August 7 , 2015

U.S. Department of Tra n spor t ation Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy , LLC ( Airbotsy ) , a survey and aerial imagery acquisition firm, requests exemption from the following Federal Aviation Regulations (FARs) that are found under Title 14 of the Co de of Federal Regulations (CFR): Part 21 Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401-91.417). Such exemptions would allow Airbotsy to commercially
operate its Small Unmanned Aircraft S y stems (“s UASs) to acquire aerial imagery for various industries with respect to the strict operation conditions outlined herein or as established by the FAA as required by Section 333. The value of sUASs would provide benefits to several industries and Airbotsy applies for exemption to allow operations to be conducted within Limited Access Area (LAA)

, which ar e areas that are sparse in population and /or where access is limited to personnel with jobsite clearance or private property

. This will ensure that all persons near the sUAS operations will be given an operations and safety briefing of the planned sUAS operations and/or Airbotsy can effectively prohibit persons from entering the flight perimeter boundaries during the flight operat ions. Specific e xamples of LAAs are construction sites, open

- pit mines, and private property boundaries

.
Airbotsy plans to operate sUASs that are rotorcraft and fixed wing aircraft (see Appendix D) , each weighing less than 55 pounds (including payload), at s peeds less than or equal to 50 knots, and at or
below 400 feet AGL (in full limitations of the FAA Form 7711

- 1 UAS COA) . The sUASs are constructed out of lightweight mater ial s such as foam and/or plastic, do not carry flammable materials, and will be operated by a highly qualified Pilot In Command ( PIC )

. Given these operating limitations, Airbotsy is confident that operations will not create a hazard to users of the N ational A ir S pace (NAS) nor to the general public and that the operation guidelines herein meet the safety that the Congress envisioned that the FAA must, by exemption, allow commercial operation of sUAS.1. Company Background

Airbotsy , LLC

. Jocelyn Javernick PH: 720

- 384

- 4272 Email: Jocelyn Javernick@gmail.com

1624 Market Street, Suite 202 Denver, CO 80202

Airbotsy is a female owned marketing company located in Denver, Colorado that provides digi tal marketing tools, strategies, services, and product s to various industries. Airbotsy is comprised of highly experienced professionals and researchers and in regards to aviation, Airbotsy include s a private pilot with 11 years of experience . This background makes Airbotsy a strong competitor in the emerging comme rcial sUAS market and a prime candidate to receive an exemption for sUAS operations.

2. Statutory Authority for Exemptions FAA Modernization and Reform Act of 2012, Section 333
Under S ection 333(a) , the FAA “shall determine if certain unmanned aircraft syste ms may operate safety in the national airspace system before completion of the plan and rulemaking required by Section 332”. Section 333 (b) of the Reform Act lists several factors that should be considered in determining which UAS c ould allowed to operate in the National Airspace S ystem (NAS). Factors considered for UAS are “their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create
a hazard to the users of the natio nal airspace system or the public, or pose a t hreat to national security”. If a UAS satisfies Section 333 (b), Section 333 (c) states that the FAA can determine “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”. Therefore, if the FAA determines that UAS meets the criteria of Section 333 (b) and does not pose a hazard or threat to the public, NAS, and n ational security, then the FAA has the ability to allow a UAS to operate within the NAS without an airworthiness certification.

3. Meeting the C riteria of Section 333 The operation of sUASs by Airbotsy will meet all criteria specified in Section 333 (b) as described in the paragraphs below.

3. a
. Size, Weight, and Speed All sUASs operated by Airbotsy will be constructed of strong, yet lightweight material allowing all rotorcraft and fixed wing aircraft t o be well below a weight of 55 pounds (including payload). All sUASs will be flown at or below an altitude of 400 feet AGL and at speeds below 50 knots. All sUASs will be operated within the pilot ’s visual line of sight, within 1 nautical mile, and in area s with limited access. T herefore, these small, lightweight, and slow moving sUASs pose minimal to no hazard to infrastructure orpersons . Compared to tr aditional methods of acquiring aerial photographs, the use of
sUASs offer a considerable risk reduction to aircraft that weigh thousands of pounds, carry people, and are powered by flammable material s

.

