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United States Department ofTransportation Docket Management System 1200New Jersey Ave., SE WestBuilding Ground Floor Room W12

-140 Washington, DC 20590
Re: **Exemption Request Pursuant t** **o Section 333 of the FAA Reform Act of 2012**
Dear Sir or Madam:
We are writing pursuant to the FAA Modernization and Reform Act of20121 (the "Reform Act") and the procedures contained in 14 C.F.R. 11, to request that RiverWalk Community

Emergency

Response Team (RiverWalk CERT), an owner and operator of a small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so that RiverWalk CERT may operate its small unmanned aircraft I lightweight unmanned aircraft system ("UAS") non-commercially in airspace regulated by the Federal Aviation Administration ("FAA"); as long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.
As identified and described herein, RiverWalk C,E,R,T. is a 501 (C)(3) company and is composed of volunteers who are used to identify hazards to the RiverWalk Of The Palm Beaches, West Palm Beach, Florida community after a disaster, usually

weather related, within its 1 square mile community

. The **Community Em** **ergency Response**  **Team (CERT)**  Program, A FEMA program, educates people about disaster preparedness for hazards that may impact their area and trains them in basic disaster response skills, such as fire safety, light search and rescue, team organization, and disaster medical operations. Using the training learned in the classroom and during exercises, CERT members can assist others in their neighborhood or workplace following an event when professional responders are not immediately

available to help. CERT members also are encouraged to support emergency response agencies by taking a more active role in emergency preparedness projects in their community

. RiverWalk CERT has been actively involved in the technical development ofUAS/ UAV service applications to provide high definition film of its community with a small, unmanned aircraft and lightweight UAS to search, identify and assist the rescue of its community

members RiverWalk CERT exemption request would permit its operation of a lightweight (under 20lb), unmanned (remotely controlled in line of sight) UAS in tightly controlled and limited airspace. The UAS will only operate under 200’ at less than 35MPH, within the boundaries of RiverWalk of The Palm Beaches. The Phantom 3 from DJIhas additional software that can be set to prevent the exceeding of this airspace. As2

identified, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, safety plan or controls in place to prevent catastrophe. Granting RiverWalk CERT request comports with the Secretary of Transportation's (FAA Administrator's) responsibilities to not only integrate UASs into the national airspace system, but to "

... establish requirements for the safe operation of such aircraft systems [UASs] in the national airspace system" under Section 333(c) of the Reform Act. Further, RiverWalk CERT will conduct its operations in compliance with the protocols described herein or as otherwise established by the FAA.
RiverWalk CERT respectfully requests the grant of an exemption allowing it to operate lightweight, remote controlled UAS's.
The Specific Sections of Title 14 of the Code of Federal Regulations, RiverWalk CERT Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a)(l); 14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b). Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1);91.409 (a) (2);91.417 (a) &(b).
The Extent ofRelief RiverWalk CERT Seeks and the Reason It seeks such Relief: RiverWalk CERT submits this application in accordance with the Reform Act, 112 P.L

. 95 §§ 331

-334. Seeking relief from any currently applicable FARs operating to prevent RiverWalk CERT contemplated search and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. RiverWalk CERT lightweight UASs meet the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of RiverWalk CERT lightweight UASs are expressly contemplated by the Reform Act. RiverWalk CERT would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAAto promulgate rules governing such craft.
The Reform Act guides the Secretary in determining the ty pes of UASs that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated near airports or crowds; and, Whether the UAS will be operated by line of sight. 112 P.L

. 95 § 333 (a). Each of these items militates in favor of an exemption for RiverWalk CERT3

RiverWalk CERT UASs utilizes four counter

-rotating propellers for extreme balance, control and stability

. They each weigh less than 55 pounds, including cinematic or other equipment. The RiverWalk CERT small unmanned aircraft is designed to operate at less than
a 50 knot maximum speed. It is capable of vertical and horizontal operations but operate only within the line of sight of the remote control pilot. In addition to the remote control pilot, RiverWalk CERT uses a spotter and a technician, such that, at minimum, three RiverWalk CERT personnel govern the safe flight of a RiverWalk CERT aircraft at all times. Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. RiverWalk CERT does not operate its UASs with less than twenty five percent battery capacity

