UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

LEADING EDGE ASSOCIATES , INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATION S SECTIONS 61.113(a) & (b), 91.7(a), 91.121 , 91.151(b ), 91.405(a), 91.407(a)( 1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

PRECISIONVISION 10 UNMANNED AIRCRAFT SYSTEM

PURSUAN T TO SECTION 333 OF THE F AA MODERNIZATION AND REFORM ACT OF 2012 ( PUBLIC LAW 112

- 95)

Submitted on February 5
, 201 5

G REGORY S

. W INTON , E SQ

. J ARED M. A LLEN , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner2 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................. 3

SUMMARY

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................. 4

BACKGROUND

................................ ................................ ................................ ................. 4

BASIS FOR PETITION

................................ ................................ ................................ ...... 5

NAME AND ADDRESS OF PETITIONER

................................ ................................ . 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH LEADING EDGE ASSOCIATES , INC. SEEKS EXEMPTION

................................ ................................ 8

THE EXTENT OF RELIEF LEADING EDGE ASSOCIATES , INC. SEEKS AND THE REASON LEADING EDGE ASSOCIATES , INC. SEEKS THE RELIEF

....... 1 1

THE REASONS WHY GRANTING LEADING EDGE ASSOCIATES , INC. 'S REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ............ 1 5

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ .............. 1 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

.......... 3 4

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT LEADING EDGE ASSOCIATES , INC. 'S REQUEST

...................... 3 4

CONCLUSION

................................ ................................ ................................ ................. 3 43 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
C.F.R. Code of Federal Regulation s COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot I n Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 SUMMARY
Leading Edge Associates , Inc. seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA)

. This exem ption will permit Leading Edge

Associates , Inc. to operate an Unmanned Aircraft System (UA S ) for the commercial purpose of
conducting aerial acquisitions and research over certain rural areas of the United States

.

INTRODUCTION AND INTERESTS OF THE PETITIONER
Leading Edge Associates , Inc. (hereinafter referred to as “ Leading Edge ”) provides its
clients with expertise and knowledge in advanced technologies and solutions to increase
efficiency, productivity and effectiveness. Leading Edge is experienced in all aspects of disease
vector control, agriculture, and forestry. The objective of Lea ding Edge’s mosquito control
operations is the protection of public health from disease vectors (i.e., small organisms such as
mosquitoes or ticks that can carry pathogens from person to person and place to place) and
insuring a quality of life from nuisan ce mosquitoes.

BACKGROUND
Unmanned Aircraft System: PrecisionVision 10 UAS
Leading Edge seeks an exemption to operate the Leading Edge PrecisionVision 10 UAS
for compensation or hire within the NAS

. The PrecisionVision 10 UAS is comprised of a
vertical takeoff and landing (VTOL) U nmanned A ircraft (UA) and a transportable G round

C ontrol S tation (GCS) . The PrecisionVision 10 UA has a maximum gross weight of
approximately 27 pounds, while having a length of 57 inches
, width o f 14 inches, height of 20

inches
, and maximum speed of approximately 19 knots . The PrecisionVision 10 UA is equipped5

with one main rotor and one tail rotor , driven by a Lithium Polymer b attery powered electric

motor.

The PrecisionVision 10 UA that will be operated by Leading Edge will be registered in

accordance with 49 U.S.C. 44103
, Registration of Aircraft
, as well as 14 C.F.R Part 47, Aircraft

Registration
, and marked in accordance with 14 C.F.R. Part 45
, Identification and Registration

M arking

.
BASIS FOR PETITION

Petitioner, Leading Edge Associates , Inc.
, by and through undersigned counsel, pursuant
to the provisions of t he Federal Aviation Regulations ( 14 C.F.R. § 11.61) and the FAA

Modernization and Reform Act of 2012 (FMRA) , Section 333, Special Rules for Certain
Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the

PrecisionVision 10 UAS in the N ational A irspace S ystem (NAS)
, and for an exemption from the
requirements of 14 C.F.R §§ 61.11 3(a) & (b), 91.7(a), 91.121, 91.151( b ), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

I n consideration of the size, weight, speed, and limited operating area associated with the
unmanned aircraft and its operation, Leading Edge ’s op eration of the PrecisionVision 10 UAS

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

certificate in accordance with 14 C.F.R. P art 21, Subpart H.
Accordingly
, Leading Edge requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.
Leading Edge submits that the requested relief is proper since an equivalent level of
safety will be ensured. Leading Edge will use trained technicians to perform maintenance,6

alteration s , or preventive maintenance on the UAS using the methods, techniques, and practices
prescribed in the operating documents (i.e., th e PrecisionVision 10 UAS Operation Manual
,
Maintenance Schedule and Manual
, Airframe Maintenance Manual , and Spektrum DX8

Instruction Manual )

. Furthermore, Leading Edge will document and maintain all maintenance

records for the PrecisionVision 10 UAS.