3.b. Operational Capability The objective of Airbotsy is to provide our clients with high resolution images and videos
that can be utilized for marketing and analysis . While our initial targeted market will be real estate, we would like the opportunity to expand into construction, mining
, agricultural, and surveying industries. Digital imagery data has a variety of uses and
benefits to various industries , but t he most compelling argument for allowing sUASs to capture such data is their ability to provide safe , cost efficient, and fast methods when compared to tradition acquisition methods and thus benefit the economy and the public
interest

. Prior to any flight, the PIC will complete a pre

- flight checklist (Appendix A) and all flights will be conducted with a specific flight protocol (Appendix B). All sUASs will be
launched and landed on

- site without the need for a runway , all flights will be conducted
at or below an alti t u d e of 400 feet AGL (as specified by the current ‘blanket’ COA)

, and within visual line of sight, and visual flight rules (VFR) . Given the built

- in safety of most operating sUASs and the extensive training required for all PIC s (Appendix C)

, the safety of the aerial vehicle will provide a much safer option for aerial imaging and would pose a minimal hazard to the NAS or public.

3.c. Proximity to Airports/Populated Areas
All operations will be performed at considerable and safe distances to airports and populated areas. At a minimum, flights will be conducted 5 NM away from general aviation airports, at least 3 NM away from any populated area, and at an altitude of 400
f ee t AGL or less , which will prevent co nflict with manned aircraft operations. Further, all operations will be conducted in LAA environments were all persons within the area of interest will have explicit information of the flight operations date, time, duration and thus operations will not pos e a threat to individuals or structures on the ground and will remain well clear of any and all air traffic.

3.d. Visual Line of Sight (VLOS)
The sUASs will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (VMC) during day-light hours. Flights will operate within 1 NM and VLOS of the PIC

, at an altitude 4 00 f ee t AGL or less , and will includ e a

s afety Visual O bserver (VO).

4. E quivalent Level of Safety The applicant proposes that exemption be granted to our sUAS operations that have the characteristics and that operate with the limitations listed herein. These lim itations provide an equivalent or higher level of safety to operations under the current regulatory structure that already operates safe protocols followed by helicopters and conventional aircraft with thepurpose of acquiring aerial imagery and survey dat a

. Therefore, Airbotsy sUAS flights will be

limited to the operations described in Appendix B.

5. Basis for Petition

5 .a. Name and Address of the Petitioner Airbotsy , LLC 1624 Market Street, Suite 202 Denver, CO 80202

5 .b. Specific Sections of 14 CFR from which Airbotsy s eek s the following e xemption s:

o 14 CFR Part 21

o 14 CFR 45.23 (b)

o 14 CFR 63.113 (a) & (b)

o 14 CFR 91.7 (a)

o 14 CFR 91.9 (b)

o 14 CFR 91.103

o 14 CFR 91.109

o 14 CFR 91.119

o 14 CFR 91.121

o 14 CFR 91.151 (a)

o 14 CFR 91.203 (a) & (b)

o 14 CFR 91.405

o 14 CFR Part 91 Subpart E (91.401

- 91.417)

5 .b.1. 14 CFR Part 21 Subpart H: Airworthiness Certificates 14 C.F.R §91.203(a)(1) Part 21 Subpart H establishes the requirements for the issuance of an a irworthiness
certificate (FAR §91.203 (a) (1))

. The applicant requests exemption from Part 21 Subpart H pursuant with Section 333 given the size, and operational capability (Limited Area Access described above), proximity to airports and populated areas, and VLOS ope rations with which Airbotsy will operate sUASs. An equal level of safety will be achieved with the operational limitations established in this document ( Appendix B ) for all Airbotsy flights. Specifically , our sUASs flights will occur within VLOS of the PIC, at an altitude of 400 f ee t AGL or less, and only over designated

LAAs

. Further

, coupling our pilots experience in the NAS and with the UAS required training (described in Appendix C) will ensure safely operat ions without creating a hazard to any other aircra ft, peop le, or structures on the ground and thus offers a safer alternative for aerial imagery collection.

5 .b.2. 14 CFR 45.23 (b) : Marking Requirements 45.23 (b) requires certain aircraft to display the roman capital letter “N” with registration number a nd the words “restricted”, “light­sport”, “experimental”, or “provisional”, as applicable, on the entrance to the cabin, cockpit, or pilot station inlettering that is between 2 inches and 6 inches in height. The sUASs operated by Airbotsy are unmanned and h ave no cabin, cockpit, pilot station, or entrance to which these required markings could be displayed. In addition, Airbotsy may not have a registra tion number assigned by the FAA, and therefore seeks full exemption from this regulation. However, Airbotsy proposes to comply with 45.29 (f) by placing the word “EXPERIMENTAL” in the largest possible lettering on top of the aircraft s fuselage

. To ensure an equal or greater level of safety, Airbotsy also proposes to plac e a flag at the ground control station with the w ords “EXPERIMENTAL UAS” in 3 inch lettering. Together, the flag and sUAS marked as “EXPERIMENTAL” will serve to
inform all p ersons within visual distance that UAS’ status and operations

.

