proneAmerica, Inc

. 'Federal Aviation Regulationsfor Exemption



# DRONE AMERICA

April 8, 2016 DocketOperations, M-30 U.S. DepartmentofTransportation (DOT) 1200 NewJerseyAvenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 RE: Section 333 Petition for Exemption Towhom it may concern: Drone America, Inc. petitions for relief of specific regulations with regards to airworthiness certification under Section 333, 14 CFR 11.81. The proposed request for exemption would allow for the use and operation of Unmanned Aircraft Systems (UAS) within the National Airspace System (NAS) for emergency response. The proposed applications are assisting emergency personnel, protecting them from hazardous conditions and bodily harm, and providing a communications relay

. In the event of national or local emergencies it may be deemed necessary for unmanned aircraft operations. Drone America requests thatthe FAA approve an exemption based on a specific platform size, weight, speed and limited operating range. Our request for exemption is based on public safety and integration to supportfirefighting, disaster relief, search and rescue, law enforcement, crew training and to participate in research of various National Aeronautics and Space Administration (NASA) and National Oceanic and Atmospheric Administration (NOAA) environmental studies. Inthe interest of public safety and research, the FAA has alreadyauthorized emergency service agencies limited use of unmanned aircraft forcritical operations. Operational control would remain within Drone America's Emergency Services Division in which "due regard" for rules, regulations and operational procedures will 

### beadhered to. The platform in consideration for Section 333 E xemption is Drone America's S a

vant. This is a multi-use fixedwing aircraft with potential applications in agriculture, search and rescue, mapping, mining, fire monitoring, communications, and others still in development.

Drone America, Inc

.2016 Section 333 E xemption for UAS Operations 1DroneAm~rica, Inc. Federal Aviation Regulationsfor Exemption

Kyle Pruett - Engineering Manager DroneAmerica, Inc. 3555 Airway Drive Suite 310 Reno, NV 89511 775-473-9998 

### I 775-232-8650 www.DroneAmerica.com

Drone America, Inc. 2016 Section 333 Exemption for UAS Operations 

### Savant

2DroneAmerica, Inc. FederalAviation Regulationsfor Exemption


# SECTION 333 PETITION FOR EXEMPTION DroneAmerica requestsexemptionfromthefollowing regulations: PART 21THAT DESCRIBESPROCEDURAL REQUIREMENTS FORTHE COMPLIANCE OF:
• Subpart G; Production Certificates • Subpart H; Airworthiness Certificates • Subpart I; Provisional Airworthiness Certificates • Subpart K; Parts ManufacturerApproval • Subpart L; ExportAirworthiness Approvals • Subpart N; Acceptance ofAircraft Engines, Propellers and articles for Import • Subpart O; Technical Standard OrderApprovals • Subpart P; Lavatory Oxygen Systems PART45THAT REQUIRESIDENTIFICATION AND REGISTRATION MARKINGS: Due to platform size and airframe configuration, 2" regulation markings will not

### fit in accordance with Part 45.11. Request for modification to comply with only Part 45

.13 fire proof identification plate located on the inside ofthe platform. The Savant is an unmanned aircraft and cannot meetthe requirements for display of markings ofthis size, nordoesthe Savant have a doororcabin todisplay theword "Experimental". PART61.113 PRIVATE PILOT PRIVILEGESAND LIMITATIONS: a) Except as provided in paragraphs (b) through (h), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passenger or property for compensation or hire; nor maythat person, for compensation or hire, actas pilot in command. b) A private pilot may, for compensation or hire, act as pilot in command of aircraft in connection with any business oremployment if: 1) The flight is only incidental tothat business oremployment; and 2) The aircraftdoes notcarry passengers or propertyforcompensation or hire

