The Honorable Michael P. Huerta 

Office of the Administrator 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

September 23, 2015 

RE: Baltimore Ravens Limited Partnership sUAS Petition for Exemption Pursuant to 

FMRA Sec 333 and 14 CFR Part 11 

Dear Administrator Huerta: 

The Baltimore Ravens Limited Partnership ('Ravens') hereby petition the FAA for regulatory r elief 

pursuant to Section 333 ofP.L. 112-95 and 14 C.F.R. Sec. 11.81 to conduct commercial flights using the 

DJI Phantom 2 sUAS, DJI Phantom 3 sUAS, and a tethered sUAS (model to be determined) for 

the following applications: 

• Aerial Data Collection 

The Ravens, therefore, seek a request for exemption from airworthiness and the following specific 

Title 14 C.F.R. provisions: 

• 14 C.F.R. Part 21 

•14 C.F.R. 45.23 

· 14 C.F.R. 61.113(a) (b) 

• 14 C.F.R. 61.133(a) 

·14C.F.R. 91.7(a) 

• 14 C.F.R. 91.9 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

1 Winning Drive • Owings Mills, Maryland 2!117 • phone 410.701.4000 
The FAA has issued grants of exemption in circumstances similar in all material respects to those 

presented in this petition, specific Exemptions No. 11062 to Astraeus Aerial, 11109 to Clayco, 

Inc., and 11213 to Aeryon Labs, Inc.: and we therefore request that our petition be granted without 

delay. Additional similar exemptions include (videography) No. 11842, 11843, 11845, 11848, 11850, 

11820, 11822, 11825, 11826, 11829, and 11833, and (aerial data collection) No. 12803, 12792, 12790, 

and 12696. 

The Havens have also provided supporting documentation to include; a General Operations Manual 

(Ravens Manual') which is composed of (1) an operations manual, (2) flight manuals for each of the 

Ravens models: (3) an Operator Training Manual, and (4) a Maintenance and Inspection Manual. 

Please note that all the Ravens Manual (including all of the above listed components) are clearly 

marked "Confidential'' on each page and contain confidential commercial and proprietary 

information that Ravens has not and will not share with others who are not subject to a 

"Nondisclosure Agreement" (NDA). Therefore, the Ravens Manual (including all components) are 

not available to the public and contain operating conditions, procedures and other information that 

are protected from public release or disclosure under the Freedom ofinformationAct 5 USC Sec. 552 

etseq. 

1 Company Description 

This section responds to the specific requirements of 14 CFR Sec 11.81. 

The Baltimore Ravens Limited Partnership is a professional sports team operating in an 

environment where seeking a competitive advantage over your opponents is the key to success. The 

Baltimore Ravens Video Department seeks to utilize UAS to gain superior video perspectives of 

practices to assist coaches and players in evaluation and strategy sessions as well as producing 

promotional material effectively and safely. 

Mailing address and other contact information. ATTN: 

Mark Bienvenu 

Baltimore Ravens Limited Partnership 

1 Winning Drive 

Owings Mills, MD 21117 

Email: Mark.Bienvenu@ravens.nfl 

2 Relevant Statutory Authority 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the P.L. 112-95, the FAA Modernization and Reform Act ('Reform Act'). This law 

directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may 
• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 1 

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 aircraft in the 

national airspace system." 2 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate 

3 Qualification for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Sec· 

tion 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are 

satisfied. The requested exemption would permit Ravens to perform commercial operations under 

controlled conditions in airspace that is 1) limited 2) predetermined 3) restricted, limited, or controlled 

as to access and 4) would provide safety enhancements to the already safe operations in these 

industries presently using conventional aircraft. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to 

"estabhsh requirements for the safe operation of such aircraft systems in the national airspace system." 

Section 333(c) of the Reform Act. 

Each Ravens sUAS weighs 55 lb. or less including payload. Each Ravens sUAS operates under 

normal conditions at a speed of no more than 87 knots. Each Ravens sUAS has the capability to 

operate in either Automatic' or Manual' mode as described in the Ravens Manual. 

Generally Ravens s UAS operations will be below an altitude of 400ft. AGL, within specific accessrestricted areas, either within Class G airspace or with the permission of the ATC, using s UAS 

operated by Ravens·qualified s UAS pilots, and within the visual line of sight of the operator and observer. Such operations will insure that the sUAS will "not create a hazard to users of the National 

Airspace System or the public" as per the FMRA 2012 Section 333. Given the size of the sUAS and 

the operating environment, this petition for exemption meets an equivalent level of safety, in which 

Congress envisioned that the FAA must, by exemption allow commercial operations of UASs to 

commence innnediately. Also due to the size and enviromnent, approval of the application presents no 

national security issue. 