Relief from certain requirements of Section 61.113(a) and (b)
, entitled Private pilot
privileges and limitations: Pilot in command
, is requested by Leading Edge to the extent
necessary to allow a Pilot in Command ( PIC ) holding a private pilot or higher level certificate , as

well as a n airman medical certificate, and who has demonstrated, by meeting m inimum flight

hour and currency requirements
, that the PIC is able to safely operate the PrecisionVision 10

UAS in a manner consistent with this ex emption, including evasive and emergency maneuvers
and maintaining appropriate distances from people, vessels, vehicles and structures.
Leading Edge seeks relief from Section 91.7(a) , entitled Civil aircraft airworthiness
,
because the PrecisionVision 10 U AS does not require an airworthiness certificate in accordance

with 14 C.F.R. P art 21, Subpart H. As such, Leading Edge submits that it will ensure that the

PrecisionVision 10 UAS is in an airworthy condition
, prior to every flight
, by determining that
the UAS is in compliance with the operating documents (i.e., the PrecisionVision 10 UAS
Operation Manual
, Maint enance Schedule and Manual, Airframe Maintenance Manual, and
Spektrum DX8 Instruction Manual ) , and that the aircraft is in a condition for safe flight

. Leading Edge also seeks an exemption from the requirements of Section 91.121, entitled
Altimeter Settings , as the PrecisionVision 10 UA will not have a typical barometric altimeter

onboard

. However
, altitude information of the PrecisionVision 10 UA will be provided to the

PIC via Global Positioning S ystem ( GPS ) equipment and a radio communications telemetry data7

link, which downlinks from the UA to the GCS for active monitoring of the flight path

. This

altitude information, c ombined with Leadi ng Edge ’s operation of the PrecisionVision 10 UA
within visual line of sight
, at or below 400 feet AGL, will ensure a level of safety equivalent to

Section 91.121.
Additionally, Leading Edge seeks an exemption from the requirements of Section

91.151( b ), entitled Fuel requirements for flight in VFR conditions

. Leading Edge submits that
safety will not be affected by operation of the PrecisionVision 10 UA during daylight hours in
visual meteorological conditions (VMC) under visual flight rules ( VFR )
, with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and,
assuming normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery

power remaining )

.
In accordance with 14 C.F.R. § 11.81, Leading Edge provides the following information
in support of its petition for exemption:

A. Name A nd Address Of T he Petitioner.

The name and address of the Petitioner is:
Leading Edge Associates
, Inc. 702 Tulip Tree Court Fletcher
, N orth Carolina 28732
The point of contact for this P etition and specific contact information is as follows:
Gregory S. Winton, Esq. The Aviation Law Firm 1997 Annapolis Exchange Parkway
, Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 | Fax: (866) 568

- 9886 Ema il: Greg@aviationlawexperts.com8

B. The Specific Sections Of 14 C.F.R. From Which Leading Edge Seeks Exemption.

1. Leading Edge Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113 , entitled Private pilot privileges and limitations: Pilot in command
,
subsections (a) and (b) prescribe th e following, in relevant part:
( a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carryin g passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.
(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.

2. Leading Edge Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91. 7 , entitled Civil aircraft airworthiness , subsection (a), states the following :
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3

. Leading Edge Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121 , entitled A ltimeter settings , subsection (a), states the following, in part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or
(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter set ting available before departure.9

4

. Leading Edge Seeks Exemption From The Requirements Of Section 91.151 ( b )

.
Section 91.151
, entitled Fuel requirements for flight in VFR conditions
, subsection ( b ),

state s the following:
(b) No person may begin a flight in a rotorcraft under VFR conditions unle ss (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5

. Leading Edge Seeks Exemption F rom T he R equirement O f Section 91.405(a)

.
Section 91. 405
, entitled Maintenance required
, subsection ( a )
, states the follow ing :
Each owner or operator of an 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) of this section, have discrepancies repaired as prescribed in part 43 of this chapter [.]

6

. Leading Edge Seeks Exemption F rom The Requirements Of Section 91.407(a)(1)

.
Section 91. 407
, entitled O peration after maintenance, preventive mainte nance,
rebuilding, or alteration , subsection (a)(1)
, state s the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

7

. Leading Edge Seeks Exemption F rom The Requirements Of Sections 91.409(a)(1) A nd 91.409( a)(2 ).

Section 91.409
, entitled Inspections , subsection (a)
, state s the following:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or10 (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8

. Leading Edge Seeks Exemption From The Requirements Of Section s 91.417(a) A nd 91.417 (b)

.
Section 91.417
, entitled Maintenance records , subsections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the foll owing records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 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 of an aircraft. The records must include

--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of co mpletion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following 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 sp ecified 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 airwo rthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety11 directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods p rescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section sha ll be retained and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approve d for return to service.

