1

October 1, 2015 U.S. Department of Transportation Docket Operations, M
- 30 1200 New Jersey

Avenue, SE Room W12 - 140, West Building Ground Floor Washington, DC 20590
- 0001 Re: **Petition of USA Unmanned Aeronautical Systems Solutions Corporation for an Exemption Pursuant to Sect**  **ion 333 of the FAA Modernization and Reform Act of 2012 to Operate Unmanned Aircraft Systems for Aerial Data Collection, sUAS Flight Training, Aerial**  **Photography and Videography, Support News Services, Real Estate Photography and Videography, Construction, Waterway and Land Planning and use of Agriculture, Education,**  **Oil and Gas Industry Infrastructure Inspection and Demonstration Flights.** Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C. F.R. Part 11, USA Unmanned Aeronautical Sy stems Solutions Corporation. (“U2 SOLUT IONS ”) hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJ I Insp ire 1 (“Inspire”), the DJ I Spreading Wings S - 1000 (“Spreading Wings”), the DJ I Spreading Wings S
- 900 (“Spreading Wings”), the DJ I Phantom 2 (“Phantom 2”), the DJIPhantom 3 (“Phantom 3 ”) , the 3DR Aero
M (“Aero
- M”), the 3DR Solo (“Solo”), and the Precision Hawk Lancaster (:Lancaster”) unmanned aircraft s ys tems for aerial data collection, sUAS flight training, aerial photography and videograph y, support news services, real estate photograph y and videograph y, construction, waterway and land planning and use of agriculture, education, oil and gas industry infrastructure inspection and demonstration flights. U2 SOLUT IONS requests that the FAA review this petition pursuant to its “summary grant” process as the FAA has alread y granted exemptions similar in all mat erial respects to this petition. See FAA Grant of Exception Nos. 11062, 11109, 11112, and 11213. The reasons stated by the FAA in granting the exemptions listed above also appl y to this petition, and the grant of this petition is in the public interest. **I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED**  U2 SOLUT IONS requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a) ;2

 14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  14 C.F.R § 91.103;  14 C.F.R § 91.109(a);  14 C.F.R § 91.119;  14 C.F.R § 91.121;  14 C.F.R § 91.151(a) & (b)  14 C.F.R § 91.203 (a) & (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 § 91.417 (a) & (b). This petition incorporates the material contained in the User Manuals for Inspire, the Spreading Wings, the Phantom 2&3, the Aero, the Solo and the Lancaster (together, the “Manuals”). **II. STATUTORY**  **AUTHORITY FOR REQUESTED EXEMPTIONS** This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspa ce sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft s ys tem (“UAS”) where it does not create a hazard to users of the national airspace s ystem (“NAS”) or the public or pose a threat to national securit y based on the following considerations:

 The size, weight, speed and operational capability ;  Operation in proximity

to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency ’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 4470 1 - 44716, et seq. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safet y or how it would provide a level of safet y at least equal to the exist ing rules. 14 C.F.R. § 11.81. **III. DESCRIPTION OF U2**  **SOLUTIONS AND ITS SERVICES** U2 SOLUT IONS provides aerial data capture and imaging services , as well as, sUAS flight training, aerial photography and videograph y, support news services, construction waterway inspections and land planning, education, and demonstration flights for a variety of industries including engineering, infrastructure, energy , agriculture, real estate, sport s, wild life, and insurance. U2 SOLUTIONS is headquartered in DeMotte, Indiana.3

Nicholas Van Houten, CEO USA Unmanned Aeronautical Sy stems Solutions Corporation 9729 North Bunker Hill Road Demotte, IN 46310 Tel (219) 345
- 2413 **IV. DESCRIPTION OF PROPOSED OPERATIONS**  U2 SOLUT IONS is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to perform aerial data capture and imaging services for a variet y of industries including sUAS flight training, aerial photography and videograph y, support news services, construction waterway inspections and land planning, education, and demonstration flights engineering, infrastructure, energy , agriculture, real estate, sports, wild life, and insurance. These t ypes of service s are ty picall y performed by helicopter or fixed wing aircraft. Use of a UAS will reduce safet y risks because the UAS will not carry flammable fuel or a pilot, and UAS operations can be performed at considerable savings. The UAS will also allow for better imagery than can be produced b y using a helicopter or fixed wing aircraft. **A. Aircraft to be Operated**  **1. DJI Inspire 1**  U2 SOLUT IONS will use the Inspire as one of the aircraft to provide its services. The FAA has alread y approved the Inspire for commercial us e in FAA Exemption No. 11679 (FAA Docket No. FAA - 2015 - 0706). The Inspire is shown in Figure 1 below.