. Drone America requests exemption from requiring a private pilot license because the aircraft size, weight, speed, and limited operational range do not necessarily require a private pilot license to operate. The aircraft will be operated within a horizontal visual line ofsight (VLOS) from the surface not to exceed 400 feet AGL. Operations are conducted from a handheld tablet or laptop computer with auto takeoff and landing capabilities. Operators are required to complete a pilot training course and hold either aThird Class Medical Certificate or a state-issued driver's license. PART91.7 CIVILAIRCRAFTAIRWORTHINESS: a) No person may operate a civil aircraft unless it is in airworthy condition. b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, orstructural conditions occur.
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. Federal Aviation Regulationsfor Exemption

Drone America's aircraft vehicle operators (AVO's) are responsible for the inspection and safe operation ofthe aircraft. Aircraft will be inspected priorto each flight and maintenance performed as necessary to ensure flight safety. Should the condition ofsafe flight not be met, resolved or repaired the flight will be terminated until discrepancies are corrected. See Section 11 - Savant Preflight and Checklist. PART 91.9 CIVILAIRCRAFT FLIGHT MANU AL, MARKING AND PLACARD REQUIREMENTS: a) No person may operate a civil aircraft without complying with theoperating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings and placards, or as otherwise prescribed bythecertificating authorityofthe:county of registry

. A flight manual with operating limitations and placards will be immediately accessible to the AVO during flightas prescribed. · PART 91.107 USE OF SAFETYBELTS, SHOULDER HARNESSESAND CHILD RESTRAINTS: Part 91.107 Subpart Bis notapplicableto Unmanned Aircraft. PART 91.119 M INIMUM SAFE ALTITUDES: Drone America requests exemption from minimum safe altitude regulations

. Operations will be performed between 

### Oand 400 feetAGL. PART91.203CIVILAIRCRAFT: CERTIFICATIONS REQUIRED: Drone America requests exemption from Part 91.203 because the Savant is Experimental and does not require airworthiness certification based on size, weight, speed, and limited operating range. The Savant does not carryfuel or passengers. PART91.405 MAINTENANCE REQUIRED: Each owner or operatorofan 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) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

. Drone America requests exemption from Part 91.405 (a) on the basis ofthe size, weight, speed and limited range ofthis unmanned aircraft. Drone America's aircraft vehicle operators (AVO's) will be responsible for the inspection and safe operation of the aircraft

. The aircraft will be inspected prior to each flight and maintenance performed as necessary to ensure flight safety

. 

### Ifa condition is identified, and cannot be resolved or repaired, the flight will be terminated until discrepancies arecorrected. PART 91.407 OPERATIONS AFTER MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, OR ALTERATION:

a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, oralteration unless - 1) 

### It has been approved for return to service by a person authorized under 43.7 of this chapter Drone America requests exemption from Part 91.407 (1) on the basis that Drone America is the sole operator. The Savant is considered Experimental and the AVO is responsible for all maintenance, preventive maintenance, rebuilding and/oralterations.
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### PART 91.409 INSPECTIONS: 

### a) No person may operate an aircraft unless, within the preceding 12 calendar months - 2) It 

### has had an inspection for the issuance of an airworthiness certificate in accordance with Part 21 ofthis chapter. Inspections and preventive maintenance is performed prior to each flight, therefore, Drone America requests exemption from Part 91.409 (a) (2). PART 91.417 MAINTENANCE RECORDS: 

### a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section:

Drone America, Inc. 2016 

### 1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (Including the airframe) and each engine, propeller, rotor and appliance ofan aircraft. The records must include: i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and ii) The dateofcompletion ofthe work performed; and iii) The signature and certificate number ofthe person approving the aircraft for return to service. 2) Records containing thefollowing information: i) The total time in service of the airframe, each engine, each propeller and each rotor. ii) The current status of life-limited parts of each airframe, engine, propeller, rotor and appliance

. iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis

. iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained

. v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. 

### Ifthe AD or safety directive involves recurring action, the time and datewhen the nextaction is required

. vi) Copies of the forms prescribed by 43

.9(d) of this chapter for each major alteration tothe airframe and currently installed engines, rotors, propellers, and appliances

.