C

. The Extent Of Relief Leading Edge Seeks And The R eason Leading Edge Seeks The Relief

.
1. Extent O f Relief Leading Edge Seeks And The Reason Leading Edge Seeks Relief From Section 61.113(a) And (b)

.
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command
, is requested to the extent necessary to allow a PIC holding a private pilot or
higher level certificate , as well as a current and valid airman medical certificate, and who has

met certain flight

- hour and currency requirements
, to conduct the proposed UAS flight
operations for compensation or hire

.
This relief is re quested since the limitations set for th in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any
business or employment if : (1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property fo r compensation or hire.12

As set forth more fully below, Leading Edge submits that an equivalent level of safety
will be maintained because no PIC will be allowed to operate the PrecisionVision 10 UAS unless
that PIC has met certain flight

- hour and currency requirements, demonstrat ing that the PIC is
able to safely operate the PrecisionVision 10 UAS in a manner consistent with the operations
specifications as described in this exemption, including evasive and emergency maneuvers, as
well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Leading Edge sub mits that all flights of the PrecisionVision 10 UAS
, conducted
by the PIC pursuant to the grant of this Petition : (1) will be incidental to Leading Edge ’s

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent O f Relie f Leading Edge Seeks And The Reason Leading Edge Seeks Relief From Section 91. 7(a)

.

R elief from Section 91. 7( a) entitled Civil aircraft airworthiness
, is requested to the extent
required to allow Leading Edge to determine that the PrecisionVision 10 UAS is in an airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., the PrecisionVision 10 UAS Operation Manual, Maint enance Schedule and

Manual, Airframe Maintenance Manual, and Spektrum DX8 Instruction Manual)

. Leading Edge seeks the requested relief because the PrecisionVision 10 UAS does not
require an air worthiness certificate in accordance with 14 C

. F

. R

. P art 21, Subpart H

. Therefore,
Leading Edge will ensure that the PrecisionVision 10 UAS is in an airworthy condition based

up on its compliance with the operating documents (i.e., the PrecisionVision 10 UAS Operation

Manual, Main tenance Schedule and Manual, Airframe Maintenance Manual, and Spektrum DX8

Instruction Manual) prior to every flight, and further, determine that the airc raf t is in a condition
for safe flight, as stated in the conditions and limitations below.13

3

. Extent O f Relief Leading Edge Seeks And The Reason Leading Edge Seeks Relief From Section 91. 121

. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight
operations of the PrecisionVision 10 UAS, which utilizes a barometric pressure sensor , GPS
equipment, and a radio communications telemetry data link to downlink altitu de information

from the UA to the PIC at the ground control station ( GCS )

. Since the FAA requires that any

altitude information concerning UAS operation s be reported to air traffic control ( ATC ) in feet
above ground level ( AGL )
, Leading Edge seeks the requested relief because the PrecisionVision

10 UA ’s altimeter may be set on the ground to zero feet AGL
, rather than the local barometric
pressure or field altitude
, before each flight.
Considering the limited altitude of the proposed operati ons, relief from 14 CFR 91.121 is
sought to the extent necessary to comply with the applicable conditions and limitations stated

below. As more fully set forth herein , an equivalent level of safety will be maintained since the

PrecisionVision 10 UA is equipped with a barometric pressure sensor and GPS equipment
,
which automatically ensure s that a ground level pressure setting will be established prior to each
flight, and provides the PIC with altitude information of the UA on the heads

- up display of the

GCS.

4

. Extent O f Relief Leading Edge Seeks And The Reason Leading Edge Seeks

Relief From Section 91.151( b )

.

R elief from Section 91.151( b ) entitled Fuel requirements for flight in VFR conditions
, is
requested to the extent required to allow flights of the battery powered PrecisionVision 10 UA
during daylight hours in visual meteorological conditions (VMC)
, under visual flight rules

( VFR )
, for a total duration of 13.5 minutes to the first point of intended landing and, assuming
normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 2 5 percent battery power14

remaining )

. Leading Edge seeks the requested relief because without an exemption from Section

91.151( b ), the flight time duration of the battery power ed PrecisionVision 10 UA will severely
constrain the practicality of any aerial acquisition and research flight operations that Leading
Edge propose s to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the PrecisionVision 1 0

UAS, the PrecisionVision 10 operating documents , and Leading Edge ’s proposed operating

limitations
, ensure that Leading Edge will safely operate the battery powered PrecisionVision 10

UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules

(VFR), with enough battery power to fly f or a total duration of 13.5 minutes to the first point of
intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

(i.e., 2 5 percent battery power re maining )

.
5

. Extent O f Relief Leading Edge Seeks And The Reaso n Leading Edge Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only
apply to aircraft wit h an airworthiness certificate, Leading Edge requests relief from these

Sections because the PrecisionVision 10 UAS does not require an airworthiness certificate. A s

set forth more fully below, the PrecisionVisio n 10 UAS meets the conditions of FMRA Section
333 for operation without an airworthiness certificate

