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**\~** to-' Snowy Owl Productions

16 November 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 4200 James Ray Drive Suite 161 Grand Forks, ND 58202 Tel: 701-738-4825 matt@skyskopes
.com

Re: Amendment to Snowy Owl Productions, LLC Exemption No
. 11752 Regulatory Docket No. FAA-2015-0947 Dear Sir or Madam: Pursuant to Section 333 ofFAA Modemization Act of2012 and 14 CFR Part 11, Snowy Owl Productions, LLC (Snowy Owl) developer and operator ofSmall Unmanned Aircraft Systems ("sUAS "), equipped to conduct aerial infrastructure inspections, hereby requests a modification to Exemption No. 11752, Regulatory DocketNo. FAA-20 15-0947, Condition and Limitation 26, to allow commercial operations ofa vertical takeoffand landing (VTOL) sUAS within 500 feet ofany person, vessel, vehicle, or structure in a manner consistent with 14CFR 91.119(d). SNOWY OWL will not operate over persons non-participating in the operation ofthe sUAS unless they are under a covered structure. SNOWY OWL will comply with all other conditions and limitations ofExemption No. 11752 or as additionally established by the FAA. Exemption No. 11752 granted SNOWY OWL an exemption for 14CFR Section 91.119c to allow operations Jess than 500 foot AGL. Exemption No. 11752 Condition 26, prohibits the operation ofsUAS within 500 feet ofall non-participating persons, vessels, vehicles, and structures unless owner/controller permission is granted for each vessel, vehicle and structure and all non-participants remain under protection from a potential accident. This limitation is more onerous than what is required ofmanned aircraft. Per 14CFR 91.119(d) helicopters may be operated at less than the minimums prescribed in 14CFR 91.119 (b) or (c) ifthe operation is conducted without hazard to persons or property on the surface
. In addition, each person operating the helicopter complies with any routes or altitudes prescribed by helicopters by the Administrator. All SNOWY OWL VTOL sUAS were registered as rotorcraft (helicopters)
. This modification request is organized by Section. Section I describes the petitioner
. Sections 2-5 respond to the FAA Public Guidance for Petitions for Exemptions filed under Section 333. Risk and Mitigation Justification for this proposal was added to Section 4. Sincerely,



# JIJI-~ Matt Dunlevy President and CEO

# \~ (/1, \ Snowy Owl Productions 

### Section 1: Introduction and Interest ofPetitioner SNOWY OWL, Veteran owned and operated, is the leading developer ofsUAV service operations, training, safety and management programs. The mission ofSNOWY OWL is to support, develop and validate unmanned system operations. Our goal is to provide unmatched quality and safety. SNOWY OWL has five approved FAA Exemptions (11752, 11487, 11527, 11571 and 11577) authorizing the commercial use ofsUAS in the National Air Space. 

### Section 2: Unmanned Aerial Systems Regarding the UnmannedAircraft System 1. Petitioners shoulddescribe how theproposed UAS operation will be safely conductedto minimize risk to the NAS or topersons and property on the ground Specifically, petitioners shoulddescribe the design and operational characteristics for the type(s) ofUAS they intend to operate, e.g. aircraftperformance and performance limitations, operating procedures, andaircraft loading information in as much detail as possible. This could beprovidedin thepetition or in anAircraft Flight Manual orsimilar document. NOTE: The FAA will consider all information anddata submitted by thepetitioner that describes the UAS developmental and operational history. This could include statistical data or other documentation for the specific design and performance characteristics of the UAS, including the operational history and operational failure modes, obtained throughprevious Research & Development (R&D) and/or flight test activities, e.g. operations conducted under a COA, with a civil airworthiness certificate, or under other authorized operating conditions. 2. Petitioners shoulddescribe anyprocedures they would implement, such aspre-flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could beprovided in thepetition, anAircraftFlight Manual, a Maintenance andInspection Manual, orsimilar document. NOTE: The Aircraft Flight Manual andMaintenance andInspection Manual may be separate documents or combined in a single document 3. Thepetitionershoulddescribe the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that ispart of the UAS (i.e., sensors, cameras, etc.), andwhether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements
. NOTE: Petitioners should be able toprovide the FCC approval letter orshow compliance with FCC requirements upon request. 