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b) The owneroroperator shall retain the following records forthe periods prescribed: 1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated orsuperseded by otherwork, orfor 1year afterthework is performed. 2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the aircraftatthetimethe aircraft is sold. 3) A list ofdefects furnished to a registered owner, oroperator under 43

.11 ofthis chapter shall be retained until the defects ar~ repaired and the aircraft is approved for return to service. Drone America requests exemption from Part 91.4'17

.The Savant is considered Experimental and the AVO is responsible for all maintenance, preventive maintenance, rebuilding and/oralterations

.There are no serial numbers for replaceable parts, so there would be nowaytotracktheir maintenance. If a part is notfunctioning correctly, itwill be replaced

.

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# UMANNANED AIRCRAFTSYSTEM OPERATIONS 1. 

## OPERATIONALAND DESIGN CHARACTERISTICS: The Savant is a fixed
-wing aircraft made of light-weightcomposite materials. 

### It is intended for speeds between 30 mph and 85 mph and under normal flight conditions has a flight endurance of up to two hours. This small, fixed-wing aircraft is designed forcommercial, industrial, and ISR applications

. The advanced software and GPS guidance system provide the aircraft with self-stabilizing capability and multi-waypoint navigation. The Savant is powered by an electric brushless motor that produces highlevel performance and thrust. The aircraft is intended to carry payloads such as atmospheric sensors, surveying sensors, mapping equipment, and high d~finition stabilized video and data links. Based on other flight experience with similar platforms, flight data has not presented any unsafe conditions thatwould cause concern for safety while conducting flight under normal conditions. 

## 2. INTENDED PROCEDURE IMPLEMENTATIONS Preflight Inspection-Airframe:
• Assess airframe foranydamage during transportation • Inspect propeller • Verifythat motorturns freely and bearings are smooth and quiet • Inspectwiring harness forwear, chafing, and all connections are tight • Check link antenna and mountfortightness • Checkflight control servos for smooth operation • Check control linkages are secure • Checkfor Foreign Object Debris (FOD) in the payload compartment/battery compartment • Checkthat payload cover plate and any payload installed are secure • Installfresh batteryand secure with straps • Plug battery into battery terminal • Install hatches and secure • Check wing and stabilizer attachments are secure • Check parachute for proper packing, notangled lines, hatch releases freely • Inspect launch lugsfor damage • Inspect landing skids 

### PreflightInspection- GCS:
• Check and record initial batteryvoltage and current • Verify maps page as required forthe mission • Verify and/or load flight plans • Verify mission limits including dead man status and lostcom waypoint • Verify working aircraft GPS, check the number ofsatellites (7 or more is needed) and Percent Deterioration of Position (POOP) is less than 3% • Control altitude to GPS • Select manual control and verify manual control indicated is autopilot page (Ifusing EP) • Verify control surface trims in manual mode, adjust using pilotconsole (If using EP) • Verify manual control (Ifusing EP)
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• Checkthe correct operation ofthegyros and accelerometers by physically rotating the aircraft and verifying the sensor outputs • Configure the autopilot loops as needed (typically all auto) with the waypoint set for the launch plan • Check communications atthe farend ofthe runway strip. RSSI signal should indicate close to the minimum reading of-71dBm (average is around -25) • Checkforaircraft trafficand make any radio calls mandated by airtrafficcontrol • Final check on the system: Battery voltage, GPS health, RSSI, and sensors • Launch! Post FlightInspection:
• Disconnect battery • Unplug ground station radio • Shut offtransmitter (ifapplicable) • Complete logbookentries and record battery use information • Inspectfor any loose bolts/connectors/wiresand note • Inspectairframe and propellerforany damage and note (replace ifnecessary) • Inspect launch lugs • Inspect landing skids • Plan to discharge all unused batteries to storage level (follow all battery and charger instructions) Maintenanceand Repairs: Drone America's aircraft vehicle operators (AVO's) will be responsible for the inspection and safe operation of the aircraft. The aircraft will be inspected prior to each flight and maintenance performed as necessary to ensure flight safety. Ifa condition is identified, and cannot be resolved or repaired, theflightwill be terminated until discrepancies are corrected. 