. Accordingly, Leading Edge will use

trained technicians to perform maintenance, alteration s , or preventive maintenance on the UAS
using the methods, techniques, and practices prescribed in the UAS operating documents (i.e.,
the PrecisionVision 10 UAS Operation Manual, Maintenance Schedule and Manual, Airframe
Maintenance Manual, and Spektrum DX8 Instruction Manual)

. Furthermore, Leading E dge w ill

document and maintain all maintenance records for the PrecisionVision 10 UAS.15

D

. The Reasons Why Granting Leading Edge ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole

.
Gr anting the present Petit ion will further the public interest by allowing Leading Edge to
safely, efficiently, and economically perform aerial acquisition s , aerial application, and research

over rural areas of the United States, commercially, in support of government entities,
agriculture, and scientific studies

. Specifically, Leading Edge will operate the PrecisionVision

10 UAS as part of an integrated mosquito management program , which will serve to protect
public health and reduce vector borne disease transmission

.
Addition ally, use of the PrecisionVision 10 UAS will decrease congestion of the NAS,
reduce pollution, and provide significant benefits to the economy. Notably, the benefits of
Leading Edge ’s proposed operation of the PrecisionVision 10 UAS will be realized witho ut
implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisition And Research Performed.
Leading Edge submits this Petition to commercially operate the PrecisionVision 10 UAS
and perform aerial acquisition, aerial application, and research throughout rural areas of the
United States, as part of mosquito control operations including pest/vector management
programs, source analysis and reduction strategies, breeding habitat s urveillance, and the
creation of predictive mosquito breeding models. Therefore, the operations that Leading Edge
will perform with the PrecisionVision 10 UAS will directly benefit the public and promote
public health by enhancing current mosquito suppres sion efforts, and help prevent the spread of
disease through nuisance mosquito species.
The mission statement and objective of Leading Ed ge’s mosquito control operation is the
protection of public health from disease vectors (i.e., small organisms such as mosquitoes or16

ticks that can carry pathogens from person to person and place to place) , as well as insuring a
quality of life free from nuisance mosquitoes.
Leading Edge’s use of the PrecisionVision 10 UAS, accompanied with imagery sensors
for creating geo

- reference mosaic imagery, 3D elevation profiles and other models
, will greatly
enhance the efficiency and precision of mosquito control operations.
Specifically, Leading Edge’s use of the PrecisionVision 10 UAS will increase the
precision and effic iency of strategies that are vital to integrated pest/vector management
programs, such as source reduction, source analysis, and breeding habitat surveillance.
Moreover, an increase in the precision and efficiency of these strategies will result in a decr eased
use of costly larvacides and insecticides.
The public will also benefit through Leading Edge’s use of the PrecisionVision 10 UAS
,
since Mosquito breeding habitats are often located in areas that are inaccessible by manned

vehicles, and/or are locat ed in areas where the use of manned vehicles will negatively impact the

environment. While operating in areas such as fresh and salt water marshes, pasture lands, and

wetlands, the use of a battery operated, lightweight UAS will eliminate the harmful effe cts that
manned vehicles or aircraft may have on threatened and endangered species, such as fuel
pollution, noise pollution, and bird strikes

. Additionally, use of the PrecisionVision 10 UAS increases the ability to respond
effectively and efficiently d uring natural disasters, since response strategies that rely upon use of
the UAS are not practical with the use of manned aircraft.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The PrecisionVision 10 UA is battery powered and serves as a safe, efficient, and
economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By17

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption

allowi ng the use of a PrecisionVision 10 UAS would reduce the amount of manned aircraft in the
NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air
and on the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The

PrecisionVision 10 UA does not require an airport to takeoff or land. Likewise, a reduction of
manned aircraft conducting aerial sur vey missions would result in fewer aircraft that must be
handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of
flight operations.

3

. The Public Will Benefit From The Safety And Efficiency Of The Precisi onVision 10 UAS.
Conducting aerial acquisitions with the PrecisionVision 10 UAS, instead of manned
aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution
generated during traditional aerial survey flight operations. By using battery power and electric

motors, the PrecisionVision 10 UAS produces no air pollution, and is the most viable
environmentally conscious alternative to the cabin class, six cylinder internal combustion twin
engine aircraft that are t ypically utilized for aerial acquisitions, while burning approximately 20

- 30
gallons per hour of leaded aviation fuel. The PrecisionVision 10 UA, while reducing the carbon
footprint of aerial acquisitions , also eliminates noise pollution, as the UA is pro pelled by battery
powered electric motors, rather than an internal combustion engine.
By using the PrecisionVision 10 UAS to perform aerial acquisitions, the substantial risk
to life and property in the air and on the ground, which is usually associated with traditional
manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside18

from the lack of flightcrew members located onboard the aircraft, the PrecisionVision 10 UA
(weighing approximately 27 pounds at its maximum gross weight with a length of 57 inches
, width

of 14 inches, and with no fuel on board), has less physical potential for collateral damage to life
and property on the ground, and in the air, compared to the manned aircraft that typically conduct

aerial acq uisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40
feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4