**Figure 1**
**– DJI Inspire 1** 4

The Inspire is more fully

described in the Inspire User Manual. **2. DJI Spreading Wings S**  **- 900**  U2 SOLUT IONS will use the Spreading Wings as one of the aircraft to provide its services. The FAA has alread y approved the Spreading Wings for commercial use in FAA Exemption No. 11521 (FAA Docket No. FAA
- 2014 - 0947). The Spreading Wings is shown in Figure 2 below.

**Figu re 2** 
**– DJI Spreading Wings S**  **- 900**  The Spreading Wings is more fully described in the Spreading Wings User Manual. **3. DJI Spreading Wings S**  **- 1000**  U2 SOLUT IONS will use the Spreading Wings as one of the aircraft to provide its services. The FAA has alread y approved the Spreading Wings for commercial use in FAA Exemption No. 11521 (FAA Docket No. FAA
- 2014 - 0947). The Spre ading Wings is shown in Figure 3 below.5 **Figure 3**
**– DJI Spreading Wings S**  **- 1000**  The Spreading Wings is more fully described in the Spreading Wings User Manual. **4. DJI Phantom 2**  U2 SOLUT IONS will use the Phantom 2 as one of the aircraft to provide its services. The FAA has alread y approve d the Phantom 3 for commercial use in FAA Exemption No. 11696 (FAA Docket N o. FAA - 2015 - 0746). The Phantom 2 is shown in Figure 4 below.6 **Figure 4**
**– DJI Phantom 2**  The Phantom 2 is more fully described in the Phantom 2 User Manual. **5. DJI Phantom 3**  U2 SOLUT IONS will use the Phantom 3 as one of the aircraft to provide its services. The FAA has alread y approved the Phantom 3 for commercial use in FAA Exemption No. 11696 (FAA Docket No. FAA
- 2015 - 0746). Th e Phantom 3 is shown in Figure 5 below.7 **Figure 5** 
**– DJI Phantom 3**  The Phantom 3 is more fully described in the Phantom 3 User Manual. **6. 3DR**  **Aero -**  **M** U2 SOLUT IONS will use the 3DR Aero
- M as one of the aircraft to provide its services. The FAA ha s already

approved the Aero
- M for commercia l use in FAA Exemption No. 12842 (FAA Docket No. FAA
- 2015 - 2091 ). Th e Aero - M is shown in Figure 6 below.8 **Figure 6**
**– 3DR Aero**  **-**

**M** The Aero
- M is more fully described in the Aero
- M User Manual. **7. 3DR Solo**  U2 S OLUT IONS will use the 3DR Solo as one of the aircraft to provide its services. The FAA ha s alread y approved the Solo for commercial use in FAA Exemption No. 12842 (FAA Docket No. FAA - 2015 - 2091). Th e Solo is shown in Figure 7 below.9 **Figure 7**
**– 3DR Solo**  The Solo is more fully described in the Solo User Manual.

**8. PrecisionHawk Lancaster**  U2 S OLUT IONS will use the PrecisionHawk Lancaster as one of the aircraft to provide its services. The FAA ha s already approved the Lancaster for commercial use in FAA Exemption No. 12842 (FAA Doc ket No. FAA
- 2015 - 2091). Th e Lancaster is shown in Figure 8 below.10 **Figure 8**
**– PrecisionHawk Lancaster**  The Lancaster is more fully described in the Lancaster User Manual. **B. U2 SOLUTIONS’S Proposed Operations Demonstrate an Equivalent Level**  **of Safety 1.**  **General Description of Proposed Flight Operations** U2 SOLUT IONS proposes to operate within the limitations and performance specifications listed in this application and in the Manuals. These limitations provide for at least an equivalent, or higher, level of safet y for operations under the current regulatory structure because the proposed operations are safer than conventional operations using helicopters or fixed wing aircraft which carry

an operator and flammable fuel. The proposed flight operations are similar in all material respects to operations already approved by the FAA and are therefore subject to the FAA’s “summary

grant” process. The proposed operations do not create an y hazard to users of the national airspace s ys tem or pose a threat to nation al security . The aircraft are battery operated which will not be flown with less than 25 percent battery

life. The vehicles weigh less than 55 pounds. The vehicles will be operated at or below 400 feet AGL within the visual line of si ght of the pilot in co mmand. U2 SOLUT IONS’s operations will be over private or controlled access property with the permission of the owner/ controller or authorized agent. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The propose d UAS carry

no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the UAS being operated b y the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditio ns, and design safet y features. The petitioner’s aircraft have the capability to operate safel y after experiencing certain inflight failures, as specified in the Manuals. The aircraft are als o able to respond to a lost
- link event with a pre
- coordinated, predictable, automated flight maneuver.