## 3. COMMUNICATIONAND FREQUENCIES: C2 Link The Savant uses Microhard Digital Data Link (DDL) radios as a standard, which are directly integrated with the Cloudcap Piccolo autopilot system. The 2.4GHz band is used on the Savant, but all options listed in the table below are interchangeable with no further modification to the aircraft or any onboard systems. 

## • FCC IDforthe current IPnDDL2450 : NS9NBG30 Model P/N GHz IPnDDL900 MHS116400 900 MHz IPnDDL2350 MHS116000 2.304-2.364 IPnDDL2450 MHS116100 2.405-2.470 IPnDDL3400 MHS116200 3.300-3.500 IPnDDL5800 MHS116300 5.000-5.800

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### Camerasand Sensors The savant is payload agnostic and will be capable of carrying a variety of standard and customer supplied sensors/payloads. Typical sensors will be provided by UTC aerospace (Cloudcap Technologies) which include the TASE series of gimbal cameras. Trillium Engineering is another supplier ofgimbal cameras that may be used. Custom sensors are assembled using high end cameras from FLIR, Sony, and other manufacturers. All sensors are separated from the flight control system and are housed in a removable cartridge in the bottom ofthe aircraft

. These cartridges may or may not have an additional windows or Linux computer which handle all processing for the payload completely separatefrom theautopilot. Communications forthe payload will be chosen based upon the data rate required for the system and will vary with each installation. These will be either on separate frequencies from the C2 link, or will have differentencoding so thatthey do not cause interference with theC2 link. 

## 4. PILOT/CREW QUALIFICATIONS/TRAINING REFERENCE:
a. Airman Certificate: Drone America will require a minimum ofa Sport Pilot Certificatefor piloting the Savant. 

### b. Training: A pilot training course has been developed and is taught by a licensed FAA flight instructor employed by Drone America.


### c. Flight Hours: Drone America will not require a specific number of flight hours for a certified pilot. Ifthe training course is completed satisfactorily, that person is qualified to pilotthe Savant. 

### d. Visual Observers: All visual observers must pass training and have an understanding of proper communication and phrases, visual scan techniques, and standard flight operations at non-towered airports. Pilots who have observertraining may actas an observer when they are notacting as a pilot. 

## 5. MEDICAL STANDARDS FOR PIC: Drone America will require either a Third Class Medical Certificate ora State-issued Driver's license to pilotthe Savant. 

## 6. OPERATIONS
• Agriculture
- The Savant is capable of carrying both hyperspectral and multispectral cameras which can be used to derive valuable information about crops. Plant health, insect infestation, and overspray of pesticides can be detected and monitored via the Savant's sensors. Safety considerations in this environment include a detailed site recon which will map any obstacles in order to create a safe and effective flight plan.


### • Search and Rescue - The Savant can be used to carry both visual and IR cameras simultaneously. Onboard processing and live downlink of data from the onboard computer provides faster response times and more accurate searches under tight time constraints. The Savant has a high wind tolerance and moderate flight speed, which allow it to be deployed in situations that are not ideal forthe use of
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manned aircraft. Crew members deployed with Search and Rescue teams are trained both as pilots and first response personnel, allowing them tooperate safely and efficiently with the crews on theground.


### • Mapping
- The Savant can be configured with visual and IRcameras and LiDAR for use in mapping of hard to reach locations. 

### It is suited to powerline and pipeline surveying due to its long endurance and moderate flight speed

.These operations can provide data more quickly than sending manned crews on foot, and can also increase safety when the infrastructure is damaged by weather or natural disaster by preventing personnel from entering an unknown and dangerous situation

. 