5 .b.3. 14 CFR 61.113 (a) & (b) : Private Pilot Privileges and Limitations: Pilot in
Command Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. However, since the s UAS s will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilo t operating the aircraft to hold a n airline transport, commercial, private, recreational, or sport pilot certificate and to have completed the s UAS flight training described in Appendix C (Note: These p ilot requirements for UAS operation are granted in Exemption No. 12326)

. When comparing the knowledge requirements of a private pilot compared to a commercial pilot (Table C 1), the results show that “required areas of knowledge for a commercial versus priv ate pilot cover the same fundamental principles” and the “experience obtained beyond a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily aid a pilot in the operational environment proposed” (Exempt ion No. 11062). Further, the risk associated with manned commercial flights discussed in Part 61 will be decreased with sUAS operations since no pilot or

passengers are on board , operation s will be in limited to con trolled and restricted

areas , and all flights will be planned and coordinated in advance as set forth in the Appendix A and B

.

5 .b.4. 14 CFR 91.7 (a): Civil Aircraft Airworthiness Regulation 91.7 (a) states “no person may operate a civil aircraft unless it is in an airworthy con dition”. Assuming that Airbotsy is a pproved e xemption for
airworthiness c ertification requested in Section 5.b.1

, no FAA standard will exist for determining airworthiness. Therefore, Airbots y seeks full exemption from this regulation. To ac hieve an equal level of safety , prior to each flight Airbotsy will perform the pre

- flight protocol and safety checks described in Appendix A as well as follow all comprehensive maintenance procedures established by the specific sUAS
manufacturer.5 .b.5. 14 CFR 91.9 (b): Civil Aircraft Flight Manual in the Aircraft 91.9 (b) states that no person may operate an aircraft unless there is a current approved flight manual for the aircraft onboard. Since the sUASs utilized are small and lightweight

, it is not physically capable of carrying an aircraft flight manual
onboard. Given the sUAS is an unmanned aircraft with the P IC located at the ground
control station , accessing such documents would be impossible during a flight

. Therefore, Airbotsy requests ex emption from the requirement to carry the aircraft flight manual onboard. To provide an equivalent level of safety, Airbotsy proposes to keep the sUASs manufactures’ flight manual at the ground station and thus allowing the PIC immediate access. The FAA has issued sever al exemptions to this regulation and include: Exemption Nos. 8737,8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

5 .b.6. 14 CFR 91.103 : Preflight Action Regulation 91.103 requires that the PIC be familiar with specific information before each flight such as weather, forecast, and fuel requirements to ensure the safety of flight

. Further, the PIC must be familiar with the information of the approved flight manual relating to aircraft performance and take-off and landing distances. Since the operated sUASs will not have fuel or a FAA-approved flight manual

, Airbotsy
requests exemption from this regulation. To achieve an equal level of safety, Airbotsy will perform the pre

- flight actions listed in Appendix A including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions listed.

5 .b.7. 14 CFR 91.109: Flight Instruction
Section 91.109 states that “no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls”. Since all sUASs will be piloted remotely and do not have dual controls, Airbotsy requests exemptio n from this regulation. An equivalent level of safety can be achieved since pilot and passengers are not aboard the aircraft and thus the lack of dual controls does not pose a safety hazard. Further, the remote ‘controls’ can be passed back
and forth betwe en the Instructor and the Student, which will essentially provide the

same functionality as having dual controls. Examples of exemptions t he FAA has previously approved for aircraft without fully functional dual controls include: Exemption Nos. 5778K & 986 2A.