. Performing Aerial Acquisition Operations With The PrecisionVision 10 UAS Will Benefit The Economy.
In addition to being safe and efficient, the PrecisionVision 10 UAS is also an economical
alternative to using manned aircraft to conduct aerial acquisitions . As such, operation of the

PrecisionVision 10 UAS will allow Un ited States based companies, like Leading Edge , to remain
competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of
aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out

leaded a viation fuels, U.S. owned and operated companies must adopt new and alternative
technology in order to remain competitive. Operating the battery powered PrecisionVision 10
UAS is one such technology that not only allows companies greater operational flexi bility
compared to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.
By operating the PrecisionVision 10 UAS, companies such as Leading Edge
, can remain
competitive and profitable, and ther efore, provide greater job stability to employees and
contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial
performance of U.S. companies, through commercial use of the PrecisionVision 10 UAS,
provides a stable wo rkforce that increases consumer spending; improves local, state, and federal19

tax revenues; and allows companies to invest in research and development in order to remain
competitive both in the United States and abroad.

5

. There Are No Privacy Issues

.
Simi lar to the manned aerial acquisition flight operations that have been conducted for

d ecades, Leading Edge ’s proposed operation of the PrecisionVision 10 UAS will not implicate
any privacy issues. Specifically, the PrecisionVision 10 UAS will be operated o nly in rural

ar eas, and in accordance with the Federal Aviation Regulations, including the minimum altitude
requirements of 14 C.F.R. § 91.119. Most significantly, the PrecisionVision 10 UA will not be
operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly
involved in the operation

.
E

. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Leading Edge Seeks Exemption.

1. Reasons Why The PrecisionVision 10 UAS Meets The Conditions Of The FAA Modernizatio n and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limit ed operating area associated with the
unmanned aircraft and its operation, Leading Edge ’s operation of the PrecisionVision 10 UAS

meets the conditions of FMRA Section 333
, and will not require an airworthiness certificate in
accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets for th requirements for considering whether a UAS will cr eate a hazard to users of the
NAS or the public
, or otherwise pose a threat to national security. Specifically, FMRA Section
333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 18 0 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national20

airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.
(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to na tional security; and
(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragr aph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely i n the national airspace system, the Secretary shall establish requirements for the safe ope ration of s uch aircraft systems in the national airspace system.

I n seeking this exemption, Leading Edge submits that the PrecisionVision 10 UAS can
operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by : ( a ) the

characteristics of the PrecisionVision 10 UAS ; ( b ) the pilot certification requirement; and ( c ) the
specific operating limitations

.

a . The Specifications Of The PrecisionVision 10 UAS Demonstrate Its Safe Characteristics.

The PrecisionVision 10 UAS does not create a hazard to users of the NAS or the public,
or otherwise pose a threat to national security considering its size, weight, speed, and operational
capability.

i

. Technical Specifications Of The PrecisionVision 10 UAS.
The technical specifications of the PrecisionVision 10 UAS are set forth by the
PrecisionVision 10 Specifications and Data Sheet
, attached hereto as Exhibit A. Exhibit A21

contains proprietary information and is to be held in a separate file p ursuant to 14 C.F.R. §

11.35(b) 1

.
ii

. The PrecisionVision 10 UAS Autonomous Flight A nd Navigation Modes Enable T he UAS To Remain Within A De fined O perational A rea.

The PrecisionVision 10 UAS may be operated in both manual and fully autonomous
flight modes. A complete description of the flight and navigational modes of the

PrecisionVision 10 UAS is provided at page s 3

- 9 of the PrecisionVision 10 User Manual,

attached hereto as Exhibit B

. Exhibit B contains proprietary information and is to be held in a
separate file pursuant to 14 C.F.R. § 11.35(b).

iii

. The PrecisionVision 10 UAS Is D esigned For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost
, the PrecisionVision 10 UA will remain stationary , in
flight, for 30 seconds. I f, after 30 seconds, the PrecisionVision 10 UA does not re acquire control

link data from the GCS , the UA will assume that the Control Link is lost and the UA will return

to the home position (i.e., failsafe mode ) via GPS
, and will de scend to the takeoff position and

shutdown.

When GPS s ignal is lost, the PrecisionVision 10 UA will continue to estimate its position
and velocity based upon accelerometers. In the case of GPS signal loss, the UA autopilot will
rely upon recorded pitch and roll values in order to keep the UA in a stable flight mode

. In the

alternative, the UA autopilot has the ability to allow the operator to control the desired pitch and

roll in the un likely event of GPS signal loss . If the operator cannot take control of the helicopter

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the Federal Docket Management System (FDMS).22

using the remote transmitter or CGS , the UA autopilot will keep the UA stable until GPS signal

is re ac quired

.
A complete description of the Failsafe Functions of the PrecisionVision 10 UAS are set

forth at pages 7 through 9 ( i.e., GPS Loss

- Recovery Method) and pages 12 through 13 ( i.e., Fly

Away Prevention Measures ) of the PrecisionVision 10 User Manual
, attached hereto as Exhibit

B

. Exhibit B contains proprietary in formation and is to be held in a separate file pursuant to 14

C.F.R. § 11.35(b).

iv . The PrecisionVision 10 GCS And Its Operation.

