MANAGEMENT LABOR 

### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

EASTERN NORTIIERN ~(~'~ Local IOwA IEUNOIS ~ ~ 150
NORTHERN INOIANA 

## Operating Engineers Loca1150 Apprenticeship Fund A Joint Effort of Labor and Management to Further the Aim of Industry www.asiplocaII50.org

July 7, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Exemption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103; 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) Dear Sir or Madam, Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. 11, ASIP Local 150 ("Petitioner") hereby applies for an exemption from Federal Aviation Regulations ("FARs") to allow commercial operation of small unmanned aircraft systems ("sUAS") in airspace regulated by the Federal Aviation Administration ("FAA") for use in a variety of commercial applications so 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 described more fully below, the requested exemption would permit the commercial operation of sUAS under controlled conditions in airspace that is: 1) limited; 2) predetermined; and, 3) controlled as to access. The exemption would also provide safety enhancements to the safe operations currently perFormed by those presently using conventional manned aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "....establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) of the Reform Act. 1. Name and Address of the Petitioner ASIP Local 150 Attn: Martin Turek 19800 W. South Arsenal Dr. Wilmington, IL. 60481 Tel: 815.722.3201 Email: mturek@asiploca1150.org

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APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM

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### JamesM. Sweeney/Chairman David M. Snelten/Secretary 

## Operating Engineers Local 150Apprenticeship Fund A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploco1150.org



### Background ASIP Local 150 (ASIP) is a non for profit organisation under the supervision of the United States Department of Labor based in Wilmington IL. ASIP local 150 specialises in education and training solutions for the construction industry. ASIP supports the development and application of Unmanned Aircraft Systems and robotics to satisfy Governmental and Commercial needs. Our program assists in providing public awareness for new career paths and education tracks that are new and evolving resulting through crossover technologies of robotics, air, ground and water. Following approval of this exemption request would enable ASIP the use of sUAS to conduct operations within a variety of industry/business applications such as education and training for the following industry sectors, education, aerial survey and imaging,ground maping,aerial inspection,power and pipeline patrol,search and rescue,mining survey, quarry survey,visual and infrared infrastructure inspection, general photography and special events, so 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. AII flights will be conducted over our controlled access property or with the consent and knowledge of the property owner or controlling party. AII flight operations will maintain a 500 foot buffer from all nonparticipating persons, vessels, vehicles, and structures unless sufficient barriers are in place to protect nonparticipating persons from undue harm. Flight operations will also only be operated near vessels, vehicles, and structures where the property owner/controller has granted permission and a safety assessment has been made. AII of ASIP flight operations will be conducted by pilots that are holding current FAA Private or Commercial Licenses with appropriate medical certificates. AII visual observers (VO) will be trained to periorm their required duties before flight operations begin.

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### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

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## Operating Engineers Local 150 Apprenticeship Fund A Joint Effort of Labor and Management to 

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Regulations from which the exemption is requested, If such regulations apply to sUASs. 14 C.F.R. Part 21; 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; 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) & (b); 14 C. F. R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b). Statutory Authority for Exemptions The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes civil aircraft as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or pose a threat to national security. In making this determination the Secretary must consider: • The sUAS's size, weight, speed, and operational capability; • Whether the sUAS operates within visual line of sight of the operator; • Operation of the sUAS in close proximity to airports and populated areas. Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such R ;% . 

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### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

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## Operating Engineers Local 150Apprenticeship Fund A Joint Effort of Labor and Management to 

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Unmanned Aircraft Systems Due to the low cost of operation, increased safety to surrounding persons and property, reduced noise and environmental impact, and the versatility of the sUAS platform, we believe that a sUAS can be a great solution to consumers who would, otherwise, have to hire a larger aircraft, such as a helicopter, in order to capture the data that they need. ASIP will maintain a maintenance log book for each sUAS that documents maintenance history. In addition to PIC pre-flight inspections conducted before each ftight our personnel will conduct annual aircraft inspection and maintenance checks. This includes review of system and telemetry data files logged from prior flights, inspection for loose or worn components, balancing of props, cleaning of motors, battery voltage and cell balancing checks, etc., and performing any needed system repair and upgrades to include software/ firmware for the GPS, Flight Controller/Autopilot, Radio Transmitter, and Ground Control Station. AII scheduled or unscheduled maintenance and repair actions are documented within the sUAS maintenance log book. Upon completion of any repair, modification or upgrade, the aircraft is test flown by a qualified PIC and documented within the maintenance log book prior to return to service. ASIP will equip each of its small unmanned multi rotor aircraft for aerial photography, primarily for use in the inspection of towers and inferstructure that would otherwise require great risk to the personnel involved in the inspection process, the stability and maneuverability of UASs afford additional public saftey not only to the personel contracted to do inspection bt to the greater pubic good through better maintained inferstructure, ASIPs sUASs may be used by law enforcement personnel, for search and rescue training as well by other first responders for other photography including video. As identified, similar lightweight, remote controlled sUAS's are legally operated by amateurs with no flight experience, safety plan or controls in place to prevent catastrophe. ASIP 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 sUAS's into our national airspace system, helicopters are the primary means of aerial photography. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight sUAS.



