RAVEN EXECUTIVE & SECURITY SERVICES, INC.

1 | P a g e June 1 , 2015

Via Electronic Filing

Attn: Docket Operations

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue SE, Room W12

- 140

West Building Ground Floor

Washington, DC 20590

- 0001

RE: Exemption Request; Section 333 of the FAA Modernizat ion & Reform Act and

Part 11 of the Federal Aviation Regulations from 14 C.F.R.; 14CFR45.23(b); 15 CFR Part

21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121;

91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a )(2); 91.417(a) & (b).

Dear Sir or Madame,

Raven Executive & Security Services, Inc. (henceforth referred to as “RES”) hereby

petitions the Secretary of Transportation and the Federal Aviation Administration (“FAA”)

for exemption to the above referenced and below more fully described Federal Aviation

Regulations. The exemption is being sought for the purpose of utilizing Unmanned Aerial

Systems (UAS) for the purpose of conducting inspections of vertically developed

structures, energy pipelines, right of ways, aerial survey and photography in support of

agricultural operations (including crop monitoring and inspection), surveying and civil

engineering services, as well as the insurance and finance industries. The exemption will

provide cost effective and personal safety enhancing aerial imagery services.

The leadership team at RES has a proven track record in aviation with over 1,400 hours of

combined flight time holding Commercial and Private Pilot license certificates, instrument

single and multi

- engine land and ground instructor certificate. RES is of the opinion that

responsible UAS operations will benefit the public interest in the following ways:

• Removal of human risk from conventional flight operations

• Removal of human risk from gas detection inspe ctions

• Removal of human risk from vertica l l y developed structural inspections

• Improvement in the ability to provide integrity and encroachment data to energy

transportation facilities and infrastructures

• Improvement upon cost efficiencies associated with m anned flight.

• Improvement and increased efficiencies in the agricultural industry

• Increase the sophistication of data available to insurance and financial industries for

good decision making.

Carmen P. Gackstetter , CE O

Raven Executive & Security

Servic es, Inc

. 7111 Dixie Highway #149

Clarkston, Michigan 48346RAVEN EXECUTIVE & SECURITY SERVICES, INC.

2 | P a g e 

### Table of Contents

PROPOSED OPERATIONS

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

A IRCRAFTS

................................ ................................ ................................ ................................ ... 3 ,4

THE OPERATOR

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

OPERATING PARAMETERS

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

- 8

REGULATORY STATEMENT

................................ ................................ ................................ ......... 9

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81( A ))

................................ ............ 9

SECT IONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR WHICH RELIEF IS

SOUGHT (14 C.F.R. § 11.81( B ))

................................ ................................ ................................ 10

- 13

EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81( C ))

................................ ........................... 13

, 14

STATEMENT OF PUBLIC INTEREST (14 C.F.R. § 11.81( D ))

................................ ................ 14

, 15

REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT PUBLIC

SAFETY (14 C.F.R. § 11.81( E ))

................................ ................................ ................................ .. 15

- 17

FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81( F ))

................................ .......................... 18

ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81( G ))

................................ ........ 18

CONCLUSION

................................ ................................ ................................ ................................ ... 19RAVEN EXECUTIVE & SECURITY SERVICES, INC.

3 | P a g e 

## PROPOSED OPERATIONS

Raven Executive & Security Se rvices, Inc. (R ES or Petitioner) is seeking an exemption

that will permit it to perform aerial photography and surveying services for energy

co mpanies engaged in the research, development and maintenance of energy industry

infrastructure , transmission, transportation and refining infrastructure and facilities

, property

owners, individual farmers, agri

- businesses, surveying \ engineer ing companies, and

insurance \ finance companies. These services would be used to improve overall safety of

inspection operations , monitoring and research gathering operations normally conducted by

manned aircraft

, provide efficiencies and enhance decision

- m aking ability through safe

economical aerial based survey and photography. This would be done using

conventional high resolution and 3D photo/video imaging and thermal imaging

technology to study and document property or facility condition s

, facility and r ight of way

encroachment, the transmission and transportation infrastructure integrity and security, crop

photosynthesis \

health and also visually inspect farm ground for re

- planting, tiling needs,

as well as the need for additional farm inputs. For insuran ce \ finance purposes it will

allow for more thorough and conclusive claim research and documentation when

insurance claims are made at both an individual or catastrophic \ regional level.



