship skills acquired through UAS-specific flight cycles, flight 

time, and specific make and model experience, culminating in verification through testing."13 

The FAA stated that the combination of aeronautical knowledge, UAS airmanship skills, and 

verification through testing was sufficient for a UAS operator to evaluate a pilot's qualifications 

for operations conducted under the FAA's exemption.14 The FAA determined that the 

"knowledge and airmanship test qualifications" developed by the UAS operator, similar to those 

proposed by CyPhy Works for its PARC operations, would ensure safety and that no 

established practical test standards existed that would support a jurisdictional FAA FSDO 

evaluation and approval of the UAS operator's designated examiners. The FAA acknowledged 

that given the limitations of the proposed aerial device operations, it believed such test 

qualifications would not adversely affect the safety of the NAS. 15 The FAA found that a PIC 

holding a private pilot certificate and a third-class airman medical certificate who had completed 

the operator's training and flight currency requirements could conduct the proposed operations 

11 Astraeus Exemption at 15-17. 

12 Astraeus Exemption at 18; see also Clayco Exemption at 12. 

13 Astraeus Exemption at 18; Clayco Exemption at 12. 

14 Astraeus Exemption at 18. 

15 Astraeus Exemption at 18. 
CyPhy Works requests an exemption from section 91.7(a), which requires that no 

person may operate a civil aircraft unless the aircraft is in airworthy condition. As there will be 

no airworthiness certificate issued for PARC, approval of this exemption should be granted 

because no FAA regulatory standard will exist for determining airworthiness. Given PARC's 

size and the requirements contained in the Manual for maintenance and performance of a 

safety check prior to each flight, an equivalent level of safety will be provided. 

The FAA has recently granted other petitioners' requested relief from section 91. 7(a). 

The FAA has stated that although a UAS will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H, its operator's compliance with its Flight Manual 

was a sufficient means for determining an airworthy condition in accordance with section 

91.7(a). 17 As required by the FAA, CyPhy Works will ensure that its aerial device is in an 

airworthy condition - based on compliance with its manuals and performance of a safety check 

- prior to every flight. 18 

14 C.F.R. § 91.119: Minimum Safe Altitudes. 

To the extent the FAA may deem it necessary, CyPhy Works requests an exemption 

from section 91 .119, which establishes safe altitudes for the operation of civil aircraft. Section 

91 .119(d) allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for helicopters by 

the FAA. The requested exemption is for an aerial device that (as the FAA has found in 

previous cases) is similar to a helicopter with respect to altitude of operations. To the extent the 

FAA may deem it necessary, CyPhy Works requests an exemption that would authorize 

operations at altitudes from 0 AGL up to 400 AGL. As set forth herein, PARC will not operate at 

higher than 400 AGL in restricted areas with a safety perimeter, where the general public will 

not be exposed to operations. PARC's maximum operating height is limited by the length of its 

tether. 

The equivalent level of safety will be achieved given PARC's size, weight, and speed, as 

well as the location where it is operated. No flight will be taken over property without the 

permission of the property owner. Because of the advance notice to the property owner and 

participants in PARC's activity, all affected individuals will be aware of the planned flight 

operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the approximately 15 lbs. gross total operating weight of PARC, and the 

16 See Clayco Exemption at 12; Trudeau Exemption at 13. 

17 Clayco Exemption at 13; Advanced Aviation Solutions Exemption at 15; Trudeau Exemption at 17. 

18 Additionally, in accordance with 14 C.F.R. § 91 .7(b), the PIC of an unmanned aerial device is responsible for 

determining whether the aircraft is in a condition for safe flight. In granting section 333 exemptions, the FAA has 

determined that the PIC can comply with this requirement, and therefore relief from§ 91.7(b) is not necessary. See 

Advanced Aviation Solutions Exemption at 16; Clayco Exemption at 13. 
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C.F.R. §91.119 to previous petitioners.19 

14 C.F.R. § 91.121 Altimeter Settings. 

CyPhy Works requests an exemption from section 91.121, which requires each person 

operating an aircraft to maintain cruising altitude by reference to an altimeter that is set " ... to 

the elevation of the departure airport or an appropriate altimeter setting available before 

departure." As PARC does not utilize an altimeter, but rather relies on a digital barometric 

sensor and/or a GPS altitude read out, an exemption may be needed. An equivalent level of 

safety will be achieved by the operator, pursuant to the Manual, confirming the altitude of the 

launch site shown on the ground station altitude indicator before flight. 

