# REINVENTING AVIATION CANADA.&USA.&EUROPE.

LATIN&AMERICA.&ASIA.

1&855&ING&UAVS www.ingrobotic.com&

C ANADA&

@ CORPORATE

Unit 112, 1455 Youville Dr., Ottawa, ON, Canada, K1C 6Z7

Tel :&1&855&464&8287 07 July 2015

Attn:

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC

20590

RE: ING ROBOTIC AVIATION
REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF

FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF RESPONDER

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODER NIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

SUMMARY

ING Robotic Aviation, a Canadian UAV Company located in Ottawa ON

, Canada seeks exemption from the requirements of 14 C.F.R sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.40 7(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an

Unmanne d Aircraft System (ING Robotic Aviation owned Responder Robotic Aircraft ) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption w ill permit I NG Robotic Aviation to operate or sell its Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography (collecting aerial sensor data)

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PET ITIONER

ING Rob otic Aviation has for over 10 + years provided their clients (which include private sector

businesses and non

- profits, along with provincial and federal agencies) with expertise and knowledge in delivering data

- driven aerial sensing solution s in harsh conditions globally

. ING Robotic Aviation sells services and products that deliver airborne sensing solutions and much more. We have flown the equivalent of 81 times around the planet. We have the right solution

for our customers in mapping, ins pections, and monitoring. We are focused on getting them the right information, in the right hands, at the right t ime. The objective of ING Robotic Aviation and our Unmanned Aircraft System ( ING Robotic Aviation owned Responder Robotic Aircraft ) aerial

ope rations is to provide a more affordable, high

- quality aerial remote sensor collection and analysis system for a variety of governmental, commercial, and public uses specifically targeting :



### • Mapping



### • Land management / surveying



### • Oil & Gas



### • Utilities



### • Forestry



### • M ining



### • P recision Agriculture



### • Construction

### ING Robotic Aviation Inc. Request for Exemption Page 2 of 28



# REINVENTING AVIATION • Defence & Public Safety

ING ’ s flight operations teams are fully qualified operators that understand all the rules and regulations concerning the flight of Robotic Aircraft such as Responder

.

BACKGROUND

Unmanned Aircraft Systems : Re sponder , UAS

ING Robotic Aviation seeks an exemption to operate or sell its Responder Robotic Aircraft system for compensation or hire within the NAS. The Responder Robotic Aircraft is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Gr ound Control Station (GCS) utilizing a laptop system . The Responder specifications and limitations are listed in the tables

below . The Responder Robotic Aircraft is equipped with one main rotor ; driven by a Lithium Polymer battery powered electric motor

.

RESPONDER UAS SPECIF ICATIONS

Overall Length (With Canopy) 1245mm (49 inch)

Main Rotor Diameter 1610mm (63 inch)

Main Rotor Blades 710mm (28 inch)

Overall Height (With Canopy) 534mm (21 inch)

Overall Width 406mm (16 inch)

Tail Blade Lengt h 120mm (5 inch)

Tail Rotor Diameter 317.5mm (12.5 inch)

Maximum Payload Up to 3Kg (6.61 lbs.)

Responder Weight (with EO/IR Payload) 8.8 kg (19.5 lbs.)

Carrying Case Dimensions (Exterior) 144.9 x 47.9 x 100.6 cm

57 x 19 x 40 inch

Carrying C ase Weight (without Eqpt) 44.54 Kg (98 lbs.)

Gimbal Performance 2 x axis stabilized Gimbal (roll and pitch axis)

RESPONDER UAS LIMITA TIONS

Maximum Take

- Off Weight (MTOW) 10 Kg (22.04 lbs.)

### ING Robotic Aviation Inc. Request for Exemption Page 3 of 28



# REINVENTING AVI ATION Maximum Wind Condition 28 Km/Hr. (15 knots) 17.4 mile/H r.

Ceiling 3000M (1.86 Miles) ASL

Outside Operating Limits

- 20 to +50 Degree Celsius (14 to 122 Fahrenheit)

Weather No Precipitations

Endurance Cruise Operational: 40 Minutes* Hover Operational: 30 Minutes* Additional Reserve for Safety and Ba ttery Longevity: 5 Minutes*

Flight Performance (can be effected by mechanical performance) • Hovering Accuracy:

- Vertical +/

- 1.0m (3.2 ft.)