### AIRCRAFT

THE PHANTOM 2 VISION+ UAS

The Phantom 2 Vision+ UAS (the “Sys tem”) is comprised of a quad

- rotor unmanned

aircraft (UA ) with a gross weight of 2.6 pounds and a transportable ground control

station. C apable of carrying small digital photography equipment during flight, the

electrically powered PHANTOM has a n approximate maximum speed of 28.6 kts. and is

operated using the transportable ground station, by a minimum required flight crew of

one, the Operator (PIC )

. The system will be operated in a manner that will not pose a

threat to persons or property in t he event of motor/rotor failure. Manufacturer

s pecifications attached.

UA Manual

- http://www.dji.com/product/phantom

- 2

- vision

- plus/download

UA Specs

- h t t p : / / w w w . d j i . c o m / p r o d u c t / p h a n t o m

- 2

- v i s i o n

- p l u s / s p e c

This is the same system which is the subject system in Exemption No. 11138 granted to

Douglas Trudeau, Realtor® on January 5, 2015. Regulatory Docket No. FAA

- 2 014

-

0481

.

THE DJI INSPIRE I UAS

The DJI model T600 INSPIRE I (the “System”) is comprised of a small quad

- rotor

design unmanned aircraft (UA) and a transportable ground control station. The UA

system gross weight configuration is 2935 g (6.5 pounds) . The UA is capable of

carrying small digital photography equipment during flight, the electrically powered

INSPIRE I has an approximate maximum speed of 43 knots and may be operated using

the transportable ground station, by a minimum required fl ight crew of one, the Operator

(PIC). The system will be operated in a manner that will not pose a threat to persons orRAVEN EXECUTIVE & SECURITY SERVICES, INC.

4 | P a g e property in the event of motor/rotor failure. Manufacturer specifications attached.

UA Manual

- h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e

- 1 / d o w n l o a d

UA Specs

- h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e

- 1 / s p e c

This is the same system which is the subject system in Exemption No. 11693 granted to

Replicopy Inc., dba RDM Productions May 26, 2015

. Regulatory Docket No. FAA

2014

- 1030

.

THE DJI S1000 UAS

The DJI model S1000 (the “System”) is comprised of a small octo

- rotor design unmanned

aircraft (UA) and a transportable ground control sta tion. The UA system gross weight

configuration with full payload is 11.0 Kg (24.25 pounds). The UA is capable of

carrying digital photography and research equipment during flight, the electrically

powered S1000 has an approximate maximum speed of 39 knots and may be operated

using the transportable ground station, by a minimum required flight crew of one, the

Operator (PIC). Capable of sustained flight in the event of single motor failure. The

system will be operated in a manner that will not pose a threat to persons or property in

the event of motor/rotor failure. Manufacturer specifications attached.

UA Manual

- h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g

- w i n g s

- s 1 0 0 0 / d o w n l o a d

UA Specs

- h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g

- w i n g s

- s 1 0 0 0 / s p e c

This is the same system which is the subject system in Exemption No. 11554 granted to

Midstream Integrity Services, LLC May 12 , 2015

. Regulatory Docket No. FAA

- 2015

-

0377

.



### THE OPERATOR

The proposed Operator, (PIC) defined as the person who manipulates the controls of the

System, must hold either an airline transport, commercial, private, recreational, or sport

pilot certificate. The PI C must also hold a current FAA airman medical certificate or a valid

U.S. driv er’s license issued by a state, the District of Columbia, Puerto Rico, a territory or

the Federal Government. The PIC must also meet the flight review requirements specified

in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

T he Petitioner proposes that the Operator (PIC) would be augmented with a crew of a

visual observer (VO) to assist with scanning for collision hazards and maintaining

aw areness of the UAS ’s precise location, as noted in proposed Part 107, the Visual

Observer would be a required crewmember

.

In addition to the Observer, the Petitioner further proposes that Operator may (as an

operation dictates) augment the crew with an Equ ipment Operator (EO), who would be

responsible for operation of photographic equipment carried on board the UAS. The EO

would not be permitted to manipulate the flight or navigation controls of the UAS

.RAVEN EXECUTIVE & SECURITY SERVICES, INC.