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### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

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## Operating Engineers Local 150Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of lndustry www.osiplocal150.org

Secondary Documentation The following secondary docunientation is provided for reference as supplemental information pertaining to this Petition:
1. ASIP sUAS Flight Standards 2. ASIP Preflight Inspection & Operations Clieck List 3. Phantoni 3 Professional User Manual 4. Blade Chroma RTF User Manual 5. Blade 180 QXHD RTF 6. MAVinci SIRIUS sUAS User Manual 7. SenseFly EBee sUAS User Manual These documents will be retained at the ground control point accessible by the pilot in conimand (PIC). ASIP proposes within this petition the use of ttiree different Muti Rotors sUAS platforms, 

### DJI'sPhantom 3 Professional and Horizon Hobbie's Blade Chroma. and Blade 180 QXHD and two Fixed wing sUAS platforms MAVinci,s SIRIUS, and SenseFly E-bee to support varied niission, payload configurations, and training purposes, General specifications are as follows:
Phantom 3 Professional
Airframe: Quad X Rotor — 960mm Diameter Weight: 1280 g Propulsion: Four 920 KVElectric Motors Propellers: plastic 8"_ Power: 15.2 Volt, (4S) Lithium-Polymer Speed: 0 - 31 knots Flight Time: 23 minutes Autopilot: GPS/GLONASS Data Link: FCC approved 2.4 GHz Video: FCC approved 5.8 GHz Telemetry: Voltage, Current, Altitude, GPS LatlLong, Ground Speed

• Blade Chroma:
Airirame: Quad Rotor 580mm Diameter Weight: 45.9 OZ Propulsion: Four 780KV Electric Motors Propellers: Carbon Fiber 10'' Power: 11.1 Volt, (3S) Lithium-Polymer batteries Speed: 0 - 45 knots Flight Time: 30 minutes Autopilot: GPS/GLONASS ❑ i . ~,~. ~ Fol Data Link: FCC approved 2.4 GHz _

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### James M. Sweeney/Chairman David M. Snelten/Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM

EASTERN NORTNERN LOCaI IOWA ILLINOIS ~v~ 150 

## F;~ NORTHERN INE)IANA 

## Operating Engineers Local 150 Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org

• Blade 180 QXHD RTF ( used for learning flight controls) Ain`rame: Carbon Fiber Hex Rotor — 355mm Diameter Weight: 3.35 oz 

### Propulsion: Four Electric Motors Propellers: 136MM Power. 7 Volt, (1 S) Lithium-Polymer batterie Speed: 0 - 25 knots Flight Time: 5 minutes Autopilot: GPS Flight Controller/Autopilot Data Link: FCC approved 2.4 GHz MAVinci SIRIUS Airframe: Fixed high wing with convetional tail Wingspan: 163cm Weight: 6 pounds Propulsion: Single 900W Brushless DC Motor 

### Power: 18.5 Volt, (4S) Lithium-Polymer batterie Speed: 0 - 35 knots Flight Time: 45 minutes Autopilot: GPS/IMU aided Data Link: FCC approved 2.4 GHz
• Sensefly E-Bee
Airframe: Fixed Swept Wing Pusher Prop 

### Wing Span: 96cm Weight: 1.52 pounds Propulsion: 160W Brushless DC Motor Power: 11.1 Volt, (3S) Lithium-Polymer batteries Speed: 0 - 49 knots Flight Time: 50 minutes Autopilot: GPS/GLONASS Data Link: FCC approved 2.4 GHz

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### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM

EASTERN NORTIIERN Local

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NORTIIERN INDIANA 

## Operating Engineers Local 150Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org

Operation of the Unmanned Aircraft

The PIC will be an FAA licensed airman with at least a private pilot's certificate and third class medical. Additionally, the PIC will have a minimum of 10 hours sUAS multirotor experience of which at least 5 hours are with the specific make/model sUAS to be operated per the ASIP Preflight and Operations Checklist, to ensure the sUAS is in safe condition for flight. The pre-flight will include physical inspection of components, battery voltage level checks, motor run-up, payload system, ground control station and communications checks in preparation of flight. If the inspection reveals a condition that prohibits safe operation, the PIC will remove the aircraft from service until the necessary maintenance has been performed and documented and the sUAS is found to be in a condition for safe flight. Training of PICs who do not meet the sUAS multirotor experience will be gained within dedicated training sessions through use of a multirotor computer simulator (ground training) and the sUAS platform(s) (logged flight time) as requested through this exemption. Flight currency will be maintained by the PIC having logged 30 minutes flight time within the proceeding 90 days with the specific make/model UAS platform. Regaining currency will be achieved in dedicated training/currency sessions. In addition to flight proficiency, the PIC will be trained in use of the radio control transmitter, ground control station, pre-flight inspection of the sUAS, and operational procedures per ASIP sUAS Flight Standards document paraphrased as follows. Minimum crew for each flight operation will consist of the sUAS PIC and Visual Observer (VO). Flights will be conducted within VLOS of the PIC at all times with VO duties assisting PIC in maintaining VLOS and situational awareness of obstructions, hazards and avoiding other aircraft. Communication between the PIC and VO wi;l be maintained through direct voice communications and/or through use of two-way radio or cell phone throughout the duration of flight. Prior to each flight the PIC will conduct a thorough pre-flight inspection, per the ASIP Preflight and Operations Checklist, to ensure the sUAS is in safe condition for flight.

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### • 19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201MANAGEMENT LABOR 

### James M. Sweeney/Chairman David M. Snelten/Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM

~ . EASTERN NORTIIERN Local IowA IllIN015 150

NORTNERN INDIANA 

## Operating Engineers Local 150 Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org

The pre-flight will include physical inspection of components, battery voltage level checks, motor run-up, payload system, ground control station and communications checks in preparation of flight. If the inspection reveals a condition that prohibits safe operation, the PIC will remove the aircraft from service until the necessarv maintenance has been performed and documented and the sUAS is found to be in a condition for safe flight. The PIC will conduct pre-flight planning to include obtaining weather briefings, identifying hazards and obstructions, and establishing predetermined mission flight path and limited and controlled area for safe operation. The Petitioner will submit to the Air Traffic Organization (ATO) a Certificate of Waiver or Authorization (COA) prior to conducting any flight operations. The Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. AII flight operations will be conducted within a limited area that is strictly controlled over private or controlled-access property with permission from the land owner or their authorized representative for each flight to be conducted. The PIC will conduct pre-flight safety briefings with all personnel supporting flight activities in regard to the planned sUAS operations and mission plan prior to each flight. Flight operations will typically be conducted at least 500 feet from all nonparticipating flight operation people, vessels, vehicles, and structures unless there are barriers or structures that safely protects nonparticipating persons in event of accident. In the event nonparticipating persons leave such protection and are within 500 feet of the sUAS, the PIC will immediately cease flight operations. Additionally, if owner of vessels, vehicles, or structures provides permission and the PIC determines safe operations can be conducted with undue risk to operating personnel then flight operations may be conducted closer than 500 feet. ASIP will not conduct flight operations over congested or densely populated areas, or within 5 miles of an airport unless a letter of agreement is obtained from the airport management and per NOTAM. AII flights will be conducted under visual meteorological conditions (VMC) during daylight hours, at less than 50 knots airspeed and an altitude no greater than 500 feet AGL, and will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. Maximum flight time for each operational flight will be 40 minutes and allowing for no less than 20% battery as indicated by real-time telemetry voltage/current data relayed by the aircraft sensors to the PIC control station. In event the PIC losses data link communications, the GPS equipped sUAS have the capability to return to a pre-determined location and land and provides the PIC capability to abort flight and initiate loiter and return-to-home functions. If an in-flight emergency Q

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APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM



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## Operating Engineers Loca1150Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org