A complete description of the operation and specifications of the PrecisionVision 10 GCS
and flight control software is provided at pages 9 through 20 of the PrecisionVision 10 User

Manual

. A complete description of the manual control transmitter is set forth in the Spektrum

DX8 Instruction Manual

. A copy of the PrecisionVision 10 User Manu al is attached hereto as

Exhibit B
, and a copy of the Spektrum DX8 Instruction Manual is attached hereto as Exhibit C.

These exhibits are to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)

.

b

. Flight Operations Of The PrecisionVision 10 UAS Are Limited To The Line Of Sight Of A Certificated Pilot i n Command With A Safety Observer.
Leading Edge will only utilize certificated p ilot s who possess a current and valid a irman

m edical c ertificate to act as a pilot in command (PIC) of the PrecisionVision 10 UAS.
Additionally, a safety observer will assist all pilots during flight time

.

c . Flight s Of The PrecisionVision 10 UAS Will B e Conducted Pursuant To S pec ific Operating L imitations.
In seeking this exemption, Leading Edge proposes to commercially operate the

PrecisionVision 10 UAS for the special purpose of conducting aerial acquisitions over rural areas

of United States
, pursuant to the following specific operating limitations:23

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, a rotorcraft UAS weighing less than 27 pounds maximum gross weight : PrecisionVision 10 Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.
2. UAS ope rations under this exemption will be limited to conducting operations for the purpose of aerial acquisitions

. 3. The UA may not be flown at an indicated airspeed exceeding 19 knots.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes report ed to ATC must be in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- i ssued airman medical certificate.
6. The use of first person view (FPV) by the PIC or visual observer (VO) is not permitted.
7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC al ways maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designa tion for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents.
8. The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and othe r ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditio ns and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed . Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions fo r extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS24

Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to eac h flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
11. Any UAS that has underg one maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircra ft records.
12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.
13. The operator must follow the UAS manuf acturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintena nce, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to servi ce.
15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
17. The PIC must possess at least a private pilot certificate and at least a current third

class medical certificate. The PIC must also meet the flight review requirements specified in 14 C

. F

. R

. § 61.56 in an aircraft in which the PIC is rated on his or h er pilot certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C

. F

. R

. § 61.51(b). The VO is also requir ed to complete the operator’s training requirements. A record of training must be documented and made available upon request by the Administrator. Flights for the purposes of training the operator’s PICs and25

VOs (training, proficiency, and experience

- build ing ) are p ermitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are c onsidered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C

. F

. R

. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C

. F

. R

. § 1.1. All operations must be c onducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautica l chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS sign al, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance wit h the operating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 2 5 % battery po wer remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to cond ucting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potent ial transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C

. F

. R

. part 47, and have identification (N

Number) markings in accordance with 14 C

. F

. R

. part 45, Subpart C. Markings must be as large as practicable.26

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate gover nment oversight agency requirements.
28. The documents required fewer than 14 C

. F

. R

. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Admini strator or any law enforcement official upon request.
29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. The UA may not be operated over congested or densely populated areas.
32. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehi cles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC, VO, op erator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
33. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representa tive. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

34. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.27

2. Reaso ns Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.
Leading Edge submits that the equivalent level of safety established by Section 61.113(a)

and (b) will be maintained because no PIC will be allowed to operate the PrecisionVision 10

UAS unless that PIC has demonstrated , by meeting minimum flight

- hour and currency
requirements
, that the PIC is able to safely operate the PrecisionVision 10 UAS in a manner

consistent with th e exemption, including evasiv e and emergency maneuvers and maintaining
appropriate distances from people, vessels, vehicles and structures.
Considering Leading Edge ’s proposed area of operations
, and the operating limitations

set forth

- above ; the parallel nature of private pilot aeronautical knowledge requirements to those

of commercial pilot requirements ( See Exemption No. 11062 ) ; and the airmanship skills

necessary to safely operate the PrecisionVision 10 UAS, Leading Edge submits that the
additional manned airmanship experience of a commercially certificated pilot would not
correlate to the airmanship skills necessary for Leading Edge ’s specific proposed flight
operations.

T he FAA has previously granted relief from Section 61.113(a) and (b ) specific to UAS,
in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062
, 11063
, 11064
, 11065
, 11066
, 11067
, 11080
, 11109
, 11110, 11112
, 11136, 11138 , 11150,

11153 , 11156, 11158, 11159, 11160, 11161 ).