**2 .**  **Specific Limitations on Proposed Flight Operations** Given the small size involved, the restricted environment within which they will operate, the p rocedures listed below, and pilot certification requirements, UAV SOLUTIONS’s proposed operations would “not create a hazard to users of the national airspace s ys tem or the public or pose a threat to national securit y.” Reform Act Section 333(b)(1). 1. The aircraft weigh less than 55 pounds11

2. Each aircraft will be identified by serial number, registered with the FAA, and have identification (N
- Number) markings as large as practicable. 3. Flights will be operated within visual line of sight of the pilot in comm and (PI C). 4. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy

by PIC. 5. The PI C will ensure that before each flight, there is enough available power for the UAS to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 6. The aircraft will be operated during daylight and in VFR conditions. 7. Flights will not exceed 400 feet AGL. 8. Flights will be operated at a lateral distance of at least 500 feet from an y persons or propert y not a ssociated with the operation who have not given prior permission. 9. Flights will be limited to a groundspeed of 100 mph. 10. Minimum crew for each flight will consist of a PIC and an Obser ver. 11. The PI C will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PI C will also hold a current FAA airman medical certificate or a valid driver’s license issued b y a state or the Federal Government. The PI C will also meet the flight review requirements specified in 14 CFR § 61.56. 12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 13. The flight operations will yield the right of way to other manned aircraft operations. 14. All persons who are not involved with U2 Solutions’ operations will be required to be at least 500 feet from flight operations. 15. The aircraft will onl y operate over private or controlled access property with the permission of the owner/controller or authorized representatives.12

16. The UAS will not operate within 5 nautical miles of an airport unless a letter of agreement is obtained. 17. All required permission and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 18. Prior to commencing operations, if needed to operate above 200 feet, U2 Solutions will obtain a Certificate of Waiver or Authorization (COA) from the FAA. 19. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land. 20. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 21. The flight will be aborted in case of unpredicted obstacles or emergencies. 22. UAS operations will be conducted within the parameters of the Manuals.
**3. Flight Recovery, Lost Communications, and Lost GPS Procedures**  The flight recovery , lost communications, and lost GPS procedures are more full y documented in the attached Manuals. **V. SPECIFIC FAR EXEMPTIONS REQUESTED**  U2 SOLUT IONS seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the request ed operations. L isted below are (1) the specific FAR sections for which exemption is sought, and (2) the operating pr ocedures and safeguards that U2 SOLUTIONS has established which will ensure a level of safet y better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

**A. 14 C.F.R. Part 21, Subpart H** 
**– Airworthiness Certificates and 14**  **C.F.R. § 91.203(a)(1)** The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normall y used for the same application. These criteria are met with this petition, and therefore no exemption is needed. See Grant of Exemption No. 11062, Doc ket No. FAA 2014
-13

0352 at 13 - 14, 22. If, however, the FAA determines that there are some characteristics of the UASs that fail to meet the requirements of the Reform Act, an exemption is requested. **Equivalent Level of Safety** : The UASs are safe when taking into account their size, weight, speed, and operational capability . They weigh less than 55 pounds and will be flown at speeds less than 100 miles per hour, and in visual line of sight of the operator. The UASs do not carry pilots, passengers, explosive m aterials, or flammable liquid fuels. The UASs will be operated within the parameters of their respective Manuals. The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or fixed wing aircraft operating with an airworthiness certificate without the restrictions and conditions proposed here. **B. 14 C.F.R. Part 27 Airworthiness Standard**  **s: Normal Category**

**Rotorcraft** 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the UASs would otherwise require certification under Part 27, U2 SOLUT IONS seeks an exempti on from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and**  **Identification Requirements** 14 C.F.R. §45.23(b), M arkings of the Aircraft states: When marks include only the Roman capital letter “N” and the registration number is display ed 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 less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light
- sport, “experimental,” or “provisional,” as applicable. 14 C.F.R. § 45.27(a) states: **Rotorcraft** . Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. 14 C.F.R. § 91.9(c) states: No person may

operate a U.S. - registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identif ication (N
- Number) markings in14

accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14. **Equivalent Level of Safety:** U2 SOLUTIONS will mark all UASs with their N
- Number in a prominent spot on the fuselage with markings that are as large as practicable.