5 | P a g e 

### OPERATING PARAMETERS

Raven Executive & Security Ser vices, Inc. is committed to the safe and compliant

operation of this System at all times. Because the UAS does not carry crew or passengers

on

- board, and is so much smaller, lighter, and slower than manned aircraft, Petitioner

seeks relief from several asp ects of 14 C.F.R. Part 91.

Raven Executive & Security Service’s exemption will not adversely affect safety , in the

alternative reducing the risk to personal safety in the air and on the ground inherent with

conventional manned aviation operations to accom plish the missions. Additionally, Raven

proposes to operate with the following safety procedures and restrictions if granted an

exemption:

Proposed specific operating limitations

1. Operations authorized by this grant of exemption are limited to the above aircraft

described in the operating documents which is a quad

- rotor or octo

- rotor aircraft

weighing less than 55pounds . Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. The UA may not be flown at an indicated airspeed exceeding 87 knots.

3. The UA must be operated at an altitude of less than 200 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents. All

altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the Pilot In

Command (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

- issu ed airman medical certificate.

5. All operations must utilize a visual observer (VO). The UA must be operated

within the visual line of sight (VLOS) of the VO at all times. The VO may be

used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS

capability. The VO and PIC must be able to communicate verbally at all times

during flight operations . Such communications may be augmented through the

use of radios or other technology so long as not to interfere with the operation of

the UAS. The PIC must be designated be fore the flight and cannot transfer his or

her designation for the duration of the flight. The PIC must ensure that the VO

can perform the functions prescribed in the operating documents.

6. The operating documents and this grant of exemption must be accessi ble during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in this exemption and

the procedures outlined in the operating documents, the conditions and limitations

herein t ake 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 suchRAVEN EXECUTIVE & SECURITY SERVICES, INC.

6 | P a g e revisions and prese nt updated and revised documents to the Administrator upon

request. The operator must also present updated and revised documents if he

petitions for extension or amendment to this grant of exemption. If the operator

determines that any update or revision w ould affect the basis upon which the FAA

granted this exemption, then the operator must petition for amendment to its grant

of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if

questions arise regarding updates or revisions to the op erating documents.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for

safe flight. If the inspection reveals a condition that affects the safe operation of

the UAS, the UAS is prohibited from operating until the necessar y 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.

8. Any U AS 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 aircraf

t records.

9. The pre

- flight inspection section in the operating documents must account for all

discrepancies, i.e. inoperable components, items, or equipment, not already

covered in the relevant sections of the operating documents.

10. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

11. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, and alterations must be noted in the aircraft records, including total

flight hours, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

12. Each UAS operated under this exemptio n must comply with all manufacturer

Safety Bulletins.

13. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

14. UAS operations must be conducted by a PIC possessin g at least a private

, recreational , sport pilot certificate and at least a current third

- class medical

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

CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15. UAS op erations may not be conducted during night, as defined in 14 CFR 1.1. All

operations must be conducted under visual meteorological conditions (VMC).

16. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or w hen visibility is less than 3 statute miles from the

PIC.RAVEN EXECUTIVE & SECURITY SERVICES, INC.

7 | P a g e 17. If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in

accordance with the operating docu ments.

18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies

in accordance with the operating documents.

19. 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 25 % battery power remaining.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any op erations in Class E

airspace. 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

that operation.

21. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have

identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart

C. Markings must be as large as practicable.

22. Before conducting operations, the radio fre quency spectrum used for operation

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

23. The documents required under 14 CFR 91.9 and 91.203 must be available to t he

PIC at the Ground Control Station of the UAS any time the UAS is operating.

These documents must be made available to the Administrator or any law

enforcement official upon request.

24. The UA must remain clear and yield the right of way to all manned avia tion

operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. Flight operations must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Bar riers 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

protection. If a situation arises where nonpa rticipating 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 grantedRAVEN EXECUTIVE & SECURITY SERVICES, INC.

8 | P a g e 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, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

27. All operations shall be conducted over private or controlled

- access property with

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or au thorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by an 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.

Unless otherwise specif

ied in this grant of exemption, the UAS, the UAS PIC, and the

UAS operations must comply with all applicable parts of 14 CFR including, but not

limited to, parts 45, 47, 61, and 91.9 | P a g e 

## REGULATORY STATEMENT

In accordance with the FAA Modernization and Refor m Act of 2012, Section 333,

entitled Special Rules for Certain Unmanned Aircraft Systems

, and 14 C.F.R. §§ 11.61(b)

and 11.81, the Petitioner, through Counsel, submits the following:



### PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(a))

The name and addr ess of the Petitioner is:

Raven Executive & Security Services, Inc.