1Public Law 112-95, 'FAA Modernization and Reform Act' Section 333 (a) 

2!d. §333(c). 
Ravens operations will provide a level of safety that is equivalent to current aviation standards. 

Ravens safety procedures, risk assessments, and flight operations standards are described in detail in 

the accompanying Ravens Manual. In brief, the following procedures that apply during operations 

conducted under this exemption request, establish an equivalent level of safety (ELOS) as follows: 

1. The s UAS will weigh less than 55 lb. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Flights will occur during daylight hours. 

4. Flights will occur during Visual Flight Rules Meteorological Conditions (VMC). 

5. Flights will generally be operated at an altitude of no more than 400 feetAGL and within Class 

G airspace. Operations in controlled B,C, or D airspace will be conducted in coordination with 

the proper FSDO and ATC with prior permission. 

6. Flights will be terminated at 25% battery power reserve should that occur during the operation. 

7. All Ravens s UAS will be U.S. registered and display marks either in accordance with 14 C.F.R. 

Part 45, Subpart C or approved alternative markings. 

8. Operations will be conducted in defined regions and over property authorized for this use by the 

landowner. All operations will remain within the geographic boundaries of the operating area. 

Most operations may be conducted within the limitations of the blanket COA authorization 

provided with 333 grants as of 3/23/2015. 

9. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

10. The operator will obtain the permission of the site owner prior to conducting operations. 

Ravens staff or team members will be notified prior to the operation. Non-participants including spectators will be notified prior to any actual flight operations. Ravens sUAS will 

remain a safe distance away from nonparticipants including spectators. Specific separation requirements will be stated in the Ravens sUAS Operating Manual. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

12. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/or 

the Camera Operator. 
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emergency procedures in the Ravens Manual and demonstrated proficiency with the sUAS being 

operated. The PIC will meet at least the minimum FAA sUAS regulations for licensure. 

Currently, therefore, Ravens PICs must possess at least a sport pilot certificate and hold a 

valid U.S. driver's license, unless alternative proposed in Ravens manual is approved by the 

FAA. 

15. s UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the 

s UAS Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Visual 

Observer), that person can also be designated as the PIC. 

16. Observer and pilot will at all times be able to maintain verbal communication, either directly or 

through electronic means. 

17. Operators and engineers will maintain the sUAS system in a condition for safe operation ac· 

cording to the Ravens Manual and associated manufacturer's maintenance manuals, including 

pre-flight and post-flight inspections. 

18. The PIC and observers will maintain situational awareness and perceive, process, and perform 

risk management prior to and during each operation as described in the Ravens Manual. The 

PIC will terminate the operation in accordance with the Ravens Manual if hazards that cannot 

be acceptably mitigated are observed. 

19. sUAS will safely stop operating and either return home or auto-land at a safe location along 

the flight path if the control link is lost. 

20. For each sUAS, the PIC will have the ability to force a controlled landing at any time. 

In addition to the above, the Ravens have implemented a Safety Management System. The Ravens 

Safety Manager is responsible for conducting safety audits, investigations, and inspections and is 

authorized to stop or prohibit any activity or operations which is considered unsafe. Full details 

are available in the Ravens Manual. 

5 Regulations From Which Exemption is Requested 5.1 Part 61, Certification: Pilots, Flight Instructors, and Ground Instructors 

Extent of Relief 

Part 61, all sections. 
Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing on board. The area of operation is controlled and restricted, and all flights 

are planned and coordinated in advance as set forth in the General Operations Manual (GOM). 

The level of safety provided by the requirements included in the GOM exceeds that provided by a 

single individual holding a commercial pilot's certificate operating a conventional aircraft. The 

risks associated with the operation of the sUAS are so diminished from the level ofrisk associated 

with commercial operations contemplated by Part 61 when drafted, that allowing operations of 

the sUAS as requested with a sport pilot certificate as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b). 

5.2 61.113 Private pilot privileges and limitations: Pilot in command. 

Extent of Relief 

Relief from requirement to possess a private or commercial pilot's license for aerial work such as 

aerial survey and mapping. 

Reason for Relief 

§61.113 (a) stipulates that a holder of a private pilot certificate may not act as a pilot in command 

of an aircraft for compensation or hire: (b) states that a private pilot may act as PIC if the flight is 

incidental to business and does not carry passengers or property. Furthermore, N-8900.227 "Unmanned Aircraft Systems (UAS) Operational Approval'' paragraph 16(c)(2)(c) "Operations without a 

pilot certificate" states that a operations which conform to said paragraph may be performed by a 

PIC that does not possess a private pilots license but that has completed FAA private pilot ground 

instruction and passed the FAA Private Pilot written test. In addition, there is no means currently of 

obtaining a commercial rating for UAS. Thus, we require relief in order to perform aerial work. 