### • Mining
- Faster and more detailed mapping can be conducted from lower altitudes with the Savant versus a manned aircraft. This increase in both speed and accuracy ofthe data collected can save cost and environmental impact in a mining application

. Analyses ofdata collected from the Savant can help to reduce pollutant output and can prevent w~rkers from coming into contact with dangerous chemicals in the eventofa disaster.


### • Fire Monitoring
- The Savant's ability to carry IR cameras and process data on the aircraft gives it the abilityto collect accurate real-time data which can be directly applied to monitoring a wild fire. This is beneficial in areas of steep terrain and heavy forest. The data collected can be shared with fire teams immediately, so thatthey can be more effective and can also help them choose safer exit routes as thefire progresses. 

### • Communications Relay - There are many situations where first responders of all types are cut off from communication with their other teams for long periods of time. Steep terrain can block signal from hand-held communications devices and cell service. The Savant can carry IP radios which actas a low altitude satellite to relay communications in real-time, restoring the line ofcontact. 

### 7. OPERATING SPECIFICATIONS:
a. Proposed Operating Parameters VFR rules will be applied in theoperation ofthe Savant. The Savant has a maximum operating speed of87kts. 

### It has a normal operating speed in the range of40 to 80kts. Maximum operational altitude is estimated at 18,000 feet, pending testing of the airframe. Under normal operations, the Savant will not be operated above 400 feet AGL without permission from the FAA and any other governing body in the flightoperations area. Standard operating altitudewill be 400 feet AGL or less. 

### b. Minimum FlightVisibilityand Distancefrom Clouds: Flight operations will be conducted in compliance with 14 CFR Part 91.155 Basic VFR Weather Minimums. Operations are generally 400' AGL and will be performed as stated in the Basic VFR Weather Minimum table. 

### c. Hazards: Operations will be conducted in day-light hours in VFR conditions at400'AGL, or less and within visual line of sight. These flight parameters present minimal meteorological hazards to the operations and will not be operated in icing conditions without prior permission from the FAA. 

## d. Safety Mitigations: Prior to flight, it is the responsibility of the pilot and observers to verify and monitor current and forecasted weather conditions. In the event the weather deteriorates, the flight will be terminated until adequate VFR conditions can be met per 14 CFR Part 91.155.

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## 8. OPERATIONSAREA: The areas of operations are within Washoe County and the FM approved Reno-Stead Airport UAS Test Site. Each of these areas range from rural unpopulated desert to sparsely populated areas to demonstrate emergency service proof of concept. The criterion for each area provides specific field training relative to local emergencies and disaster relief.
• Reno/Stead Airport
- The Reno-Stead Airport has been designated by the FM as a UAS test site range. The test facility area is 812 acres 2.2 miles north of the main active runways 8/26

. Runways 14/32 does have the capability to be closed by the airport authority during flight test operations. The airport authority will post an AWOS and a NOTAM broadcasting the date and times of Unmanned Aircraft testing and air operations for the Reno/Stead Airport. The Reno/Stead Airport is secured by perimeter fencing and therefore, restricts unauthmized activities of public access and/or events. The testarea is in a remote location 1.8 miles northeast ofa housing subdivision.
• Verdi Mountain Training Center
- Is located in the Mount Rose Wilderness Area at an elevation of 7,500' MSL. This operation area is 5 square miles with no structures or population within 6 miles ofa population center. The purpose for this location provides UAS search and rescue training and implementation.
• Washoe County Desert Training Center
- This location is an isolated part of Northern Nevada in Washoe County. The operations area is 10 miles square and 10 miles from the nearest establishment. Operations will be conducted from Black Rock Airport (3,904' MSL), which is a private airstrip that has no structures in the middle of the Black Rock Playa. The purpose of location is to provide UAS emergency service training to law enforcement in the Northern Nevada and medical relief exercises. The operations area underlies the Reno Military Operation Area (MOA). The Reno MOA's floor is 13,000' MSL. Emergency operations training will not exceed 4,500' MSL and will be conducted in day light hours under VFR conditions. De-confliction ofthe airspace does not presenta problem since the Savant power supply will be depleted priorto UA reaching altitudes of 13,000'; therefore thisalleviates potential cause of hazardous situations.
• Reno Radio Control Club (RRCC)
- As an AMA sanctioned RC flying field, this site is designated as a safe location to fly radio controlled model aircraft and UAVs