- Horizontal +/

- 2m (6.56 ft.)

• Max Speed: +/

- 72 Km/h (44.75 Miles/Hr.)

• Cruise Speed: 50 Km/h (31 Miles/Hr.)

• Left / Right Speed: +/

- 56.7 Km/h (35 Miles/Hr.)

Radio Line of Sight (From Operator) 10 Km 2 (6.25 Miles)

Takeoff & Landing Suitable Area

– Preferably 100m x 100m (328 ft. x 328 ft.) wide

*ENDURANCE TIMES ARE VALID WITH THE 1.2 K G NIKON D800 IN THE

GI MBAL.

PERFORMANCE AND RANG E MAY BE AFFECTED BY ENVIRONMENTAL

AND OPERATIONAL COND ITIONS.

OPERATORS ARE ADVISE D TO ADJUST THEIR PE RFORMANCE

EXPECTATIONS ACCORDI NGLY IN ORDER TO MAI NTAIN SAFE

OPERATION AND PERFOR MANCE OF THE AIRCRAF T.

### ING Robotic Aviation Inc. Request for Exemption Page 4 of 28



# REINVENTING AVIATION Figure 1 : Responder Ground Control Station

Figure 2 : Responder Robotic Aircraft

### ING Robotic Aviation Inc. Request for Exemption Page 5 of 28



# REINVENTING AVI ATION BASIS FOR PETITION

The p etitioner, ING Robotic Aviation , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMR A), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the Responder Robotic Aircraft , UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F .R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, ING R obotic Aviation’s operation of his Responder Robotic

Aircraft meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, ING Robotic Aviation requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

ING Robotic Aviation submits that the reque sted relief is proper since an equivalent level of safety will be ensured. ING Robotic Aviation will use experienced (or well trained personnel for customers that would purchase Responder) or technicians to perform maintenance, alterations, or preventive m aintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Maintenance Schedule, Maintenance Log, and as per the Responder Operator H andbook ). Furthermore, ING Robotic Aviation will document and maintain

all maintenance r ecords for the Responder Robotic Aircraft

.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command , is requested by ING Robotic Aviation to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the Responder Robotic Aircraft in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

ING Robotic Aviation seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the Responder Robotic Aircraft do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, ING Robotic Aviation submits that they

will ensure that the Responder Robot ic Aircraft is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Maintenance Schedule, Maintenance Log, and as per the Responder Operator Handbook ), and that the

aircraft are in a condition for safe flight.

ING Robotic Aviation also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Responder Robotic Aircraft will not have a typical barometric altimeter onboard. However, altitude information of the Responder Robotic Aircraft will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This

alti tude information, combined with ING Robotic Aviation’s operation of the Responder Robotic

### ING Robotic Aviation Inc. Request for Exemption Page 6 of 28



# REINVENTING AVIATION Aircraft within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, ING Robotic Aviation seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. ING Robotic Aviation submits that safety will not be affected by operation of the Responder Robotic Aircraft during daylight

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a to tal duration of approximately 40 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, ING Robotic Aviation provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and addres s of the Petitioner and point of contact is:

Ian Glenn

President

ING ROBOTIC AVIATION Unit 112, 1455 Youville Drive Ottawa, ON

K1C 6Z7

Canada Mobile: (613) 265

- 3960

Fax:

- 951

- 653

- 3201 ian.glenn@ingrobotic.com

B. The Specific Sections Of 14 C.F.R. From Which ING Robotic Aviation Seeks Exemption.

1. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act a s PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC 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 pa ssengers or property for compensation or hire.

2. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civi l aircraft unless it is in an airworthy condition.

3. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

### ING Robotic Aviation Inc. Request for Exemption Page 7 of 28



# REINVENTING AVI ATION (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may 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.

4. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first poin t of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

5. ING Robotic Aviation Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), state s the following: Each owner or operator o f an aircraft: (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaire d as prescribed in part 43 of this chapter [ .]

6. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration

, subsection (a)( 1), states the following: (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 [ .]

7. ING Robotic Aviation Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar 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 certificate in accordance with part 21 of this chapter.