5 .b.8. 14 CFR 91.119 : Minimum Safe Altitude
91.119 establishes safe minimum altitude to operate civil aircraft. Section 91.119 (c) specifically states that over “other than congested areas” a civil aircraft cannot operate below an “altitude of 500 fe et above the surface, except over open water or sparsely populated areas in those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure

. ” Section 91.119 (d) allowshelicopters to be operated at less than the minimums prescribed, if the PIC of the helicopter complies with any route or altitudes prescribed for helicopters by the
FAA. The functions of the Airbotsy ’s sUASs will be to fly at low altitudes over LAAs that can be described as “other than congested a reas.” All flight operations will be
flown at altitudes of 400 feet AGL or less , with in close proximity to the PIC to
maintain visual line of sight ( VLOS )

. Therefore, Airbotsy requests exemption from this regulation. An equivalent level of safety will be maintained by only operating sUASs over areas that meet our definition of Limited Access Areas, which meet the criteria of “other than congested areas

. ” Given the small size and lightwei ght
airframe s of sUASs, these alternative aerial platforms offer a significant risk
reduction to persons and structures on the ground than a manned aircraft providing
the same service. Further, by operating the sUASs at or below 400 feet AGL, Airbotsy will e nsure that conflicts will be avoided between manned aircraft that are subject to the minimum safe altitude regulation of 91.119 and thus provide an equal or greater level of safety.

5 .b.9. 14 CFR 91.121: Altimeter Settings Regulation 91.121 requires aircraft to maintain cruising altitude by reference to a current reported altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure." Since the sUASs operated may not have a barometric altimeter, Airbotsy requests exemption from this regulation. However, all sUASs operated by Airbotsy will be equipped with GPS that will provide both an initial altitude of the launch site prior to flight operations
as well as real time GPS altitude readings during the flight that are visible to the PIC

, which will ensure that flights at and below 400 feet AGL. Prior to any flight, a separate handheld barometer will be utilized to check that the GPS altitude accuracy is within a tolerable ran ge. This will ensure a level of safety equal to the regulation 91.121. Further details about Airbotsy ’s altitude can be found in the pre

flight operations of Appendix A, and the flight protocol of Appendix B

.

5 .b.10. 14 CFR 91.151 (a): Fuel Requireme nts for Flight in VFR Conditions Regulation 91.151 (a) outlines fuel requirements for flights in VFR conditions and

states that no person may begin a flight in Day VFR conditions unless there is enough fuel to fly to the intended landing point and fly for 30 m inutes after that point is reached. Since the operated sUASs are battery operated and will not carry fuel

, Airbotsy requests an exemption from 91.151 (a)

. Since most sUASs batteries will be exhausted after flights between 20 to 45 minutes (depending on the s UAS model), a 30 minute reserve would leave minimal, if any

, operational flight time. Instead, Airbotsy proposes to operate its sUASs until the battery reaches 20% of its

power (as determined by the onboard monitoring system and the PIC). Such an operation g uideline will ensure that the sUASs will have plenty of battery to return to the launch site safely; however, one major advantage of a sUAS is that unlikemanned aircraft it can easily and safely land anywhere over a Limited Access Areas in which its opera tions are limited to. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,10673, and 10808.

5 .b.11. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration Regulation 91.203 requires all civil aircraft to have within “

.. .an appropriate and
current airworthiness certificate” which must be “displayed at the cabin or cockpit entrance so that is legible to passengers or crew. ” As requested in Section 5.b.1

, Airbotsy is alread y seeking exemption from the airworthiness certificate regulation and thus requires an exemption from this regulation. Further, since the small size and design of sUASs do not provide cabin or cockpit, there is no ability to carry
passengers or certificati on an d r egistration documents. To provide an equal level of safety, Airbotsy p roposes keep these documents at the ground flight control point
where the PIC will have immediate access, to the extent they are applicable to the
sUAS. N umerous exemptions to this regulation have been granted and include: Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

5 .b.12. Part 91 Subpart E (91.401

- 91.417) : Maintenance, Preventative Maintenance
and Alterations These regulations outline the requirements f or maintenance and inspections in
reference to Part 39 and Part 43. 91.405 (a), which states that “no person may perform maintenance, preventive maintenance, and alterations on an aircraft other than as prescribed in this subpart and other applicable regul ations, including part 43 of this chapter. ” Since these sections apply to only aircraft with an airworthiness certificate, for which Airbotsy has applied for exemption (Section 5.b.1 ), Airbotsy
also seeks full exemption from these regulations

. Prior to any flight, the PIC will be responsible for conducting pre

- flight inspections and will following all inspection requirements specified by the manufacturer of the utilized sUAS

. Fu rther details can
be found in Appendix A

.