**D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations**  U2 SOLUT IONS seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of an y P IC matches the airspace in which the PIC will be operating, as well as requiring certifications if the pilot is carryi ng passengers or cargo for hire. While the UAS will be operated as part of a commercial operation, they carry neither passengers nor c argo. In the Grant of Exemption in FAA Docket No. FAA
- 2014 - 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to hav e a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The FAA has also granted exemptions allowing ope rations b y people who hold an airline transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. The PI C must also mee t the flight review requirements specified in 14 CFR § 61.56. See FAA Exemption No. 11374. U2 SOLUT IONS will ensure the PI C will meet the requirements li sted in the above paragraph. U2 SOLUT IONS will also ensure the PIC will have completed the manufacture rs’ training guidelines outlined in the Manuals. The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS
- specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. FAA 2014 - 0352, at p. 18. The proposed operations can achieve an equivalent level of safet y b y requiring the knowledge and experience in the UAS operations described above. The restrictions U2 SOLUTIONS has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial in FAA Docket No. FAA
- 2014 - 0352 and those listed in the FAA’s “summary grant” process. **E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness**  U2 SOLUT IONS seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. The FAA has stated that no exemption is15

required to the extent that the requirements of Part 21 are waived or foun d inapp licable. Accordingl y, U2 SOLUTIONS requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14**  **C.F.R . §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and**  **Registration** Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may

operate a U.S. - registered civil aircraft

–

... (2) For which an Airplane or Rotorcraft Flight Manual is 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 an y combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as pr ovided 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 issued under § 91.715 is display ed at the cabin or cockpit entrance so that it is legible to passengers or crew. U2 SOLUT IONS does not request an exemption from this section but instead notifies the FAA th at, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PI C during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19 - 20, and Grant of Exemption No. 8607.

**G. 14 C.F.R. § 91.103: Preflight Action**  U2 SOLUT IONS seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA - approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Under these circumstances, the FAA has stated that n o exemption is required. See Grant of Exemption16

No. 11062, p. 20. An exemption is requested to the extent that an FAA
- approved Flight Manual is required. **Equivalent Level of Safety** : An equivalent level of safet y will be provided by following the Manuals. The PIC will take all required preflight actions
- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas
- before init iation of flight. The Manuals will be kept at the ground station with the operator at all times.

**H. 14 C.F.R. § 91.109(a): Flight Instruction**  U2 SOLUT IONS seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 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.” UASs and remotely piloted aircraft, b y their design, do not have functional dual controls. Instead, flight control is accomplished through the use of the Ground Control Station (GCS) that communicates with the air craft via radio communications. **Equivalent Lev el of Safety**  : When flight instruction is performed, no pilots will be on board the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of the UAS, an equivalent level of safe tra ining can still be achieved without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. In addition, U2 SO LU TIONS will conduct flight training at a remote facility away from population centers. These training flights will comply with the provisions in the Manuals. Accordingly, U2 SOLUTIONS’s proposed method of operation provides superior levels of safety
.

**I. 14**  **C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas** U2 SOLUT IONS requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. The Manuals provi de for U2 SOLUTIONS operations at least 500 feet from persons and structures not involved in the operations. The FAA has alread y determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by U2 SOLUTIONS. See Grant of Exemption No. 11062, p. 20
- 21. **Equivalent Level of Safety:** Compared to flight operations with rotorcraft or fixed wing aircraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, an y risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given th e size, weight, and speed of the UAS, as well as the locations where it is operated. In order to avoid any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft are already prohibited from operating closer th an 500 from structures where U2 SOLUTIONS proses to operate. This is airspace where other aircraft do not normally operate. As set forth in the Manuals17

and herein, the UAS will be operated in the remote sites, away from persons or structures not involved in the operation. All perso ns who are not involved with U2 SOLUTI ONS’ operations will be required to be at least 500 feet from flight operations. This will pose no risk to the public because other aircraft are not operating in these areas.