The FAA has recently granted exemptions from 14 C.F.R. § 91.121 to other operators of 

unmanned aerial devices. The FAA found that even though an operator would not have a 

typical barometric altimeter onboard the aircraft, its intention to operate a UAS within VLOS and 

at or below 400 feet AGL, combined with its intention to provide altitude information to the UAS 

pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a groundbased on-screen display, was a sufficient method for ensuring the UAS operations did not 

adversely affect safety and that "good cause" existed for granting the requested relief to 14 

C. F. R. § 91 . 121 . 20 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

CyPhy Works requests an exemption from section 91.151 (a), which prohibits an 

individual from beginning "a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, 

and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes." PARC is not powered by fuel; it 

has a tether-powered operational system that provides potentially unlimited flight persistence. 

Given the limitations on PARC's proposed flight area and the location of its proposed operations 

within a predetermined area, a fuel reserve requirement for flight in daylight or night VFR 

conditions is unnecessary. 

Prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including FAA Exemption Nos. 2689, 5745, and 10650. In addition, similar UASspecific relief has been granted in FAA Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. 

19 Astraeus Exemption at 20-21; Clayco Exemption at 14-15; Advanced Aviation Solutions Exemption at 17. 

20 Astraeus Exemption at 21 ; Clayco Exemption at 15; Advanced Aviation Solutions Exemption at 17. 
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as prescribed 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 .. . ," and "others shall inspect or maintain the aircraft in compliance with Part 43." 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections would not apply to PARC. Maintenance on PARC will be performed by its 

operator pursuant to the instructions referenced in the Manual. An equivalent level of safety will 

be achieved because PARC is limited in size with a very small payload and will operate only in 

restricted areas at elevations no higher than 400 feet AGL. In the unlikely event that 

mechanical issues arise, PARC can land immediately. As provided in the Manual, the operator 

will ensure that PARC is in working order prior to initiating flights, perform required basic 

maintenance, and keep a log of any maintenance performed. The operator will be the person 

most familiar with the aerial device and best suited to maintain it in an airworthy condition to 

provide the equivalent level of safety. 

The FAA evaluated previous petitioners' requests and determined that cause for 

granting the exemption was warranted because their manuals contained daily, preflight, monthly 

and yearly checks for the UAS. The FAA found that adherence to the manuals, as required by 

the conditions and limitations imposed by the exemption, was sufficient to ensure that safety 

was not adversely affected.21 

Summary of Federal Register Notice. 

CyPhy Works provides the following summary for publication in the Federal Register. 

Petitioner: CyPhy Works, Inc. 

Section of 14 C.F.R. Affected: 14 C.F.R. § 61 .113(a) & (b); 14 C.F.R. § 91.7(a); 14 

C.F.R. § 91 .119; 14 C.F.R. § 91 .121; 14 C.F.R. § 91 .151(a); 14 C.F.R. § 91.405(a); 14 

C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); and 14 C.F.R. § 91.417(a) & (b). 

Description of Relief Sought: The petitioner, a manufacturer and operator of tetherpowered small aerial devices, is seeking an exemption to commercially operate its 

tether-powered aerial device, weighing approximately 21 .75 lbs. when carrying its 

maximum payload, to conduct aerial inspection, agricultural management and research, 

construction site management, law enforcement, emergency first responder 

communications, asset surveillance and observation, energy and mining facilities 

monitoring and inspection, and UAS testing. 