Lea ding Edge will not allow any PIC to operate the PrecisionVision 10 UAS unless that

PIC has demonstrated , by meeting minimum flight

- hour requirements or the PrecisionVision 10
UAS training and currency requirements, that the PIC is able to safely operate the

PrecisionVision 10 UAS in a manner consistent with this exemption, including evasive and28

emergency maneuvers and maintaining appropriate distances from people, ve ssels, vehicles and

structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of

tho se hours as a UAS pilot operating the same make and model of UAS to be used for operat ions
under the exemption ). In addition to the hour requirements, the PIC must accomplish 3 take

- offs
and landings in the preceding 90 days (for currency purposes).
As in Exemption Nos. 11062
, 11138, and 11153, prior documented flight experience that
was obtained in compliance with applicable regulations will ensure an equivalent level of safety
during Leading Edge ’s proposed operations. The Administrator has held that prior documented
flight experience that wa s obtained in compliance with applicable regulations would ensure safe
operations , stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather t han additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 take

- offs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s pro posed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to

ac complish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.29

Accordingly, Leading Edge will ensure safe operations by not allow ing any PIC to
operate the PrecisionVision 10 UAS unless that PIC has demonstrated
, by meeting minimum
flight

- hour and currency requirements
, that the PIC is able to safely operate the Prec isionVision

10 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers
and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption Fr om The Requirements Of Section 91. 7 (a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91. 7(a) will be maintained because
prior to every flight, Leading Edge will ensure that the PrecisionVision 10 UAS is in an
airworthy condition based up on the UAS’s compliance with its operating documents and as

stated in the conditions and limitations herein

. Additionally, t he FAA has previously granted relief from Section 91. 7(a) specific to
UAS, in circumstances similar, in all material respects, to tho se presented herein (e.g. Exemption

Nos. 11062, 11063 , 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112 , 11136, 11138
, 11150, 11153
, 11156, 11157, 11158, 11159, 11160, 11161 ).

4

. Reasons Why An Exemption Fr om The Requirements Of Section 91. 121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because

the altitude information of the PrecisionVision 10 UA will be provided to the PIC via GPS
equipment and a radio communications tele metry data link, which downlinks from the UA to the

GCS for active monitoring of the flight path and altitude . This altitude information, combined

with Leading Edge ’s operation of the PrecisionVision 10 UA within visual line of sight
, at or

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude30

information will be generated by GPS equipment installed onboard the aircraft. Prior to each
flight, a zero altitude initiation point is automatically established by the UAS at ground level

.

T he FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062
, 11063
, 11064
, 11065
, 11066
, 11067
, 11080
, 11109
, 11112
, 11136, 11138 , 11150, 11153
, 11156, 11157, 11158, 11159, 11160, 11161 ).

5

. Reasons Why An Exemption From The Requirements Of Section 91.151( b ) Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equiv a l e nt level of safety established by 14

C.F.R. Section 91.151( b ) as a result of (1) the technical specifications of the PrecisionVision 10

UAS ; (2) the limitations on the proposed flight operations ; and (3) the location of the proposed
flight operations . Accor dingly, Leading Edge will ensure that it will safely operate the battery
powered PrecisionVision 10 UA during daylight hours in VFR conditions
, with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and
, assuming normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery

power remaining )

. Here, as in Exemption No. 11109, the technical specifications of the PrecisionVision 10

UAS ; the limitations on the proposed flight operations ; and the location of the proposed
operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b)

. Furthermore, safety will be ensured as the PrecisionVision 10 UAS provides two audible and
visual warnings to th e PIC at the GCS when the UA experiences low battery voltage, the first
warning occurring at 50% remaining battery power, and against at 30% remaining battery power.
Significantly
, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating31

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at

less than the minimums prescribed in Section 91.151 , including Exempti on Nos. 2689, 5745, and

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS
, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673 , 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080
, 11109
, 11110
, 11136, 11138 , 11150, 11153 , 11156, 11157, 11158, 11159, 11160, 11161 ).

6

. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, Leading Edge submits that the equivalent level of safety with
regard to the regulatory maintenance and alteration requirements established by Sections

91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b) will be met because Leading
Edge will use trained technicians to perf orm maintenance, alteration s , or preventive maintenance

on the UAS using the methods, techniques, and practices prescribed in the operating documents

(i.e., the PrecisionVision 10 UAS Operation Manual, Main tenance Schedule and Manual,
Airframe Maintenance Manual, and Spektrum DX8 Instruction Manual) . Furthermore, Leading
Edge will document and maintain all maintenance records for the PrecisionVision 10 UAS.