Preventative maint en ance and corrective maint en ance will be conducted by the manufacture if so stated by the manufactures’ guidelines. However, in instances that the manufacture does not require maint en ance to be performed by the manufacturer, then the PIC will be responsible for conducting maintenance in
accordance with the manufactures procedures and all maintenance performed by
the PIC and /or manufacturer will be documented in accordance with 91.407 (a) (1). Specifically

, records will include “a description of the work performe d; and the date of completion of the work performed; and the signature of the person approving
the aircraft for return to service. ” Further, Airbotsy will ensure that no modifications
or alterations are made to the airframe that a ffect s the flight operating
characteristics of the sUAS

. These proposals are considered to be a n equivalent level of safety since these sUAS s are very limited in size and will carry a small payload andoperate only in restricted areas for limited periods of time. In the event that
mechanical issues arise

, the sUAS can land immediately and will be operating from no higher than 400 feet AGL.

6. Benefits to the Public Approval of the above exemptions and commercial operation of sUASs by Airbotsy will benefit the public in the following f our ways. 1) The commercial use of sUASs to acquire aerial photographs will reduc e the need for manned
aircraft operating in the NAS. With the skies of America becoming busier and Air Traffic Control (ATC) workloads overburdened, the use of sUASs will offer s ome relief to ATC since coordination during ground, take-off, departure, transit, arrival, and landing phases of flight s is not necessary

. 2) R educe d manned aircraft will reduce air and noise pollution . Since all sUASs operated by Airbotsy will be lightweight and battery powered, these sUASs electric motors operate much quieter than manned aircraft and do not burn fossil fuels. Typically, aerial photography is captured by twin engine fixed wing aircrafts that burn between 20 to 30 gallons of fuel per
hour and c an require significant travel time before reaching the intended area of interest. However, acquiring aerial imaging with sUASs can take off and land on site and would greatly reduce both air pollution and noise pollution which is of great benefit to the pub lic

. 3) O perating sUASs for the purpose of aerial photography also reduces the risk to life and property on the ground

. When compared to a twin engine airplanes, sUASs’ size, weight, slow speed, and lack of flammable liquids are considerably less dangerous t o people and/or structures on the ground. 4) Operations of sUASs offer an effective, affordable, and safe method to acquire aerial photography to many business industries such as mining, construction, and agriculture. Such cost efficiencies and improved knowledge from available data will result in greater business
effi ciency and thus the potential for economic growth for such industries

. These high

resolution imagery data generated from sUAS flights can help mines and construction sites monitor progress, plan and design future improvements/work, and aid in site surveys in
both two

- dimensional maps and three

- dimensional terrain models. Further, farmers and
scientists can use this aerial data to estimate biomass, yield monitoring, leaf area indexing, and overall crop health. In all, this data will provide the information n ecessary for
business es of today to thrive in the future and thus in the publics’ interest.

7. Summary for Federal Register

Pursuant to with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy LLC requests exemption from the following Federal Aviation Regulations that are found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401-91.417). Exemption from these regulations would allow Airbotsy , LLC to operate small unmanned vehicle (of 55 pounds or less) in areas with limited and controlled access for the purpose of providing high

- resolution aerial imagery and video

.APPENDIX A: Pre

- flight protocol

This section is divided into t wo areas of i) 24 hours prior to flight and ii) a n immediate p re

- flight inspection checklist.

1) 24 hours prior to flight :

 Prior to a sUAS flight, an area of operation will be established. This area of operation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property

, and applicable airspace within the area of operation.

 Flights will be operated wit hin line of sight of the PIC and Visual Observer

.

 The sUAS will weigh less than 55 lbs total.

 Flights will be operated in Class G airspace whenever possible. lf operation in other airspace is required, the relevant controlling agency will be notified at least 24 hour s prior to the operation and, if required, any necessary permission obtained.

 Flight planning will include flight completion with at least 20 % battery power remaining as measured by the sUAS or appropriate timing.

 lf equipped, and appropriate for the opera tion, sUAS aircraft will utilize GPS navigation, failsafe, return

- to

- home (RTH) and/or flight abort safety features.

 A briefing will be conducted in regard to the planned sUAS operations prior to operation at each new location. All personnel who will be pe rforming duties within the boundaries of the area of operation will be present for this briefing. Therefore, images taken will be of individuals who have also consented to being photographed or otherwise have agreed to be in the area where aerial photograp hy will take place.

 All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or others appropriate governmental agencies.

 Written, to include electronic, and/or oral permission from the relevant property owners will be obtained prior to an operation.

 All employees working on-site will be thoroughly briefed on sUAS operations prior to operations commencing2) Pre

- flight inspection checklist

The pre

- flight checklist/inspection will follow the specific pattern and sequence before each flight.