By adhering to these operational procedures, ASIP will achieve a safety level equivalent to, or greater than that, directed by the rules in which they seek exemption. sUAS are inherently safer in all facets due to the fact they are much smaller, fly at much slower speeds, have no human operators or occupants on board and no flammable fuels to be concerned of in event of crash. As sUAS processes are further refined, and commercial flight experience gained, the operations will serve to enhance an already higher level of safety compared to manned flight operations in which serves the public's best interest in the FAA's pursuit to integrate UAS into the NAS. Due to the small size of the sUAS involved, ability of the PIC to control and set flight parameters, and the controlled and limited environment in which they will operate, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Additionally, due to the Private Pilot rating of the PIC, the size of the sUASs, limited payload capacity and flight durations, the use of batteries versus flammable fuels, and the limited and tightly controlled areas in which the sUASs will operate, approval of the application presents no national security issue. Given the clear direction in FRMA §333, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts due to battery operation, and reduced costs of sUAS aircraft assets as compared to conventional aircraft, the grant of the requested exemptions is in the public interest. Accordingly, Advanced Robotics respectfully requests that the FAA grant the requested exemption without delay.

Description of Specific Regulations Pursuant to 14 C.F.R. § 11.81(e), ASIP seeks exemption from the below mentioned regulations and provides reason as to why the exemption should be approved based on the level of safety at least equal to that of which the rules require. • 14 C.F.R. Part 21 Subpart H— Airworthiness Certificates :- Establishes: The procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 99.203(a)(1)

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### Jarnes M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM

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: 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also 

### display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not /ess 

### than 2 inches nor more than 6 inches high, the words "limited, " "restricted, " "light-sport, "experimntal, " or "provisional, " as applicable. The sUAS to be flown by ASIP fiave no airworthiness certificate, an exemption may be needed as the sUAS have no entrance to the cabin, cockpit, or pilot station on whicti the word "Experimental" can be placed. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command :- Sections 61.113 (a) and (b) limit private pilots to noncommercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is reniotely controlled by a ground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the use of a sUAS are so diminished from the level of risk associated witti commercial operations contemplated by Part 61 allowing sUAS use by a private pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

### 19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201 AW01 36MANAGEMENT IABOR 

### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM Local [ASTERN NORTNERN IowA IEEINOIS 150 

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NORiNERN INDIANA 

## Operating Engineers Local 150Apprenticeship Fund

A Joint Effort of Labor and Management to Further the Aim of lndustry www.asiploco1150.org

• 14 C.F.R. 91.7(a) — Civil Aircraft Airworthiness ➢ No person may operate a civil aircraft unless it is in an airworthy condition. There is no airworthiness certificate for the sUAS to be operated by ASIP To provide an equivalent level of safety, the PIC will conduct pre-flight inspections to ensure airworthiness. During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon identification of an in-flight anomaly or emergency. A Licensed A&P will conduct annual inspections. Maintenance log books will be maintained for each sUAS thereby achieving an equivalent level of safety. • 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. ➢ Section 91.9 (b) (2) provides: No person may operate a U.S.- registered civil aircraft .. (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given their size and configuration have no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft platform. The equivalent level of safety will be maintained by keeping the sUAS documentation at the ground control point where the PIC will have access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. • 14 C.F.R. 91.103 — Pre-flight Action

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### Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include- (paragraphs a, 

### b, 1 and 2) The PIC will take all actions, to include flight and mission planning, reviewing weather, flight battery requirements, safe take-off and landing areas, and aircraft performance data before commencement of flight. In addition, the PIC will verify the sUAS is ready for flight by conducting a pre-flight inspection and run up of systems and data-link communications checks prior to each flight. The exemption requested for this section is specifically addressed % . . 0

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APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

EASTERN NORTNERN Local Io

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toward the requirements which do not apply to sUAS operations such as runways and air traffic control integration. The airport manager will be notified and approval obtained prior to any operations being executed less than five statute miles of an operating airport. 14 C.F.R. §91.109: Flight instruction :- Section 99.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a radio transmitter or ground control station that communicates with the aircraft via a receiver in the sUAS. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption numbers 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be occupants in the aircraft and by the small size and slow speed of the sUAS.
• 14 C.F.R. 91.119 — Minimum Safe Altitudes ➢ Except when necessary for takeoff or landing, no person may operate an aircraff below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet 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 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a sUAS and the exemption requests authority to operate at altitudes up to 500 AGL underneath navigable airspace and in class E and G airspace maintaining safe separation from manned aircraft, an exemption may be needed to allow such operations. sUAS as well as the limited and controlled location where it is operated. Compared to flight operations with manned aircraft weighing far more than the maximum 55 pounds proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional manned aircraft. In addition, the low-altitude operations


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APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

EASTERN NORTIILRN .~ Local
IOWA IItINO15 150

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### James M. Sweeney/Chairman David M. Snelten /Secretary 

