Crown Consulting, Incorporated

1400 K ey Blvd , Suite 1100 Arlington, VA 22209

Point of Contact:

Tim Nolan

P.O. Box 1892 Silverthorne, CO 80498

tnolan@crownci.com

315

- 767

- 3913

January 20 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, D.C. 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

Crown Consulting, Incorporated (CCI), pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and Section 333 of the FAA Modernization and Reform Act of 2012

, applies for an exemption from the listed Federa l Aviation Regulations ("FARs") to allow commercial operation of its small Unmanned Aircraft Systems (sUASs) in the national a irspace system (NAS), so long as such operations are conducted within and under the conditions outlined in this petition for exemption, or as may be established by the FAA as required by Section 333. CCI petitions for an exemption from the requirements of:

• 14 CFR Part 21

• 14 CFR 45.23

• 14 CFR Part 61.113(a) and (b)

• 14 CFR Part 91: i. 91.7 (a) ii. 91.9 (b) (2) iii. 91.103(b)(2)

iv. 91.105

v. 91.109

vi. 91.119

vii. 91.121viii. 91.151 ix. 91.203 (a) & (b) x. 91.205 (b)

xi. 91.215

xii. 91.401

- 417

CCI is a multi

- disciplined analytics, information solutions, management, and engineering services firm. Our principal clients are the Federal Aviation A dministration (FAA), National Aeronautics and Space Administration (NASA), and US Department of Energy (DOE). Our work includes field engineering

services for the FAA , focusing on designing and installing VHF and UHF radio and fiber optics (FOTS)

networks for air traffi c and airport communications.CCI plans to use unmanned aircraft systems ( UAS ) for aerial inspection and documentation services

(video and still photography) for its field engineering services projects and other engineering,

construction

, surveying

, data collection, video/still photography, and search and rescue projects located

across the United States. The UAS will reduce the need to physically climb radio towers, to operate cranes, and to operate manned aircraft in close proximity to th e ground and obstacles. UAS based inspections and surveys w ill provide more accurate data in a manner that is safer

, more economical

, and

more efficient with a reduced impact on the envi ronment. Because CCI plans to utilize the UAS in many

of its FAA field engineering projects, the operations will also directly translate to measurable savings for the FAA and ultimately taxpayers.

Petitioner Information : Crown Consulting, Incorporated 1400 Key Boulevard, Suite 1100, Arlington, VA 22209

Phone: 703

- 650

- 0663

Fax: 703

- 243

- 1280

Point of contact:

Tim Nolan

315

- 767

- 3913

tnolan@crownci.com

CCI’s Chief UAS Pilot is a retired USAF pilot with over 3000 hours of flight time and an air transport pilot license. Additional CCI UAS pilots will hold either an airline transport, commercial, private, recreational, or sport pilot certificate.

Relief sought:

CCI proposes to use the following UAS:

DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1

.

CCI will employ the UAS for the following uses:

• Inspections • Aerial surveys and mapping • Obtaining still photographs, video and other da ta collected via onboard sensors

• Search and rescue

These particular aircraft h ave four rotors and four motors in a quadcopter configuration (X4). They weigh less than 55 lbs. including payload, can fly under normal conditions at a speed of no more than 30 knots

. They are equipped with GPS and an auto−return function to the predetermined safe landing area . We will

operate these UAS only in line of sight . We will conduct a ll operations in a manner to insure that the UAS

will “not create a hazard to users of the national airspace system or the public.” (Reform Act Section 333 (b)).

Public benefit: a. Use of UAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods:

i . Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., physically climbing radio masts, crane accidents during infrastructure inspections ).ii. Reduces the cost of time obtaining such information, which benefits consumers and the

economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned

aircraft.

Equivalent level of safety maintained : CCI will ma intain an equivalent or superior level of safety to current practices (both aviation practices and ground based practices, i.e. , climbing radio masts or inspecting infrastructure using cranes) by following these procedures:

a. CCI will comply with maintena nce and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel, and will require a test flight

after such work. b. All flight operations will be conducted by at least two individual s (PIC and visual observer (VO) ) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the grou nd during the flight o perations. The flight crew will include a sensor operator when necessary.

c. The PIC will possess the following credenti als for commercial operations : 1. An Airman Certificate issued under 14 CFR 61 screened by the TSA

2. A medical certificate issued under 14 CFR 67 , or a valid U.S. driver’s license

. 3. Meets the flight review requirements under 14 CFR 61.56

4. Will have completed training and demonstrated competence in the operation of the UAS

to include no rmal operations (take off, landing, traffic/obstacle avoidance, and mission operations) and contingency operations (lost link, emergency landing, degrade d/emergency operations).

5. Will have a minimum of 1000 hours total flight time and 10 hours flig ht time on UAS type, or 50 hours total flight time and 25 hours flight time on UAS type

. d . All flight opera tions will be conducted in accor dance with val id Certificates of Authorizations

.

e . All flight operations will comply with the following:

1. All guidance from the FAA, local flight safety district office, and

2. T he manufacturers’ user manuals.

3. CCI Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) which include lost communication and other emergency and safety procedures.

4. Conducted in visual meteorological conditions

. 5. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a c loud or when visibility is less than 3 statute miles from the PIC.

6. All flights will take place during daylight hours.

7. PIC and VO will main tain visual line of sight ( VLOS ) with the UAS at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.

8. Pre

- flight inspections (including ground control station, if any) for UAS airworthiness

and s afety risk assessments will be conducted prior to each flight.

9. Flight altitudes will remain below 400 feet above ground level.

10. Flight ground speeds will not exceed 50 knots.

11. Maximum flight time for each operational flight will be 50 minutes.

12. Flights will be terminated at 20% battery power reserve should that occur prior to the 50

minute limit.

13. Not intrude into Class B , C or D airspace, or published approach, SID or STAR, or take place within the distances specified ( in the “blanket” COA) surrounding airports without prior permission of the cognizant authority.14. When flying UAS within the distances specified ( in the “blanket” COA) of an airport,

shall sub mit a p lan of a ctivities to the local Flight Standards District Office (FSDO) at least 3 days before the planned flight in accordance with FAA guidelines.

15. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground w ithout their prior permission. All F light operations shall be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures 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 shall cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating clos er to those objects and determined that it does not present an undue hazard; or

c. Flight operations closer than 500 feet from participating persons consenting to be

involved are necessary for the filming production, as specified in the enclosed

MPTOM.

16. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

17. No pilot shall be permitted to operate unless the pilot demonstrates the ability to safely operate the UAS in a manner consistent with th e enclosed MPTOM including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures.

18. PIC qualification flight hours and currency shall be logged in a manner consistent with 14 CFR § 61.51(b).

19. Flights for the purposes of training PICs and VOs (training, proficiency, and experience

building) and determini ng the PIC's ability to safely operate the UAS shall only be conducted during dedicated training sessions. During such training, proficiency, and experience

- building flights, all persons not essential for flight operations shall be considered nonparticipan ts, and the PIC shall operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

20. Any incidents will be reported within 24 hours of occurrence.

21. CCI will maintain liabi lity insurance

. 22. Any applicable local FSDO requirements.

23. All other applicable regulations concerned with the operation of aircraft.

f . Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well

- defined and tested lost link procedures.