7111 Dixie Highway # 149

Clarkston, MI. 48346

The point of contact for purposes of this Petition is:

Rollie W. Gackstetter VP/CFO

Raven Executive & Security Services, Inc.

7111 Dixie Highway # 149

Clarkston, MI. 48346

Tel. 248.978.3367

Fax. 248.922.9218

rgackstetter@sbcglobal.net

Raven Executive & Security Services, Inc. is a Michigan based corporation since 2006

Michigan ID Number 37015A , DUNS 078522636 conducting safety and sec urity

operations in Michigan, Indiana and Illinois.10 | P a g e



### SECTIONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR

WHICH RELIEF IS SOUGHT (14 C.F.R. § 11.81(b))

Relief is sought from the following provisions of Title 14 of the Code Of Federal

Regulations:

Part 61

§ 61.113 (a) and (b), which state:

Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person

who holds a private pilot certificate may act as pilot in command of an

aircraft th at is carrying passengers or property for compensation or hire;

nor may that person, for compensation or hire, act as pilot in command of

an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

Part 91

§ 91.7(a), which states:

Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy

condition.

§ 91.119, which states:

Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing

without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement,

or over any open air assembly of persons, an altitude of 1,000 feet above the

highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the

operation is conducted without hazard to persons or property on the surface

—11 | P a g e (1) A helicopter may be opera ted at less than the minimums prescribed in

paragraph (b) or (c) of this section, provided each person operating the

helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA; and

(2) A powered parachute or weight

- shif t

- control aircraft may be operated

at less than the minimums prescribed in paragraph (c) of this section.

§ 91.121(a), which states:

Altimeter settings.

a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraf

t, 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 setting

available before departure; or

(2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.

§ 91.151, which states:

Fuel requirements for flight in VFR conditions.

(a) ) No person may begin a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to

the first point of i ntended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wi nd 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.

§ 91.405(a), which states:

Maintenance required.

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 ;12 | P a g e

§ 91.407(a)(1), which states:

Operation after maintenance, preventative mainte na nce

, rebuilding, or alteration.

(a) ) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been ap proved for return to service by a person authorized under

§43.7 of this chapter; and...

§ 91.409(a)(1) and (2) which state:

Inspections

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 ca lendar 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; or

(2) An inspection for the issuance of an airworthiness certificate in

acc ordance with part 21 of this chapter.

§ 91.417(a) and (b) which state:

Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in p aragraph (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 ea ch 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 completion of the work performed; and

(iii) The signature and certifi cate 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 a irframe, 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)13 | P a g e and safety directives including, for each, the method of

compliance

, the AD or sa fety 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 c urrently installed

engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be

retained until the work is repeated or s uperseded by other work or for

1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered o wner or operator under

§43.11 of this chapter shall be retained until the defects are repaired and

the aircraft is approved for return to service.



### EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))

61.113(a) and (b). Relief is requested to the extent neces sary to permit the holder of a

private pilot certificate, with at least a current third

- class medical certificate holder to

conduct the proposed flight operations for compensation or hire.

91.7(a). Raven Executive & Security Services, Inc. seeks relief fr om 91.7(a) to the extent

that the UAS systems delineated above are not eligible for an airworthiness certificate

under 14 C.F.R. 21 and therefore can not be airworthy in the context of the regulation.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations

and the limited capabilities of the System. Raven Executive & Security Services, Inc.

can ensure that each operation is conducted within the requirements of 91.119(a) and is

therefore not seeking exemption from that secti on of the regulation. With respect to

91.119 (b) and (c) Raven Executive & Security Services, Inc. seeks relief for two

reasons. First, the diminutive size and flight envelope of the UA, and the limited range

of the System necessarily restrict operations to that of low level, low speed, line of sight

(with the Operator) operations. Combined with the intent of the operations primarily

being the survey and photography of property; commercial operation simply could not be

done without exemption. Second, while not a manned helicopter, the UAS systems are

more analogous to a helicopter than other aircraft, which a private pilot is permitted to

operate at less than the minimums prescribed in paragraph (b) or (c) of section 91.119 so

long as the operation is condu cted without hazard to persons or property on the surface.