Public Benefit 

As described above, the public benefit includes exponential economic growth, enhanced safety, and 

improved precision agriculture capabilities. In general, commercial small UAS operations provide 

aerial services which are affordable to small businesses, something that would not be possible without 

UAS technology. 

Equivalent Level of Safety 

Our operations fulfill all the requirements in N-8900.227 16(c)(2)(c) for operations without a private 

pilots license. 
Should the exemption be granted allowing commercial operation of the s UAS without an airwor 

thiness certificate no standard will exist for airworthiness ofthe sUAS. 

Equivalent Level of Safety 

Given the size and weight of these aircraft and the requirements contained in the GOM, an equivalent 

level of safety will be achieved by insuring compliance with the sUAS user manuals prior to each 

flight. 

5.4 91.119, Minimum safe altitudes: General. 

Extent of Relief 

Section 91.119 establishes safe altitudes for operation of civil aircraft. 91.119(c) limits aircraft flying over 

areas other than congested areas to an altitude of 500 feet above the surface, except over open water or 

sparsely populated areas, and the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. 

Reason for Relief 

To provide for these operations, the s UAS are normally operated at or below 400 feet AGL. In 

addition, due to the nature of the proposed operations, the PIC and the observer may at times be 

less than 500 feet away from structures during the operation. 

Equivalent Level of Safety 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well 

as the location where it is operated. No flight will be taken without the required permission of the 

property owner and local officials, and advanced notice to participants and spectators. Because of the 

advance notice all affected individuals will be aware of the planned flight. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. described above 

and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently conducted with conventional aircraft operating at or below 500 AGL in other industries. In 

addition, the low· altitude operations of the s UAS will ensure separation between these s UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

5.5 91.121 Altimeter Settings 

Extent of Relief 

§91.121 
Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. 

5.6 91.151, Fuel requirements for flight in VFR conditions. 

Extent of Relief 

§91.151, all provisions. 

Reason for Relief 

The provision requires fuel sufficient for one half hour flight beyond the destination. These sUAS, 

including today's longest endurance platforms, are unable to meet this requirement because of limited 

max flight times. 

Equivalent Level of Safety 

An equivalent level of safety can be achieved by limiting flights for the s UAS according to the safety 

limitations described in the GOM. This restriction would be more than adequate to return the 

s UAS to its planned landing zone from anywhere in its limited operating area. 

5.7 91.405, 91.407, 91.409, 91.417 Inspection and Maintenance Programs 

Extent of Relief 

§§91.405, Maintenance required; 91.407, Operation after maintenance, preventive maintenance, rebuilding, or alteration; 91.409, Inspections; and 91.417, Maintenance records. 

Reason for Relief 

The part 91 provisions are not applicable to a s UAS of the described weight class. Furthermore, 

FAA certified mechanics for s UAS do not at this present time exist, so full compliance is not possible. 

The s UAS flown are modular and as such entire components including engines and propellers are 

minor replacements rather than major repairs. Finally, continuous minor alterations and payload 

reconfigurations of sUAS are designed and required for the operation of sUAS and do not negatively 

impact airworthiness. 
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determined by Ravens. 

6 Public Interest 

The Ravens believe that the enhanced safety achieved using a sUAS with the specifications described in 

this petition and supporting documents and by carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions carrying crew in addition to flammable fuel, 

gives the FAA good cause to find that the UAS operations enabled by this exemption are in the 

public interest. 

The outputs of safe, reliable, and regulatory compliant operations of sUAS provide economic benefits 

historically unparalleled since the invention of flight, benefiting stakeholders at every level, both 

public and private. Lawful, safe aerial robotics operations will create new high-tech employment 

that will stimulate city and state governments; improve industries, create new small and large 

businesses; infuse new interest in STEM for children; and increase the safety of citizens through 

enhanced first-responder capabilities. 

7 Privacy 

All flights will occur over private, limited, or restricted-access areas with the property owner's prior 

consent and knowledge. Operations will be conducted by trained crew and all other individuals will 

either be a part of the operation or consent to be present at the time of operations. 

8 Federal Register Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 

45.23(b);14 C.F.R. §§61.113( a) & (b), 61.133(a); 91.7 (a); 91.9 (b) (2); 91.109; 91.119; 91.121; 

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

& (b) to operates UAS for commercial use. 

9 Conclusion 

The Ravens seek this exemption to conduct commercial operations using sUAS within restrictedaccess areas in the NAS. Without this exemption, sUAS innovation will be suppressed, the public 
exemption@skyward.io if you have any questions or concerns. 

Very Respectfully Yours, 

Baltimore Ravens Limited Partnership 

Richard W. Cass 

President