A. Ground station setup:

I. Place the “EXPERIMENTAL” flag near the area of PIC

II. Visually scan the area of operation for any unforeseen hazards, persons, or
infr astructure
III. Check that all relevant documents are on site and within easy access. These include:

i. PIC’s pilot license and medical certificate
ii. Proof of company’s FAA exemptions
iii. sUAS manufacturer’s flight manual
iv. All maintenance records

B. Pre

- start sUAS inspection checklist

I. Check to ensure the sUAS power is “OFF”

II. Battery

i. Check sUAS batter is fully charged
ii. Check the hand

- held controller’s battery is fully charged

III. Visually inspect the following

i. All propeller blades are free of damages
ii. All propeller blades are securely attached to the sUAS
iii. All surfaces are free from damages
iv. Antenna is undamaged
C. Pre

- flight inspection checklist

I. Turn on the controller and sUAS battery

i. Ensure that all available system read

- outs are clearly displayed on the
controller and within normal range
ii. Test the functionality and free movement of:

1. Propulsion blade(s)

2. Ailerons (if applicable)
3. Check the GPS altitude reading of the sUAS is within range of a separate hand held barometer

. II. Test flight

i. Prior to flying the sUAS for commercial purposes, the aircraft must successfully demonstrate a successful flight of approximately one minute in duration, in a small area free from any hazards, persons, and property and
at an elevation at or below 10 feet AGL.APPENDIX B : Flight protocol

Safety is the first and foremost concern of Airbotsy . Therefore, the following outlines the limitations and conditions which will govern all commercial operations conducted by Airbotsy
PIC in lieu of the approved FAA exemptions and all aircraft will be limited to the specifications of Appendix D

.

 The sUAS will be less than 55 pounds (including payload)

 All sUAS flights will be piloted by an FAA licensed airman with a n airline transport, commercial, private, recreational, or sport pilot certific ate and who will have completed the training outlined in Appendix C.

 The sUAS FAA licensed airman will be considered Pilot in Command (PlC), whether flying or supervising, and will be responsible for safe operation of the flight.

 The sUAS will operate at or below 400 feet AGL

 No flight will be conducted if wind speeds are in excess of 20 mph.

 The sUAS will operate within 1 NM and within visual line of sight ( VLOS ) of the PIC

 The duration of each flight shall not exceed 20% of the sUAS battery’s power or a m aximum total flight time of 30 minutes, whichever occurs first.

 All take-off and landings will occur on-site in accordance with the specifications of the sUAS manufacture’s User Manual

 Flights will avoid direct overflight of any office or maintenanc e buildings located on-site

 Flights will be cancelled in the event that any aircraft or ground control station equipment is inoperative or not fully functional

 Flights will be operated under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR) and only in Visual Meteorological Conditions during daylight hours

 If the PIC or Visual Observer identifies a potential hazard, such as a manned aircraft within close proximity to the designated flight area, the PIC will immediately land the sUAS and operations will only resume after the hazard is clear of the area

 Only one sUAS will be airborne at any given time over a specific site, and at least 2NM away from any other sUAS operation.

 Minimum crew for each operation will consist of the sUAS PlC and a Visual Observer

.

 The sUAS PIC will establish a working relationship with a representative at the local FSDO with which to annually review safety procedures and other operations to further enhance safety.

 All operations will be confined to a Limited Access Area (LAA), which are areas that are sparse in population and/or where access is limited to personnel with jobsite clearance. This will ensure that all persons near the sUAS operations will be given an operations and safety briefing of the planned sUAS operations and/or Airbotsy can effectively prohibit persons from entering the flight perimeter boundaries during the flight operations.APPENDIX C: Pilot training protocol

With safety the highest priority, proper UA flight training is impe rative. In addition to exte nsive knowledge within the NAS, Airbotsy will require :

 The PIC must possess a n airline transport, commercial, private, recreational, or sport pilot certificate

, and a valid third

- class medical certificate or state issued driver license in the case of a sport pilot certificate.

 The PIC must have accumulated and logged a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a simil ar UAS type (single blade or multirotor).

 The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the make and model of UAS to be utilized for operations under the exemption and three take

offs and landings in the prec e ding 90 da ys.

 The PIC will be trained in advance for the safe operation of the sUAS to be operated. This will include operation of the sUAS both in normal and emergency modes of operation, and will include familiarization with the operation manual (or similar) if pu blished by the sUAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace.