. Safety systems in place include a GPS mode that allows the RiverWalk CERT UAS to hover in place if communication with the radio control pilot is lost and then slowly

descend the DAS at twenty five percent battery capacity. Further, RiverWalk CERT UAS is programmed in some instances, to slowly follow a predetermined set ofway

points to return to a safety point if communications are lost.
RiverWalk CERT operates no closer than 4 miles of PBI and no higher than 200’ but will get clearance prior to all flights including test flights and generally does not operate it near crowds since the RiverWalk community is composed of single family homes

. The UAS operating software and GPS navigation systems do not allow the RiverWalk CERT UAS vehicles to operate near airports or restricted fly zones. The failsafe software will disable the UAS vehicles from taking off and also limit the UAS systems from operating within specific GPS preset no-fly zones. RiverWalk CERT operation of its small unmanned aircraft will not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of RiverWalk CERT UAS , combined with their operation in well

controlled areas, falls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Indeed, RiverWalk CERT UASs have a demonstrable safety record and do not pose any threat to the general public or national security

. The FAA has the authority to issue the exemption to RiverWalk CERT pursuant to the Federal AviationAct, 85 P.L

. 726 (1958), as amended (the Act"). Commercial and Public Benefits

. Granting RiverWalk CERT exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing of the Reform Act. Second, RiverWalk CERT conducts research into safe UAS operations every time it flies its UAS. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Allowing RiverWalk CERT to log more flight time directly relates to its research and its ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with identifying hazards and search methods, namely, full size helicopters.4

RiverWalk CERT UAS is battery powered and create no emissions. If the RiverWalk CERT UAS crashes there is no fuel to ignite and explode. The impact of RiverWalk CERT lightweight UASs is far less than a full size helicopter

. Reasons Why RiverWalk CERT Exemption Will Not Adversely Affect Safety Or How the Exemption Will Provide a Level of SafetyAt Least Equal To Existing Rule:
RiverWalk CERT exemption will not adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting RiverWalk CERT to log more flight time in FAA controlled airspace will allow RiverWalk CERT to innovate and implement new and as of yet undiscovered safety protocols. In addition, RiverWalk CERT submits the following representations of enhancements to current aerial motion picture capture techniques: 1. RiverWalk CERT UASs weigh less than 55 pounds complete with picture quality camera. 2. RiverWalk CERT only operates its UASs below 200 feet; 3. RiverWalk CERT UAS only operates for 5

-25 minutes per flight; 4. RiverWalk CERT lands its UAS when it reaches 25% battery power; 5. RiverWalk CERT remote control pilots operates RiverWalk CERT UAS by line of sight; 6. RiverWalk CERT remote control pilots have video backup should they somehow lose sight ofthe UAS; 7. RiverWalk CERT staffs each flight with a remote control pilot, technician and spotter with communication systems enabling real time communication between them; 8. RiverWalk CERT UAS has GPS flight modes whereby i t hovers and then slowly lands if communication with the remote control pilot is lost or battery power is below25%; 9. RiverWalk CERT activel y analyses electronic flight data and other sources of information to constantly update and enhance safety protocols; 10. RiverWalk CERT only operates in secured areas that are strictly controlled, are away from airports and crowds; 11. RiverWalk CERT conducts extensive brief ings prior to flight, during which safety carries primary importance; 12. RiverWalk CERT always obtains all necessary permissions and permits prior to operation; 13. RiverWalk CERT has procedures in place to abort flights in the event of safety breaches or potential danger. RiverWalk CERT provides a level of safety at least equal to existing rules, and in nearly every instance greater than existing rules. It is important to note that absent the integration of commercial UASs into our national airspace system, helicopters are the primary means of aerial identifying hazards. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight UAS. First, the potential loss of life is diminished because UASs carry no people on board and RiverWalk CERT only operates them in specific areas away from crowds since the RiverWalk community is5

composed of single family homes

. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of RiverWalk CERT UASs allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture amazing images, RiverWalk CERT UAS need not be so close to the objects they are focused on. Accordingly, RiverWalk CERT UAS have operated and will continue to operate at and above current safety levels.
F. Summary RiverWalk CERT seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (l); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate its small unmanned vehicle in identifying hazards, search and assisting rescue operations for first responders. RiverWalk CERT respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by RiverWalk CERT pursuant to the Federal Aviation Act, 85 P.L

. 726 (1958) as amended (the "Act"). Sincerely,

Barry Beeber Deputy Chief of RiverWalk CERT 2576 Irma Lake Drive West Palm Beach, FL 33411 561

-712

-0141 561

-512

-3772 Mobile CC: Leonard Fintzy, Deputy Chief, RiverWalk CERT, Hazel Klopf, pilot