### ING Robotic Aviation Inc. Request for Exemption Page 8 of 28



# REINVENTING AVIATION 8. ING Robotic Aviation Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance record s , subsections (a) and (b), states the following: (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 specified in paragraph (b) of this section: (1) Re cords 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 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 ea ch 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 t he 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 co mpliance, 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 alt eration 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 service.

### ING Robotic Aviation Inc. Request for Exemption Page 9 of 28



# REINVENTING AVI ATION C. The Extent Of Relief ING Robotic Aviation Seeks An d The Reason ING Robotic

Aviation Seeks The Relief.

1. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirem ents, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in conn ection 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 property for compensation or hire.

As set forth more fully below, ING Robotic Aviation submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the Responder Robotic Aircraft unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate eithe r the Responder Robotic Aircraft in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and

structures

.

Further, ING Robotic Aviation submits that all flights of the Responder Robotic Aircraft

, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to ING Robotic

Aviation ’ s business; and (2) will not carry passengers or proper ty for compensation or hire.

2. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow ING Robotic Aviation to determine that the Responder Robotic Aircraft is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., ING Robotic Aviation Aerial Operations Manual, Mainte nance Schedule, Maintenance Log, and as per the Responder Operator Handbook ).

ING Robotic Aviation seeks the requested relief because the Responder Robotic Aircraft do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

ING Robotic Aviation will ensure that the Responder Robotic Aircraft is in airworthy condition based upon its compliance with the operating documents (i.e., Maintenance Schedule,

Maintenance Log, and as per the Responder Operator Handbook ) p rior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and

limitations below.

### ING Robotic Aviation Inc. Request for Exemption Page 10 of 28



# REINVENTING AVIATION 3. Extent Of Relief ING Robotic Aviation Seeks Seeks And The Reason ING Robotic

Aviation Seeks Seeks Reli ef From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations

of the Responder Robotic Aircraft , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL)

, ING Robotic Aviation Seeks the requested relief because the Responder Robotic

Aircraft ’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altit ude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Re sponder

Robotic Aircraft is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requeste d to the extent required to allow flights of the battery powered Responder Robotic

Aircraft during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 40 minutes. ING Robotic Aviation seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Responder Robotic Aircraft will severely constrain the practicality of any aerial video or still photo flight operations that ING Robotic Aviation proposes to conduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the Responder Robotic Aircraft

, the Responder Robotic Aircraft operating documents, and ING Robotic Aviation ’s proposed operating limitations, ensure that ING Robotic Aviation will safely operate the battery powered Responder Robotic Aircraft during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 40

minutes.

5. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)( 1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, ING Robotic Aviation requests relief from these

Sections because the Responder Robotic Aircraft do not require airworthiness certificates. As set forth more fully be low, Responder Robotic Aircraft meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, ING Robotic Aviation will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e.,

### ING Robotic Aviation Inc. Request for Exemption Page 11 of 28



# REINVENTING AVI ATION ING Robotic Aviation Aerial Operations Manual, Maintenance Schedule, Maintenance Log, and as per the Responder Operator Handbook ). Furthermore, ING Robotic A viation will document

and maintain all maintenance records for the Responder Robotic Aircraft

.

D. The Reasons Why Granting ING Robotic Aviation Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the p resent Petition will further the public interest by allowing ING Robotic Aviation to safely, efficiently, and economically perform aerial video and photography for Mapping

, Land management / surveying , Oil & Gas, Utilities

, Forestry

, Mining

, Precision Agri culture and for Defence & Public Safety over certain areas of the United States.

Additionally, use of the Responder Robotic Aircraft will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benef its of ING Robotic

Aviation ’s proposed operation of the Responder Robotic Aircraft will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Responder Robotic Aircraft is battery power ed and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Respo nder Robotic Aircraft would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operatin g in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Responder

Robotic Aircraft do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of Responder Robotic A ircraft

.

Conducting aerial acquisitions with the Responder Robotic Aircraft , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still pho tography flight operations. By using battery power and electric motor , the Responder Robotic Aircraft produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraf t that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Responder Robotic

Aircraft , while reducing the carbon footprint of aerial acquisitions, also eliminates noise po llution,

as the UAS is propelled by a battery powered electric motor , rather than an internal combustion engine.