**J. 14 C.F.R. § 91.121: Al**  **timeter Settings** This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport. The UASs proposed here use both barometric pressure sensors and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that the UAS does not have a barometric altimeter setting. The a ltitude of the UAS is monitored by the PIC on the ground control stat ion and by the visual observer. **Equivalent Level of Safety** : The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual line
- of
- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20
- 21. As the attached Manuals indicate, the UAS will be operated at or below 400 feet AGL and othe rwise compl y with the limitations in the Grant of Exemption No. 11062. **K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR** 

**Conditions** U2 SOLUT IONS requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. S ection 91.151 states: (a) 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) Duri ng the day , to fl y after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes Here, the technological limitations on the UAS battery power means that no meaningful flight operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery powered with a maximum, in which, operations will not be flown with a battery at 25 percent or less . The PI C will ensure that before each flight, there is enough available power for the UAS to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safet y is provided if the UAS flight is conducte d under day time VFR flight conditions using VLOS, and terminated18

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21
- 22. The FAA’s “summary grant” process provides that the PI C is prohibited from beginning a fli ght unless there is enough available power to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. See FAA Exemption No. 11374 (FAA Docket No. 2015
- 0091 at p. 5). The limitations here provide that the PI C will ensure that before each flight, there is enough available power for the UAS to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended b y the manufacturer if greater.

**L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b):**  **Maintenance Inspections** U2 SOLUT IONS seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91 .409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as pr escribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only appl y to aircraft wi th an airworthiness certificate, which the UAS proposed here will not have. **Equivalent Level of Safety:** An equivalent level of safet y will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, and preflight inspection requirements. See Exemption No. 11062 (FAA Docket No. 2014
- 0352, at p. 14 - 15) and Exemption No. 11374 (FAA Doc ket No. 2015
- 0091, at p. 4). U2 SOLUT IONS will follow the UAS manufacturer’s maintenance requirements. Flights will not be conducted unless a flight operations checklist is performed that includes all of the aircraft’s components. **VI. PUBLIC INTEREST**  Granting U2 SOLUTIONS’s petition for exemption furthers the public interest. National policy se t by Congress favors early

integration of UAS into the NAS in controlled, safe working environments such as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform A ct. Moreover, use of UAS will promote the efficient use of resources. The use of the UAS propped here will also decrease safety
- related incidents involving traditional aircraft. The public has an interest in promoting science and technology education and in reducing the hazards and emissions associated with alternate use of helicopters and small airplanes to conduct similar operations.19

**VII. PRIVACY**  All flights will occur over private or controlled access property with the owner’s consent. All flights will be conducted in accordance with any federal, state or local laws regarding privacy
. **VIII. SUMMARY FOR FEDERAL REGISTER**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for p ublication in the Federal Register, should it be determi ned that publication is needed: U2 SOLUT IONS seeks an exemption from the following rules for aeronautical and UAS training and education of middle and high school students: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C .F.R § 91.203 (a) & (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 § 91.417 (a) & (b). The exemption will promote science and technology education and training while enhancing safet y b y reducing risk to the operator, the general public and propert y owners from the substantial hazards associated with performing equivalent training and education using traditional conventional aircraft and rotorcraft. U2 SOLUT IONS requests that the FAA grant this petition using the “summary grant” process such that publication in the Federal Register is not required. This petition would not set a precedent, and an y delay

in acting on this petition would be detrimental to the petitioner. **IX. ATTACHMENTS**  Available online at https://www.dji.com/products Atta chment 1: Inspire 1 User Manual Attachment 2: Spr eading Wings S
- 900 User Manual Attachment 3: Spreading Wings S
- 1000 User Manual Atta chment 4: Phantom 2 User Manual Attachment 5 : Phantom 3 User Manual Available online at: https://3drobotics.com/kb/aero
- m Atta chment 6: Aero - M User Manual Available online at https://3drobotics.com/kb/solo Attachment 7 : Solo User Manual20

Available online at https://www.precisionhawk.com Attachment 8 : Lancaster User Manual If you have an y questions or require an y additional inf ormation, please do not hesitate to contact the CEO of USA Unmanned Aeronautical Sy stems Solutions Corporation
. **X. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act
- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security considerations
- provides more than adequate justification for the grant of the re quested exemptions to permit U2 SOLUTIONS to operate the UASs proposed here. Furthe rmore, this petition warrants review by the FAA under the “summary grant” process for immediate approval. Respectfully submitted, Nicholas Van Houten CEO of U2 SOLUTIONS
.