Since the PrecisionVision 10 UAS will be inspected as prescribed by t he operating

documents
, Leading Edge will maintain the equivalent level of safety established by Section s
91.405(a)
, 91.409(a)(1)
, and 91.409(a)(2)

. A copy of the PrecisionVision 10 UAS User Manual

is attached hereto as Exhibit B ; a copy of the PrecisionVision 10 UAS Maintenance Schedule

and Manual is attached hereto as Exhibit D ; and a copy of the Airframe Maintenance Manual is

attached hereto as Exhibit E

. Exhibits B , D, and E con tain proprietary information and are to be
held in a separate file p ursuant to 14 C.F.R. § 11.35(b).32

Likewise, the exemption sought will not adversely affect safety because Leading Edge

will use trained technicians to perform maintenance, alteration s or p reventive maintenance on the

UAS using the methods, techniques, and practices prescribed by t he operating documents

. Furthermore, the exemption sought would maintain an equivalent level o f safety
established by Sections 91.407, 91.417(a) and 91.417(b)
, because a ll maintenance o f the

PrecisionVision 10 UAS will be performed by trained technicians
, which will document and

maintain maintenance records for the PrecisionVision 10 UAS.
Significantly, previous exemptions granted by the FAA concerning Section s 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely
affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Leading Edge ’s proposed operating limitations, the operating

documents , and the technical aspects of the PrecisionVision 10 UAS, Leading Edge submits that
safety will not be adversely affected by granting exemption from 14 C

. F

. R . Sections 91.405 (a),

91.407(a)(1) and ( a)(2) , 91.409(a)(2), and 91.417(a) and (b)

. T he FAA has previously granted
relief specific to UAS in circumstances similar, in all material respects, to those presented herein
(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080
, 11109, 11 110, 11112
, 11136, 11138 , 11150, 11153
, 11156, 11157, 11158, 11159, 11160, 11161 ).

7

. T he FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Sec tion 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, Leading Edge requests that the FAA
prescribe special conditions for the intended operation of the PrecisionVision 10 UAS , which
contain such safety standards that the Administrator finds necessary to establish a level of safety
equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91. 121, 91.151( b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), an d 91.417(a) & (b)

.33

Such special conditions will permit safe operation of the UA for the limited purpose of
conducting aerial acquisitions over certain rural areas of the United States for compensation or

hire

. FMRA Sec tion 333 sets forth the requirem ents for considering whether a UAS w ill create a

hazard to users of the NAS or the public
, or otherwise pose a threat to national security; and
further, provides the authority for such UAS to operate without airworthiness certification in
accordance with any requirements that must be established for the safe operation of the UAS in

the NAS

.
Likewise , the Administrator may prescribe special con ditions pursuant to 14 C.F.R.

§ 21.16
, for operation of the PrecisionVision 10 UAS
, since the airworthiness regulations of 14
C.F.R. Part 21 do not contain adequate o r appropriate safety standards
, due to the novel or
unusual design features of the aircra ft . Section 21.16, entitled Special Conditions , states the
following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

s tandards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16

. Therefore, in accordance with FMRA Sec tion 333 and 14 C.F.R. § 21. 16 , the FAA may
prescribe special conditions for Leading Edge ’s intended operation of the PrecisionVision 10

UAS , which contain such safety standards that the Administrator finds necessary to establish a
level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R

Sections 61.113(a) & (b), 91.7(a), 9 1 .121, 91.151( b )
, 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b)

.34

F. A S ummary That C an Be P ublish ed In T he Federal Register, stating: The Rules From Which Leading Edge Seeks Exemption:
Leading Edge Associates , Inc. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151( b )
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

. A Brief Description Of The Nature Of The Exemption Leading Edge Seeks:
This exemption will permit Leading Edge Associates , Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions and research over certain rural areas of the United States

.
G. Any Additional Information, Views, Or Arguments Available To Support Leading Edge’s Request.

This Petition is made p ursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS
may operate safely in the NAS

. As such
, Leading Edge ’s request for exemption may be granted
pursuant to the authority of FMRA Sec tion 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the require ments for considering whether a UAS will create

a hazard to users of the NAS or the public
, or otherwise pose a threat to national security; and
further, provides the authority for such UAS to operate without airworth iness certification.

As discussed in detail above
, Leading Edge will operate the PrecisionVision 10 UAS
safely in the NAS
, without creating a hazard to users of the NAS
, or the public
, or otherwise
pose a threat to national security

.
CONCLUSION

As set forth herein
, Leading Edge seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
, which will permit safe
operation of the PrecisionVision 10 UAS commercially
, without an airworthiness certificate
, for

the limited purpose of conducting aerial acquisitions over certain ru r al areas of the United States

.35

By granting this Petition, the FAA Administrator will be fulfill ing the Congressional mandate of

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the
public
, by allowing Leading Edge to safely, efficiently, and economically operate the

PrecisionVision 10 UAS commercially with in the NAS

.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Leading Edge respectfully requests that the
Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151( b )
, 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and

91.417(a) & (b)
, and permit Leading Edge to operate the PrecisionVision 10 UAS commercially
for the purpose of conducting aerial acquisitions and research over certain rural areas of the

United States

.
Dated: February 5
, 201 5 Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________ Gregory S. Winton, Esq. Jared M. Allen, Esq. 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner

cc: James H. Williams , AFS

- 80 Robert Pappas Dean Griffith, Esq.