By using the Responder Robotic Aircraft to perform aerial acquisitions, the substantial risk to life and property in the air and on the groun d, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

### ING Robotic Aviation Inc. Request for Exemption Page 12 of 28



# REINVENTING AVIATION lack of flight crew members located onboard the aircraft, the Responder Robotic Aircraft (weighing app roximately 19.5 pounds at its maximum gross weight with diagonal dimension of

63 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The Responder Robotic

Aircraft Will Benefit The Economy.

In addition to being safe and efficient, the Responder Robotic Aircraft is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of

the Responder Robotic Aircr aft will allow United States based companies, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded

avia tion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered Responder Robotic Aircraft is one such technology that not only allows companies greater operational flexi bility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the Responder Robotic Aircraft , companies can remain competitive and profitable, and therefore, provide gre ater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the Responder Robotic Aircraft , provides a stable workforce that

in creases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the

United States and abroad.

4. There Are No Privacy Issues.

Similar to the m anned aerial acquisition flight operations that have been conducted for decades,

ING Robotic Aviation ’s proposed operation of the Responder Robotic Aircraft will not implicate any privacy issues. Specifically, the Responder Robotic Aircraft will be operate d only in compliance with operating docum ents (i.e., ING Robotic Aviation Aerial Operations Manual,

Maintenance Schedule, Maintenance Log, and as per the Responder Operator Handbook ) which requires property owner involvement as well as local law enforcemen t notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which ING Robotic Aviation Seeks Exemption.

1. Reasons Why The Responder Robotic Aircraft Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consid eration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, ING Robotic Aviation ’s operation of the Responder Robotic

### ING Robotic Aviation Inc. Request for Exemption Page 13 of 28



# REINVENTING AVI ATION Aircraft meet the conditions of FMRA Section 333, and will not require an airw orthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the N AS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactme nt of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance require d by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination 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,

w eight, speed, operational capability, proximity to airports and populated areas, and operation 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 certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the nationa l airspace system.

In seeking this exemption, ING Robotic Aviation submits that the Responder Robotic Aircraft can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the Responder Robotic Aircraft ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Responder Robotic Aircraft Demonstrate Its Safe

Characteristics.

The Responder Robotic Aircraft does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. i. Technical Specifications Of The Responder Robotic Aircraft

. The technical specifications of the Responder Robotic Aircraft is set forth by the Responder

Robotic Aircraft Operator Handbook

, attached he reto as Appendix B

. ii. The Responder Robotic Aircraft Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

The Responder Robotic Aircraft may be operated in both manual and global positioning flight

modes. A complete description of the flight and navigational modes of the Responder Robotic

Aircraft is provided at pages 147 through 154 in the Responder Robotic Aircraft Operator

Handbook attached her eto as Appendix B

.

### ING Robotic Aviation Inc. Request for Exemption Page 14 of 28



# REINVENTING AVIATION iii. The Responder Robotic Aircraft is Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Responder Robotic Aircraft will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Responder Robotic Aircraft does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GP S, and will descend to the takeoff position

and shutdown.

A complete description of the Failsafe Functions of the Responder Robotic Aircraft are set forth

at pages 48 through 59 of the Responder Robotic Aircraft Operator Handbook , attached hereto as Appe ndix B

. iv. The Responder Robotic Aircraft GCS And Its Operation.

A complete description of the operation and specifications of the Responder Robotic Aircraft GCS and flight control software is provided at pages 90 through 146 of the Responder Robotic

Ai rcraft Operator Handbook

. The Responder Robotic Aircraft User Manual is attached hereto as Appendix B

.

b. Flight Operations Of Responder Robotic Aircraft Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

ING R obotic Aviation staff (or qualified customer’s operator Trained by certified ING Robotic Aviation’s Instructor) will be the only persons to act as a pilot in command (PIC) of the Responder Robotic Aircraft . Additionally, a safety observer will assist him a t all times during flight time.

c. Flights Of Responder Robotic Aircraft Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, ING Robotic Aviation proposes to commercially operate the Responder Robotic Aircraft for t he special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations. 1. Operations authorized by this grant of exemption will be limited to the following

aircraft descr ibed in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: Responder Robotic Aircraft . Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations unde r this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet a bove ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC

must be in feet AGL. 5. The UAS 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

### ING Robotic Aviation Inc. Request for Exemption Page 15 of 28



# REINVENTING AVI ATION than corrective lenses, as specified on the PIC’s FAA

- issued airman medical

certificate.