 Further, the PIC must have also satisfied any additional qualifications/trainin g/experience that are required by the sUASs manufacturer (i.e. flight operations and procedures manual ).

At this time, Airbotsy does not require pilots to hold a Commercial Pilot Certificate. As shown below in Table C1, the overall knowledge of a Private P ilot vs. a Commercial Pilot is sufficient for the flight maneuvers required for sUAS operations.

Table C1: Private pilot vs. Commercial Pilot knowledge (Taken from Exemption No. 11062).



### Commercial Knowledge Private Knowledge

**Airplane Single Engine Land (ASEL) used for comparison** § 61.125 Aeronautical knowledge. (a) General. A person who applies for a commercial pilot certificate must receive and log ground training... § 61.105 Aeronautical knowledge. (a) General. A person who is applying for a private pilot certificate must receive and log ground training... (b) Aeronautical knowledge areas. (b) Aeronautical knowledge areas. (1) Applicable Federal Aviation Regulations of this chapter that relate to commercial pilot privileges, limitations, and flight operations; (1) Applicable Federal Aviation Regulations of this chapter that relate to private pilot privileges, limitations, a nd flight operations; (2) Accident reporting requirements of the National Transportation Safety Board; (2) Accident reporting requirements of the National Transportation Safety Board;

(3) Basic aerodynamics and the principles of flight; (10) Principles of aerodynamics, powerplants, and aircraft systems; (4) Meteorology to include recognition of critical weather situations, windshear recognition and avoidance, and the use of aeronautical weather reports and forecasts; (6) Recognition of critical weather situations from the ground and in flight, windshear avoidance, and the procurement and use of aeronautical weather reports and forecasts;Table C1 continued. 

### Commercial Knowledge Private Knowledge

**Airplane Single Engine Land (ASEL) used for comparison**

(5) Safe and efficient operation of aircraft; (7) Safe and efficient operation of aircraft, including collision avoidance, and recognition and avoidance of wake turbulence; (6) Weight and balance computations; (9) Weight and balance computations;

(7) Use of performance charts; (8) Effects of density altitude on takeoff and climb performance; (8) Significance and effects of exceeding aircraft performance limitations; **Related to other areas within the private requirements but not referenced specifically** (9) Use of aeronautical charts and a magnetic compass for pilotage and dead reckoning; (4) Use of aeronautical charts for VFR navigation using pilotage, dead reck oning, and navigation systems;

(10) Use of air navigation facilities; (4) Use of aeronautical charts for VFR navigation using pilotage, dead reckoning , and navigation systems ; (5) Radio communication procedures;
(11) Aeronautical decision making and judgment; (12) Aeronautical decision making and judgment; and

(12) Principles and functions of aircraft systems; (10) Principles of aerodynamics, powerplants, and aircraft systems;

(13) Maneuvers, procedures, and emergency operations appropriate to the aircraft; (7) Safe and efficient operation of aircraft, including collision avoidance, and recognition and avoidance of wake turbulence;

(11) Stall awareness, spin entry, spins, and spin recovery techniques for the airplane and glider category ratings;

(14) Night and high

- altitude operations;  Although not mentioned in § 61.105, 3 hours of night flight training is required for the private per § 61.107 and § 61.109. For this comparison, high

- altitude operations are considered not applicable.** 

(15) Procedures for operating within the National Airspace System; and (3) Use of the applicable portions of the “Aeronautical Information Manual” and FAA advisory circulars; (13) Preflight action that includes

— (i) How to obtain information on runway lengths at airports of intended use, data on takeoff and landing distances, weather reports and forecasts, and fuel requirements; and (ii)
How to plan for alternatives if the planned flight cannot be completed or delays are encountered. (16) Procedures for flight and ground training for lighter

than

- air ratings.** **For this comparison (ASEL), these operations are considered not applicable.* * § 61.127 Flight proficiency. (a) General. A person who applies for a commercial pilot certificate must receive and log ground and flight training § 61.107 Flight proficiency. (a) General. A person who applies for a private pilot certificate must rec eive and log ground and flight training (b) Areas of operation. (1) For an airplane category rating with a single

- engine class rating: (b) Areas of operation. (1) For an airplane category rating with a single

- engine class rating: (i ) Preflight preparation; (i) Preflight preparation;Table C1 continued.