### General Information Pertaining to All Proposed sUAS All sUAS will conform to SNOWY OWL Exemption No. 11752 or as additionally established by the FAA. This request is limited to SNOWY OWL VTOL sUAS that are registered as rotorcraft (helicopters) in the associated Aircraft Registration Application (AC Form 8050-1 Series). 

### Section 3: Unmanned Aircraft Pilot in Command (PIC) Regarding the UnmannedAircraft PIC 4. Petitioners shoulddescribe the qual(fications required of any PIC(s) who will be direct(Y responsible for the operation of the VAS, including information such as: the level of airman certificate held; any

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(11, \ Snowy Owl Production• applicable training related to the operation; andany minimum hours of flight experience requiredby the PIC(s), both total flight time and the time with theparticular UAS. 

## If the operation would use visual obsen,ers, petitioners shoulddescribe their roles and qualifications. 5. Petitioners shoulddescribe the medical standards andcertification of the PIC(s) directly responsible for the operation of the UAS
. Flight Crew Qualifications and Standards will conform to SNOWY OWL Exemption No. I I752 or as additionally established by the FAA. 

### Section 4: Operations ofsUAS Regarding the Operation of the UnmannedAircraft 6. Petitioners should fully describe their intended UAS operation(s). Petitioners shoulddescribe how the proposed operation(s) wouldnot adversely affect safety , or how they would provide a level of safety at least equivalent to thatprovidedby the rule from which exemption is sought. Petitioners shouldaddress anyplans to implement clearly defined operational borders and procedures to ensurepublic safety, which includespersons and property both in the air andon the ground This can be described in thepetition, in an Operations Manual, or similar document. NOTE: The FAA will closely examine theproposed operation(s) with respect to safety of flight, NAS safety considerations, and the safety of the non-participatingpersons and property during the operational periodandwithin the operational area. 7. Petitioners shouldspecify theproposedmaximum operating speedandaltitude, anddescribe minimum flight visibility anddistance from clouds for their intended operation(s). Petitioners shoulddescribe potential hazards andsafety mitigations associatedwith theseproposed conditions. These issues can be addressed in thepetition, an Operations Manual , or similar document. 8. Petitioners shoulddescribe the characteristics of the area of intendedoperation(s) andthe associated potential hazards, in accordance with the statutory mandate under Section 333 regardingproximity to populatedareas. These issues can be addressed in thepetition, an Operations Manual, or similar document. 9. Petitioners shoulddescribe 

## if they intend to operate in theproximity of any airports, in accordance with the statutory mandate under Section 333 regardingproximity to airports. 10. The VAS must be operatedwithin visual line-of-sight (VLOS), in accordance with the statutory mandate under Section 333(b)(J)
. Petitioners shoulddescribe how they intend to comply with his mandate. 11. Petitioners shoulddescribe anyprocedures they would implement for conducting apreflight safety risk assessment to determine that the VAS is in a condition for safe flight (14 CFR 

### § 91. 7(b)) andthat the planned operation can be completedsafely. These procedures can be addressed in thepetition, an Aircraft Flight Manual, Operations Manual, or similar document. 12
. 

### If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOj) prior to operations

- such as motionpicture andtelevision filming. orpipeline and powerlinepatrol

- petitioners shoulddescribe their intended coordination in this regard for theirproposed operalionM
.