6. The use of first person view (FPV) by the PIC or s afety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at al l 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 SO can perform the func tions prescribed in the operating

documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of

ex emption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documen ts. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised docum ents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating

documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight . If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The

Ground Control S tation must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. 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. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

### ING Robotic Aviation Inc. Request for Exemption Page 16 of 28



# REINVENTING AVIATION 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life lim it requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be n oted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

thi rd

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated u nder the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons n ot essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 1 4 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rule s (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operat ion is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

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

### ING Robotic Aviation Inc. Request for Exemption Page 17 of 28



# REINVENTING AVI ATION 22. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (consid ering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certif icate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption mu st be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91. 203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (person s other than the PIC, SO, operator trainees or essential 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. Th e 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 and/or;

b. The aircra ft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating

### ING Robotic Aviation Inc. Request for Exemption Page 18 of 28



# REINVENTING AVIATION closer to those objects and determined that it d oes not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access pr operty with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable 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.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

ING Robotic Aviation submits that the equivalent level of safety estab lished by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Responder

Robotic Aircraft unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely opera te the Responder Robotic Aircraft in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering ING Robotic Aviation ’s proposed area o f operations, and the operating limitations

set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the Responder Robotic Aircraft

, ING Robotic Aviation submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for ING Robotic Aviation ’s specific proposed flight

o perations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11 110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

ING Robotic Aviation will not allow any PIC to operate the Responder Robotic Aircraft unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the Respond er Robotic Aircraft training and currency requirements, that the PIC is able to safely operate the Responder Robotic Aircraft in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from p eople, vessels, vehicles

and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot op erating the same make and model of UAS to be used for operations

### ING Robotic Aviation Inc. Request for Exemption Page 19 of 28



# REINVENTING AVI ATION under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 111 38, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during ING Robotic Aviation ’s proposed operations. The Administrator has held that prior documented flig ht experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exempt ion No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accom plish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption N o. 11138 at page 15. Accordingly, ING Robotic Aviation will ensure safe operations by not allowing any PIC to operate the Responder Robotic Aircraft unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that

the PIC is able to safely operate the Responder Robotic Aircraft in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption F rom The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, ING Robotic Aviation will ensure that the Responder Robotic Aircraf t is in an airworthy condition based upon the UAS’s compliance with its operating documents and as

stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

### ING Robotic Aviation Inc. Request for Exemption Page 20 of 28



# REINVENTING AVIATION 4. Reasons Why An Exemption Fr om The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the

altitude information of Responder Robotic Aircraft will be provided to the PIC via GPS

equ ipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with

ING Robotic Aviation’s operation of the Responder Robotic Aircraft within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11 064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption wou ld ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Responder Robotic

Aircraft ; (2) the limitations on the proposed flight operations; and (3) the location of the propose d flight operations. Accordingly, ING Robotic Aviation will ensure that it will safely operate the battery powered Responder Robotic Aircraft during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 40 minutes.

He re, as in Exemption No. 11109, the technical specifications of the Responder Robotic Aircraft ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R . Section 91.151(b). Furthermore, safety will be ensured as the Responder Robotic Aircraft provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining ba ttery power, and again at approximately 10% remaining battery power. At the critically low battery level, the Responder Robotic Aircraft will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

### ING Robotic Aviation Inc. Request for Exemption Page 21 of 28



# REINVENTING AVI ATION In seeking this exemption, ING Robotic Aviation submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.4 09(a)(1) & (a)(2), and 91.417(a) & (b) will be met because ING

Robotic Aviation will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., ING Robotic Aviation Aerial Operations Manual, Maintenance Schedule, Maintenance Log, and as per the Responder Operator Handbook ). Furthermore, ING

Robotic Aviation will document and maintain all maintenance records for the Responder Robot ic

Aircraft

.

Since the Responder Robotic Aircraft will be inspected as prescribed by the operating documents, ING Robotic Aviation will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of t he Responder Robotic Aircraft Operator Handbook is attached hereto as Appendix B; a copy of the Responder Robotic Aircraft

Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because ING Robot ic Aviation will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equiv alent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Responder Robotic

Aircraft will be performed by trained technicians. Maintenance will be documented and maintained utilizing the schedule maintena nce log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limita tions of the UAS are considered.