### Commercial Knowledge Private Knowledge

**Airplane Single Engine Land (ASEL) used for comparison**
(ii) Preflight procedures; (ii) Preflight procedures; (iii) Airport and seaplane base operations; (iii) Airport and seaplane base operations;
(iv) Takeoffs, landings, and go

- arounds; (iv) Takeoffs, landings, and go

- arounds; (v) Performance maneuvers; (v) Performance maneuvers;
(vi) Ground reference m aneuvers; (vi) Ground reference maneuvers; (vii) Navigation; (vii) Navigation;
(viii) Slow flight and stalls; (viii) Slow flight and stalls;
(ix) Emergency operations; (x) Emergency operations;

(x) High

- altitude operations; and **For this comparison, high

- altitude operations are considered not applicable.** (xi) Postflight procedures. (xii) Postflight procedures.
**Not referenced specifically** (ix) Basic instrument maneuvers;

**Not referenced specifically** (xi) Night operations, except as provided in §61.110 of this part; andAPPENDIX D: Utilized a ircraft

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy request s that the following four aircraft be considered for this exemption :

1. DJI Phantom 3

a. Make: DJI
b. Model: Phantom 3

c. Type: Quadcopter
d. Maximum takeoff weight: DJI does not publish payload details for the Phantom 3. However, it has a total weight of 1280g (2.82 pounds) which includes the battery, propellers, c amera and gimbal. The Phantom 3’s gimbal and camera are not removable, and doing so will void the UAS’s warranty; therefore, modification to allow additional or different payloads is not recommended by the manufacture.

e. Airbotsy will utilize the Phantom 3 fo r video and aerial photography only in Limited Access Areas discussed in the exemption request (No. FAA

- 2015

- 1473). Airbotsy will not modify the aircraft’s payload or flight characteristics.
f. The FAA has issued several exemptions for the similar DJI Phantom 2 and Phantom 2 Vision+ (e.g. No. 11398, 11310A, 11767), which are very similar as shown below in Table 1.

g. Aircraft manuals: http://www.dji.com/product/phantom

- 3/download

Table 1: Phantom 2 Visi on+ compared to Phantom 3.2. DJI S1000+

a. Make: DJI
b. Model: Spreading Wings S1000+

c. Type: Octocopter
d. Maximum takeoff weight: 11 kg (24.25 pounds), aircraft weight with 4.4 kg (9.7 pounds), and a payload up to 6.6 kg (14.55 pounds).

e. Airbotsy will utilize the S1000+ to acquire high resolution aerial images, infrared remote sensing, and lidar. Such payload equipment varies in weight, but never exceeding a total aircraft weight of 11 kg (24.25 pounds).
f. The FAA has issued several exemptions for t he DJI S1000+ (e.g. No. 11694, 11398, and 11184) as well as UAS collection of lidar and infrared data collection (e.g. No. 11338).

g. Aircraft manuals: http://www.dji.com/product/ spreading

- wings

- s1000

- plus/download

3. Sensefly eBee Ag

a. Make: SenseFly
b. Model: eBee Ag

c. Type: Fixed wing
d. Maximum takeoff weight: The published data specifies the aircraft weight with battery and camera is 1.53 pounds. Of this weight the camera (i.e. the maxi mum payload) is 0.33 lbs.

e. Airbotsy will utilize the eBee Ag for agricultural monitoring and remote sensing and will not modify the payload with anything other than manufacture recommended accessories, and never exceeding a total takeoff weight greater than 1.53 pounds.
f. The FAA has issued several exemptions for the eBee Ag (e.g. No. 11635, 11628, and 11339).

g. Aircraft information: https://www.sensefly.com/fileadmin/user_upload/sensefl y/ documents/brochures/eBee_Ag_en.pdf

4. Sensefly eBee RTK

a. Make: SenseFly
b. Model: eBee, eBee RTK

c. Type: Fixed wing
d. Maximum takeoff weight: The published data specifies the aircraft weight with battery and camera is 1.61 pounds. Of this weight the camera (i.e . the maximum payload) is 0.33 lbs.

e. Airbotsy will utilize the eBee RTK for any aerial imagery that requires survey grade georeferencing and will not modify the payload with anything other than manufacture recommended accessories, and never exceeding a total takeoff weight greater than 1.61 pounds.
f. The FAA has issued several exemptions for the eBee RTK (e.g. No. 11956, 11632, and
11585 ).

g. Aircraft information: https://www.sensefly.com/fileadmin/user_upload/sensefly/ documents/brochures/eBee_RTK_en.pdf