U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, S.E.

Washington, DC 20590



# Petition for Exemption Under 14 CFR § 11.81

to Allow Commercial Use of Unmanned Aircraft Systems

June 4, 2015



### Petitioner:

Enterprise Integration LLC

Peter Jensen, Director of Media

7601 Centurion Parkway

Jacksonville, FL, 32256

Cell: 352

- 425

- 5530

Email: pjensen@entint.com

Website: www.eimediaservices.com

Greetings,

This application is substantially based on the FAA's findings in 

### exemption)No.)11306) granted to Hawk Aerial

LLC Aerial on 

### April)8,)2015 , and in reliance on the analysis provided therein.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. FAA Modernizatio n and Reform Act of 2012, PL 112

- 95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

2. Relief sought:



### i. 91.103(b)(2)

ii. 91.105



### iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

a. Enterprise Integration wishes to operate Unmanned Aircraft Systems for commercial purposes to

include (but not limited to) videography, photography, inspections and analyses. This

relief is sought because commercial use of UAS's is currently prohibited by law unless

performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than

55 pounds including payload and energy sources:



### i. DJI Phantom and Inspir e models

ii. Other models to be added by future amendment to this exemption.3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by use

of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g.,

powerline inspections) and due to other dangerous activities that can be avoided

(e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and

the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions

from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered an d marked in accordance with Section 44711 and Part 47 and

Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer.

All repair and maintenance work will be conducted or approved by qualified personne l

such as those authorized by Robotic Skies (or equivalent), and will require a test flight

after such work. Records of all maintenance and repair work will be kept in a

maintenance log for each aircraft.

c. All flight operations will be conducted b y two individuals who will maintain verbal

communication capability with each other at all times during the flight, and who will

remain stationary on the ground during the flight operations:

i. A Pilot In Command who possess the following credentials:

1. 

### SPORT PILOT (or greater) certificate.

2. Maintains a valid Drivers License

3. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft

(or UAS fixed

- wing in the case of fixed

- wing flight operations under this

exemption). Such cycles and hours may be gained during flights under

this exemption if a safe distance is maintained from persons in

accordance with 14 CFR 91.119.

4. At least 5 hours of flight experience and 3 takeoffs and landings in make

and model being flown in the prior 90 days. Such cycles and hours may

be gained du ring flights under this exemption if a safe distance is

maintained from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer.

d. All flight operations will be conducted in accordance with a valid COA

e. All flight operations will comply with the following:

i. The manufacturers' Aircraft Flight Manuals and operation guidelines



### ii. Enterprise Integrations flight operations policies including lost communication and other

emergency and safety procedures.



### iii. Conducted in VMC conditions during daylight hours

iv. PIC and VO will maintain VLOS at all times.

v. Pre

- flight inspections (including ground control station, if any) and safety risk

assessments will be conducted prior to each flight

vi. Flight altitudes will remain below 400 feet above ground level

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into Class B, CorD airspace, or published approach, SID or STAR, or

take place within 5 miles of an airport



### ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on

the ground without their prior permission

x. Each flight will be logged in both the PIC's logbook and the aircraft logbook

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes,

whichever occurs first.

xii . Any incidents will be reported within 24 hours of occurrence.

xiii. Hawk Aerial will maintain liability insurance of at least $1,000,000 issued by

a licensed insurer.

xiv. Any applicable local FSDO requirements.

xv. All other applicable regulati ons concerned with the operation of aircraft.

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data.

### Please advise us of any additional information or changes that are required.

Director of Media, Enterprise Integration