## Operating Engineers Local 150Apprenticeship Fund A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org

The equivalent level of safety will be achieved given the size, weight, speed of theof the sUAS will ensure separation between it and operations of conventional manned aircraft that must comply with Section 91.119. • 14 C.F.R. §91.121 Altimeter Settings 

### ➢ This regulation requires each 

### person operating an aircraft to maintain 

### cruising altitude by reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure. " As the sUAS do not have an adjustable barometric altimeter an exemption is required. An equivalent level of safety will be achieved by the PIC, confirming the altitude of the launch site via the sUAS GPS. • 14 C.F.R. 91.151(a) — Fuel Requirements for Flight in VFR Conditions ➢ No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed— (1) During the day, to fly after that for at least 30 minutes; This regulation is written based on the capabilities of a traditional aircraft which have flight times of several hours or greater; therefore, with the majority of sUAS which have flight times of only an hour or less, this regulation would effectively deny the ability of the air vehicle to operate. To meet the intent, ASIP, will limit its sUAS flights to 40 minutes, or no less than 20% remaining battery power, which ever occurs first, to ensure safe landing and retrieval of the air vehicle and providing at least an equal level of safety. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration ➢ The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate.... (b) No person may operate a civil aircraft unless the airworthiness certificate 

### required by paragraph (a) of this section or a special 

### flight authorization

~~ .A issued under §91.715 is displayed at the cabin or cockpit entrance so that it

. ~ is legible to passengers or crew.

### ■ I* , ~ ❑ ~. ~ 

### 19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201MANAGEMENT LABOR 

### James M. Sweeney/Chairman David M. Snelten /Secretary 

## Operating Engineers Local 150Apprenticeship Fund A Joint Effort of Labor and Management to Further the Aim of Industry www.asiploca1150.org
The sUAS fully loaded weighs no more than 55 Ibs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the PIC will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption numbers 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) Maintenance Inspections ;- 91.405(a) States: Each owner or operator of 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 repaired as prescribed in part 43 of this chapter.

➢ 91.407(a)(1) States: (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. : 91.409(a)(2) States: (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—(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection pen`ormed under paragraph (b) of this section may be substituted for any 

### inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records. Y 91.417(a) &(b) States: (a) Except for work pen`ormed 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: (paragraphs 1(i – iii), 2(i – vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1– 3) Pre-flight inspections and routine maintenance will be accomplished by the PIC to ensure the sUAS is in good working order prior to flight. APPRENTICESHIP AND SKILL IMPROVEMENT PROGRAM

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### 19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201MANAGEMENT LAROR 

### James M. Sweeney/Chairman David M. Snelten /Secretary

APPRENTICESHIP AND SKILL IMPROVEMENTPROGRAM
Ens,cRE, NOR n /ER, `'•. Local own ur.o.s '' y° 150 

## Operating Engineers Local 150 Apprenticeship Fund A Joint Effort of Labor and Management to FLn

- tlier the Aim of Industry www.asiplocoII50.org
If inechanical issues or eniergency situations arise the sUAS can land immediately and given its small size poses very little risk to persons or property. Upon completion of any repair, modification or upgrade, the aircraft is test flown by a qualified PIC and documented within the maintenance log book prior to return to service. Annual inspections and maintenance will be conducted and documented within the sUAS maintenance log book by licensed A&P personnel to nieet the intent of these regulations and provide an equivalent level of safety. 9. Summary the FAA may publish in the r=ederal Register ASIP seeks an exemption froni the following Regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103; 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) to commercially operate its small unmanned aircraft systems to support a variety of industry and business applications, to include, but not liniited to, Education and Training, Survey/ Inspection and Imaging, Agricultural, Forestry, Law Enforcement, and Search and Rescue. Granting ASIP request for exemption will reduce current risk levels and thereby enhance safety. Further, ASIPs sUAS operates at lower altitudes, up to 500 feet AGL, in predetermined and controlled airspace, weighing less than 55 pounds and traveling at speeds less than 50 knots. They will provide at least an equivalent level of safety as that acliieved under current FARs. 

### ASIP Local 150 respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by ASI P Local 150 pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Martin Turek ASIP Local 150 19800 W. South Arsenal Dr. Wilmington IL. 60481 Tel: 815.722.3201 Email: mturek@asiploca1150.org 

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### 19800 W. South Arsenal Road • Wilmington, IL 60487 • 8151722-3201 -,:Z?9 ~ 36