In consideration of ING Robotic Aviation’s proposed operating limitations, the operating documents, and the technical aspects of the Responder Robotic Aircraft

, ING Robotic Aviation submits that safety will not be adversel y affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented h erein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, ING Robotic Aviation requests that the FAA prescribe special conditions for the intended operation of the Responder Robotic Aircraft , whi ch contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91 .409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 se ts forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to

### ING Robotic Aviation Inc. Request for Exemption Page 22 of 28



# REINVENTING AVIATION national security; and further, provides the authority for such UAS to operate without

airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Responder Robotic Aircraft , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds th at the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescr ibes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to

esta blish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for ING Robotic Aviation ’s intended operation of the Responder

Robotic Aircraft , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91 .121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Summary That Can Be Published In The Federal Register, stating: The Rules From

Which ING Robotic Aviation Seeks Exemption:

ING Robotic Aviation seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption ING Robotic Aviation Seeks: This exemption will perm it ING Robotic Aviation to commercially sell or operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Sup port ING Robotic

Aviation’ s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, ING Robotic Aviation ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth

above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of th e NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.

### ING Robotic Aviation Inc. Request for Exemption Page 23 of 28



# REINVENTING AVI ATION As discussed in detail above, ING Robotic Aviation will operate the Responder Robotic A ircraft safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, ING Robotic Aviation seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 3 33 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Responder Robotic Aircraft commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certai n areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing ING Robotic Aviation to safely, efficiently, and economically operate

the Responder Robotic Aircraft commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, ING Robotic Aviatio n respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit ING Robotic Aviation to operate the Responder Robotic Aircraft commercially for the purpose of conducting aerial video and photography over certain areas of

the United States.

Dated: July 06 , 2015

Respectfully submitted,

Ian Glenn

President

ING ROBOTIC AV IATION Unit 112, 1455 Youville Drive Ottawa, ON

K1C 6Z7

Canada Mobile: (613) 265

- 3960

Fax:

- 951

- 653

- 3201 ian.glenn@ingrobotic.com

### ING Robotic Aviation Inc. Request for Exemption Page 24 of 28



# REINVENTING AVIATION Appendix A

– Glossary of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning Syste m LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

### ING Robotic Aviation Inc. Request for Exemption Page 25 of 28



# REINVENTING AVI ATION Appendix B

– Link to the Responder Robotic Aircraft Operator Handbook : Click

on the link below.

https://drive.google.com/drive/folders/0Bx1wELzc9uFIfjExZTJ3RkM3Nk1tWW9ueHJvdE JoeGxuUVZqa0JzdUxmRklkUlRfam5UX0U

### ING Robotic Aviation Inc. Request for Exemption Page 26 of 28



# REINVENTING AVIATION Appendix C

– Link to the Responder Robotic Aircraft Logbook: Click on the link

below.

https://drive.google.com/drive/folders/0Bx1wELzc9uFI fmI5RTFqUDZmZThyeURyelBDe XVFeS1XNm1TR0d3anFFRDFLbVJ3OWRPbDg

### ING Robotic Aviation Inc. Request for Exemption Page 27 of 28



# REINVENTING AVI ATION Appendix D

– Responder Aircraft Maintenance Log

Form:



## Aircraft Maintenance Log

Rev: 1.1



## THIS PAGE IS INTENTIONNALY LEFT BLANK

### ING Robotic Aviation Inc. Request for Exemption Page 28 of 28



# REINVENTING AVIATION REFERENCE: RESPONDER OPERATOR HANDBOOK 

## Top Level Assembly (i.e.: Responder, GCS, GSE Etc

... )

Enter Product Type



### Module/Component Level

Discrepant Module or Component: 

### Reported By: Print Name Date 

## Discrepancy

Corrective Action

Module or Component Replaced: 

### P/N Off: S/N Off:

P/N On: S/N On:

Repair Statement: IAW

Corrected By: Print Name Signature Date Functional Checks Required? Yes No ( If yes, section below shall be completed in order to close Form) Functional Checks Completed

Completed By: Print Name Signature Date