14. C.F.R. § 91.119(d).

91.121. Relief is sought from 91.121 due to the design of the system. While not

possessing an altimeter that can be set in compliance with the regulation, however the

Syste m contains barometric altimeter and GPS derived altitude capabilities. That being14 | P a g e

said, Raven Executive & Security Services, Inc. is not proposing relief to the extent that

the Operator is not expected to check the System settings prior to each flight.

91 .151. Raven Executive & Security Services, Inc. requests relief from 91.151 due to the

limited design range and associated battery storage capacity.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that

the UAS aircraft and the larger System are not certificated pursuant to Part 21, nor issued

airworthiness certificates, and due to the fact that the technology of the System is so

different from traditional manned aircraft, the System does not fit well into the regulatory

scheme of Part 91 Subpart E. As such Raven seeks relief from the above noted

regulations. However, Raven will maintain all maintenance records related to the system.

Raven does not intend to document each battery replacement or charge, however, because

th e battery is analogous to fuel in manned aircraft, and documenting each charge would

be as laborious as documenting each fueling of a certificated aircraft in that aircraft’s

maintenance records.



### STATEMENT OF PUBLIC INTEREST (14 C.F.R. § 11.81(d))

The pu blic benefits commensurate with the commercial operation of the UAS systems

described above by Raven Executive & Security Services, Inc. are numerous. By

implementing this technology into the National Airspace System in a deliberate and

limited way, the pu blic’s interest will be served in that environmental impacts will be

lessened, economies will be more efficient and relative public safety will increase.

This technology will serve to reduce present environmental impacts, and prevent future

negative impac ts. Being an incredibly small, electrically powered System environmental

impacts are mitigated when this system is used in place of present approved manned

aircraft operations. Because neither leaded avgas nor jet fuel is burned, the System itself

has low impact. The low weight and tiny motors not only reduce fuel consumption, but

reduce noise in the environment and reduce the likely hood of other negative

environmental impacts such as bird strikes and fuel spills.

Because the System is so small, cheap and quick to deploy, yet retains the ability to

return incredibly detailed information, crops can be monitored more closely for less cost,

and as such the need to dispense agricultural chemicals can be further minimized.

Infrastructure such as roads, bridges, pipelines, can be quickly assessed without the need

for heavy equipment such as trucks, cranes, hoists and aircraft that run on fossil fuels.

Additionally, with this technology deployed, studies regarding all aspects of land use,

soil, topography, become possible where they previously were not due to economic

reasons. The information collected by Raven for their consumers will have a broader

environmental impact that will benefit everyone, not just the customer.

When this System is used in support of comm ercial operations, the public at large will

benefit from the efficiencies that this system brings into the aerial survey market. UAS

services in agriculture will allow farmers to have access to aerial based crop studies15 | P a g e

performed on a more timely basis whi ch will allow them to reduce input costs (fuel,

fertilizer, chemicals, etc.) allowing for more efficient crop production. In support of

agricultural operations, UAS operation will provide the American consumer with lower

food prices and better gains from t he export of those agricultural products.

In support of the insurance and financial industries, pools of the insured will see lower

premiums as a result of lower costs of claims administration and better future risk

analysis derived from the collected inf ormation.

For both individual and wide

- scaled disasters, the use of UAS’s will allow the insurance

companies a more efficient way of assessing the assets necessary to service their

policyholder needs. They will be able to align their teams closely to the disaster paths at

their disaster sites and allow them to visually inspect more frequently where their teams

have been as well as where they need to go. The use of UAS’s in disaster scenarios will

not only allow the insurance companies to better service the ir policyholders, but will

ensure that life safety measures are even more enhanced during widespread disaster

scenarios. Through the use of thermal based imaging, not only will photosynthesis

studies be possible, but it will also be possible to be used for disaster \ recovery services

during regional disasters.



### REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT

PUBLIC SAFETY (14 C.F.R. § 11.81(e))

Raven Executive & Security Services, Inc. is firmly convinced that this product will not

affect public safet y in any adverse way, but will in fact enhance it.

With respect to the safe operation of the aircraft, the Administrator, in exemption No.

11138 has already evaluated the technical specifications of the aircraft. In noting it’s

small size, limited speed a nd numerous safety features (such as low battery autonomous

landing, lost

- link event autonomous procedures, auto

- pilot and stability control, to name

a few), Raven believes that the Administrator’s finding that this System can be safely

operated in the NAS system was correct.