. The RRCC field is located 11 nautical miles from the Mustang (FMG) VOR, on the 317 Radial, and is also 6.4 nautical miles ENE of Reno/Stead Airport. Field elevation is 5020 feet MSL. Operations up to 400 feet AGL are permitted in accordance with the rules ofthe Academy of Model Aeronautics (AMA). The purpose ofthis location is to provide a safe area for testing of new configurations including sensor/payload modifications, and airframe enhancements. Drone America will file a NOTAM prior to operations at the RRCC club field. The RRCC field is secured by perimeter fencing and therefore, restricts unauthorized activities of public access and/orevents.
• Hawthorne Airport and Army Depot - Hawthorne is located East and South of Reno, NV along Highway 95. 

### It is isolated in a valley between high mountains, with Hawthorne Lake to the North and provides a location for harsh weather testing. The facility is operated by the Hawthorne Army Depot, and airspace will be coordinated through that government entity and the FM. Drone America will post an AWOS and a NOTAM broadcasting the date and times of Unmanned Aircraft testing and air operations for the Hawthorne Airport. The Hawthorne Airport is secured by perimeter fencing and therefore, restricts unauthorized activities of public access and/or events.
• Tiger Field Airport
- This airport is located on highway 95 in Fernley, NV. 

### It is rarely used, and has minimal surrounding population. A large area to the west is wide open desert which is also used as army and navy testing and training grounds. This is the alternate location when the RRCC club field is not available due to weather or a club event. Drone America will post a NOTAM broadcasting the date and times of Unmanned Aircraft testing and air operations for Tiger Field Airport. The Tiger Field
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Airport is secured by perimeter fencing and therefore, restricts unauthorized activities of public access and/orevents
. 

## 9. Airport Operations: Airport operations have been described in Section 8. The airports selected for operations have been either deemed as a UAS test site or are private fields in which authorization has been sought and approved for UAS emergency training exercises. All safety mitigations have been taken into consideration, including radio communications and lost link procedures

. 

## 10. VISUAL LINE OF SIGHT (VLOS): The Savant will remain within visual line of sight (VLOS) of the observers. Through two-way communications with the pilot, observers will 'provide critical information about flight safety, obstructions and airspace encroachment. Observers will also clear the area of people to keep a safe perimeter ofoperations. 

## 11. PREFLIGHT SAFETY RISKASSESMENT:
• Airframe preflight check completed according to checklist in manual • Pilot and all personnel briefed on operation details • Pilot and crew safe to fly • Maps loaded for flying area within autopilot software • All flight plans verified by flight crew forclearance ofobstacles and any potential hazards • Ground supportequipment inspected for safety and in working order • Launch and recovery area inspected and cleared ofobstacles and personnel • Correct sensor package installed and operating correctly • Data collection equipmentfunctioning 

### 12. 

## OPERATIONSWITH EXISTING REQUIREMENTS: Whenever existing requirements are in place (i.e. Temporary Flight Restrictions), Drone America will coordinate directly with the agencies involved

. Before every test operation, Drone America files a NOTAM with the FAA. 

### 13. 

## CERTIFICATE OF WAIVERORAUTHORIZATION - COA: Drone America will submit an application for a Certificate ofWaiver or Authorization congruently with this 333 Exemption request.

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