21 Astraeus Exemption at 14-15; Clayco Exemption at 11; Advanced Aviation Solutions Exemption at 13. 
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populated areas, and proposed operations within visual line of sight, as well as its lack of effect 

on U.S. national security, justify the FAA's approval of CyPhy Works' petition for exemption. 

Accordingly, CyPhy Works respectfully requests that the FAA grant its requested exemption 

allowing the commercial operation of PARC in order to enhance aerial inspection, agricultural 

management and research, construction site management, law enforcement, emergency first responder communications, asset surveillance and observation, energy and mining facilities monitoring and inspection, and UAS testing. CyPhy Works also requests that the FAA grant it a blanket Certificate of Waiver or Authorization ("COA") for PARC flights at or below 200 feet 

pursuant to the FAA's recently announced interim policy. 

Sincerely, 

COZEN O'CONNOR 

JJcMfld 

By: David Heffernan 

Counsel for 

CyPhy Works, Inc. 
aerial inspection, agricultural management and research, construction site management, law 

enforcement, emergency first responder communications, asset surveillance and observation, 

energy and mining facilities monitoring and inspection, and unmanned aircraft system ("UAS") 

testing. It is powered from the ground using a patented microfilament tether that also provides 

secure 10 Mbps Ethernet data connection to a ground station. PARC offers automatic takeoff, 

hovering and landing in commercial grade/industrial strength chassis. On-board battery backup 

allows safe, autonomous landings if base station power or communications are interrupted. 

Depending on how it is outfitted, PARC weighs approximately 21.75 lbs. when operating 

with its full payload capacity of 3.6 lbs. From rotor base to rotor base, it is about 39 inches wide 

at its widest diameter. Its maximum operating altitude above ground is approximately 500 feet, 

but in order to comply with FAA requirements, PARC would be operated at a maximum altitude 

of 400 feet. Because the length of its tether is relatively short and limited, PARC can be 

operated within the visual line of sight of the operator and will operate only within the area 

described in the confidential Operator's Technical Manual, attached as Exhibit 1 (hereinafter 

"the Manual"). Such tethered operations ensure that PARC will"not create a hazard to users of 

the National Airspace System or the public," as required by Section 333(b) of the Act. It can 

maintain its location in continuous wind speeds of 25 knots, gusting to 35 knots. In addition, 

PARC can operate via 35 watts of payload power from a total system draw of 2KW (including 

spooler and base station), which can be furnished by grid or generator, with air vehicle power 

provided via a microfilament tether managed by an intelligent spooler. 

Ethernet communications used by PARC are not broadcast, and therefore do not use 

radio frequencies. Payloads are similarly controlled, using the system's on-board Ethernet 

connections. PARC passes those communications down from the payload to its base station, 

which in turn immediately routes them to a supplemental computer used to control the imaging 

or other sensing payload. CyPhy Works has no current plans to use radio frequencies, not even 

for payload control. 

As required by the FAA, PARC will be operated within visual line-of-sight (VLOS), in 

accordance with Section 333(b)(1 ). PARC is designed for maximum operator attention to 

mission rather than flight micromanagement. Operators can select a target altitude and launch 

the device with minimal effort. Software governs in-flight response to changing wind conditions, 

and responds with automated, controlled flight termination and landing if communications or 

power is lost. Operators can direct the vehicle to a new altitude and re-orient the payload 

gimbal mid-flight if focus on a new observation area or new position is desired, but once that 

new area of interest is specified, again via simple commands, operators are freed to monitor 

sensor output. Safe landing is also automated, with no need to pilot the vehicle down to the 

ground. 
transponders, and can assist in evaluating the effectiveness of ADS-B send/receive technology 

for sense-and-avoid manned-assist and autonomous behaviors; and for gee-fencing 

applications. ADS-B sensing can provide cues to vehicle operators, allowing man-in-the-loop 

controllers to redirect unmanned aircraft systems ("UAS") that may compromise the flight paths 

of other vehicles, or that might stray into interdicted airspace. The same cues can inform 

automated sense-and-avoid behaviors that adjust vehicle altitude or direction without the need 

for operator intervention. PARC can be programmed to use ADS-B input for sense-and-avoid, 

supporting proof-of-concept studies. 