In order to ensure that safety, Raven would utilize a certificated pilot as the Operator,

and abide by common sense operating limitations to ensure that the safety of the public is

ensured. A list of proposed specific operating limita tions is included in the additional

information section, above

. The Petitioner is only seeking relief from very specific

regulations that relate to the operation of this System, and is suggesting specific

alternative procedures to ensure safety in lieu of those regulations from which Petitioner

is seeking relief.

Raven further notes that by replacing certain manned operations with operations

conducted by this small System, public safety will actually be enhanced. In those

operations where traditional manne d aircraft are presently used, the public bears the risk

of the crash of a much larger, heavier vehicle travelling at a much higher rate of speed.16 | P a g e

Furthermore, many of those manned operations contribute to congestion in the NAS, and

as such an increased ri sk of collision with other aircraft. Because the UAS systems listed

above will be operated away from the airport environment, the airport environment being

the location of the highest risk of collision, using this aircraft in place of a manned aircraft

red uces the risk of collision.

With respect to each particular regulation for which relief is sought, Raven believes safety

is insured:

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a

private pilot certificate, with a t least a current third

- class medical certificate holder to

conduct the proposed flight operations for compensation or hire.

Raven Executive & Security Services, Inc. notes that private pilots are allowed to operate

aircraft for compensation or hire so lo ng as doing so is incidental to their business and

they do not carry passengers. This is done in much heavier, faster aircraft, which pose a

greater risk to persons or property on the ground. In the case of the UAS systems listed

above

, the aircraft, thro ugh it’s limited speed and weight poses much less risk of harm to

those on the surface. The fact that the very small UA will be operated in accordance with

the manufacturer’s instructions and over limited parcels of land, combined with it’s

limited range, negates the long cross

- country flying experience required for a commercial

pilot certificate. Therefore Petitioner believes that an equivalent level of safety with

respect to manned aircraft is met with a minimum certification level of Private Pilot

91.7( a). R aven Executive & Security Service, Inc. seeks relief from 91.7(a) to the extent

that the UAS systems listed above are not eligible for an airworthiness certificate under 14

C.F.R. 21 and therefore can not be airworthy in the context of the regulation. The

Operator can, before each flight, determine whether or not the aircraft is capable of safe

flight by visually inspecting the System, accomplishing appropriate pre

- flight inspections,

and ensuring compliance with the manufacturers operating manuals and therefore an

equivalent level of safety will be met.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations

and the limited capabilities of the System. Raven can ensure that each operation is

conducted within the require ments of 91.119(a) and is therefore not seeking exemption

from that section of the regulation. With respect to 91.119(b) and (c) Raven seeks relief

for two reasons. First, the diminutive size and flight envelope of the UA, and the limited

range of the Sys tem necessarily restrict operations to that of low level, low speed, line of

sight (with the Operator) operations. Combined with the intent of the operations

primarily being the survey and photography of property; commercial operation simply

could not be d one without exemption. Second, while not a manned helicopter, the UAS

systems listed above are more analogous to a helicopter than other aircraft, which a

private pilot is permitted to operate at less than the minimums prescribed in paragraph (b)

or (c) of section 91.119 so long as the operation is conducted without hazard to persons or

property on the surface. 14. C.F.R. § 91.119(c).

With respect to operating the UAS systems listed above over or near a structure, Raven

would like point out that it is oft en more dangerous for those involved if a person were17 | P a g e

to, for example, fall off of a roof or a ladder, or drop a heavy tool such as a hammer, than

it would be for the listed UAS systems to fall, so long as the Operator ensures that he has

permission from t he owner and requires that any structure the UAS is operated over or

near is not occupied, nor are people in the immediate vicinity, a high level of safety can

be achieved.

Due to the Systems limitations with respect speed and altitude, it’s light weight, and

ability to maneuver like a helicopter (with an equally trained Private Pilot Operator), and

a restriction than any structure flown over with permission and only when unoccupied,

Raven respectfully submits that an equivalent level of safety is assured if relief is granted

from 91.119 (b) and (c).

91.121. Relief is sought from 91.121 due to the design of the system. While not

possessing an altimeter that can be set in compliance with the regulation, an equivalent

level of safety can be met due to the fa ct that the System contains barometric altimeter

and GPS derived altitude capabilities, thus ensuring an equivalent level of safety. That

being said, Raven is not proposing relief to the extent that the Operator is not expected

to check the System settings prior to each flight.