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# ~ til'\ Snowy Owl Produrtion• 13. The FAA intends to require entities who obtain an exemption under thisprocess to also obtain a Certificate of Waiver orAuthorization (COA)from the FAA Air Traffic Organizationprior to conducting operation(s) in the NAS. SNOWY OWL requests a modification to Exemption No. 11752, Regulatory Docket No. FAA-20 15- 094 7, Condition and Limitation 26, to allow commercial operations ofa vertical takeoffand landing (VTOL) sUAS within 500 feet ofany person, vessel, vehicle, or structure in a manner consistent with 14CFR91.119(d)
. Exemption No. 11752 granted SNOWY OWL an exemption for 14CFR Section 91.119c to allow operations less than 500 foot AGL. Exemption No. 11752 Condition 26, prohibits the operation ofsUAS within 500 feet ofall non-participating persons, vessels, vehicles, and structures unless owner/controller permission is granted for each vessel, vehicle and structure and all non-participants remain under protection from a potential accident. This limitation is more onerous than what is required ofmanned aircraft. Per 14CFR 91.119( d) helicopters may be operated at less than the minimums prescribed in l4CFR 91.119 (b) or (c) ifthe operation is conducted without hazard to persons or property on the surface
. In addition, each person operating the helicopter complies with any routes or altitudes prescribed by helicopters by the Administrator. SNOWY OWL requests a modification to Exemption No. 11752, Regulatory Docket No. FAA-20 15- 0947, Condition and Limitation 26, to allow commercial operations ofa vertical takeoffand landing (VTOL) sUAS within 500 feet ofany person, vessel, vehicle, or structure in a manner consistent with 14CFR 91.119(d). SNOWY OWL will not operate over persons non-participating in the operation ofthe sUAS unless they are under a covered structure. 

### Risk Mitigation and Justification The proposed change to Exemption No. 11752 Condition 26 is consistent with the Operation and Certification ofSmall Unmanned Aircraft Systems (sUAS) Notice for Proposed Rulemaking (NPRM)
. SNOWY OWL has a documented safe and effective operating experience conducting infrastructure inspection testing with sUAS operating within the guidelines ofexisting FAA approved Certificates of Authorization proximate to non-participants, participants, vehicles and a structures. It is SNOWY OWL's policy that sUAS shall never be deliberately operated over any personnel. This is included as part ofthe flight safety brief. Prior to flight operations, SNOWY OWL shall conduct an assessment ofthe planned flight area to ensure that the planned flight operations can be conducted in a manner without hazard to persons or property on the surface. Covered shelters to protect participants are briefed prior to flight operations. During sUAS takeoffand landing only the SNOWY OWL flight crew are allowed to be proximate to the sUAS. SNOWY OWL FOM dictates that the sUAS Fail Safe protocols default to " Land Now" vice " Retum to Home" automation to minimize the likelihood ofunintentionally striking a structure or flying over personnel. SNOWY OWL Infrastructure Inspection flight profiles are planned to minimize horizontal flight operations away from the flight crew. This improves flight crew situational awareness, and lessons the likelihood ofinadvertently flying over personnel.

# \~ (II'\ Snowy Owl Produclion• 

### The low mass and lack of liquid fuel on SNOWY OWL sUAS ensure that the consequence ofthe hazard associated with the operation of sUAS is significantly less than that associated with manned helicopters
. All SNOWY OWL VTOL sUAS were registered as rotorcraft (helicopters) as directed by the FAA in the associated Aircraft Registration Applications (AC Fonn 8050-1 Series). SNOWY OWL sUAS operations shall confonn to Exemption No. 11752 except as noted above or as additionally established by the FAA. Images illustrate SNOWY OWL UAVs during recent testing missions and demonstrates the close proximity that is maintained from structures being inspected, routinely inside of20 feet. 

### To ensure safety of personnel on the ground, SNOWY OWL UAVs will remain within a safe distance from structures being inspected andNEVER overflypersonnel. Section 5: Requested Exemptions from Regulations No additional exemptions from regulations are requested beyond what was approved in SNOWY OWL Exemption No. 11752 at this time.

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