In addition, because it uses ground-based power, and is capable of autonomous flight, 

PARC can operate 24/7 with minimal operator attention. This makes it ideal for use as a test 

vehicle - a flyer lofted at an easily monitored and stable location, providing ADS-B broadcast, 

for UAS to sense and initiate avoidance procedures. For example, a UAS using ADS-B-In might 

see PARC coded as an obstacle (current classifications that may be used include aerostat and 

antenna tower), and use standard avoidance zones associated with that coding. It can be 

positioned at the desired test range, within visual observation range, and broadcast its 

presence. PARC's on-board cameras and ground-based cameras can then watch and record 

the behavior of UASs in its vicinity. 

PARC is designed and equipped for asset surveillance deployments. Use of PARC 

provides long-time static position placement. PARC's long-dwell autonomous operations allow 

it to be positioned over an area of interest for extended observation. Its ability to be relocated 

when anomalies are detected make it especially useful for confined areas that are difficult to 

access, as well as for changing venues. One example of these might be a shipping container 

staging area, in which the cargo loads come and go, creating alleys and visual canyons that can 

be out of range of fixed surveillance assets. A vehicle-mounted PARC unit could be re-based 

as needed during the day, within the confines of a storage yard. 

PARC can also be outfitted with sensors required for crop or natural area management, 

depending on oversight needs - long duration monitoring of a small, well-defined area; or 

oversight of a larger area with option to hover for in-depth analysis. For example, equipped with 

multispectral cameras, both tethered and free flight oversight can spot areas of poor hydration 

or crop nutrition; or can characterize resource/habitat exploitation or movement patterns of 

domesticated or wild livestock. 
least 30 meters ( 100 feet) in diameter with no overhanging obstructions, such as tree branches 

or wires, and no deep standing water. The ideal characteristic of the area of intended PARC 

operation is earth or similar turf soft enough to minimize any impact or potential damage during 

landing, rather than hardtop or concrete. The intended area of operation must also provide 

enough space to accommodate the PARC TESS-Spooler. In addition, the PARC aerial device 

requires a launch/land location with terrain slope of less than 5 degrees, and the PARC TESSspooler requires a set-up location with terrain slope of less than 10 degrees. CyPhy Works will 

not operate PARC in the proximity of any airports, in accordance with Section 333. 

The requested exemption would allow the commercial operation by CyPhy Works of its 

tethered PARC aerial device, with such operations to be conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333 of 

the Act. CyPhy Works' PARC would be operated under controlled conditions in airspace that is: 

1) limited; 2) predetermined; and 3) controlled as to access. PARC is designed and 

manufactured with significant safety features that ensure a high level of safety is maintained 

while in operation. These features include: 

1. If the device's filament is broken for any reason, PARC will immediately shut down and no 

high voltage energy will travel through it; 

2. PARC will automatically land if any single motor fails, there is a loss of power supply, or the 

device overheats; 

3. If PARC cannot hold position in substantial winds, including drifts more than 10 meters, it will 

automatically begin to descend at the same speed as the auto land feature until the windproduced error is corrected and it can once again hold position within 10 meters or less. If the 

situation persists, eventually PARC will simply land; 

4. The PARC filament was designed with sufficient strength that it cannot break with static 

thrust or in a dynamic thrust situation; 

5. The spooler is designed so that the end of the filament provides a mechanical fail-safe stop. 

If the spooler unwinds, it is too heavy for PARC to drag and PARC will stop at that point; 

6. With respect to software and controls systems issues, PARC has undergone and will 

continue to undergo a substantial amount of testing to identify and mitigate software issues, 

bugs, etc., so that PARC can continue to be flown in all types of adverse conditions; and 

7. PARC is designed with appropriate lighting.