91.152. Raven requests relief from 91.151 due to the limited battery storage capacity.

Petitioner feels that a good balance of safety and utility can be met if the Operator is

permitted to plan and initiate a daytime VFR flight to the first intended point of landing,

at normal cruising speed which would require no more than 70% battery power. This

System possesses several safety features with respect to power, including a low battery

warning that first alerts at 30% remaining and an automate d landing function when a

low battery is detected by the System. Should conditions change during the flight, this

will leave 30% battery capacity to fly to a safe alternative landing zone.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b). Due to the fact that

the UAS systems listed above are not certificated pursuant to Part 21, nor issued

airworthiness certificates, and due to the fact that the technology of the System is so

different from traditional manned aircraft, the System does n ot fit well into the regulatory

scheme of Part 91 Subpart E. As such Raven seeks relief from the above noted

regulations. In order to ensure an equivalent level of safety, Raven will use trained

technicians to perform maintenance, alterations, or preventiv e maintenance on the UAS

using the methods, techniques, and practices prescribed in the manufacturer’s manuals.

Raven will maintain all maintenance records related to the system. Raven does not

intend to document each battery replacement or charge, however

, because the battery

operated systems are analogous to fuel in manned aircraft, and documenting each charge

would be as laborious as documenting each fueling of a certificated aircraft in that

aircraft’s maintenance records.18 | P a g e 

### FEDERAL REGISTRY SUMMARY (1 4 C.F.R. § 11.81(f))

Raven Executive & Security Services, 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).

This exemption will permit Raven Executive & Security Services, Inc. to

commercially operate an Unmanned Aircraft System (UAS) for the purpose of

conducting aerial survey and photography within the United States.



### ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81(g))

Doc uments and Manuals

The documents and manuals for the UAS systems delineated above in the petition can

be found at:

DJI Phantom II Vision +:

http://www.dji.com/product/phantom

- 2

- vis ion

- plus/download

h t t p : // w w w . d j i . c o m/ p r o d u c t / p h a n t o m

- 2

- v i s i o n

- p l u s/ s p e c

D J I In s p i r e I:

h t t p : / / w w w . d j i . c o m/ p r o d u c t / i n s p i r e

- 1 / d o w n l o a d

h t t p : / / w w w . d j i . c o m/ p r o d u c t / i n s p i r e

- 1 / s p e c

D J I S 1 0 0 0 :

h t t p : // w w w . d j i . c o m/ p r o d u c t / s p r e a d i n g

- w i n gs

- s 1 0 0 0 / d o w n l o a d

h t t p : // w w w . d j i . c o m/ p r o d u c t / s p r e a d i n g

- w i n gs

- s 1 0 0 0 / s p e c

These documents are incorporated into this petition by reference. However, due to

file size limitations they are not being attached

.19 | P a g e 

## CONCLUSION

As set forth above, Raven Executive & Security Services Inc. seeks an exemption from

certain parts of the Federal Aviation Regulations to permit Raven Executive & Security

Services to operate a UA systems described above

, for compens ation or hire, commercially

in the United States for the purposes of conducting aerial photography and survey. RES

believes that a grant of exemption is in the public interest and that public safety will not

be negatively affected. By use of an unmanned sy stem in scenarios where manned

aircraft are traditionally operated RES believes that public safety will actually be

enhanced.

PETITIONER, Raven Executive & Security Services Inc.

, in accordance with the

Federal Aviation Regulations and the FAA Modernizati on and Reform Act of 2012,

Section 333, respectfully requests that the Administrator grant this Petition for an

exemption from the requirements of 14 C.F.R Sections 61.113(a) and (b), 91.7(a),

91.119(b) and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) and (b), and permit Raven Executive & Security Services to operate

the UA systems described above commercially for the purpose of conducting aerial

survey and photography over certain areas of the United States.

Resp ectfully Submitted,

Raven Executive & Security

Services Inc.

Carmen P. Gackstetter, CEO

Raven Executive & Security Services,

Inc.

7111 Dixie Highway #149

Clarkston, Michigan 48346

o.248.922.9218

c.248.830.1338

f.248.922.8218

Email:

cgackstetter@ravenexecutive.com