U.S . Department of Transportation

Docket Management System 1200 New Jersey Avenue, S.E.

We st Building Ground Floor, Room W 12

- 1 40 Washington, DC 20590



## RE: Docket ID: FAA

- 2014

- 1081
Revised Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations

March 5, 2015

Petitioner: bizUAS Corp
Bernd Lutz , CEO 4845 Pearl East Circle, Suite 101 Boulder, CO 80301
Tel.: 303.931.4126
Email: bernd@bizUAS.com
Website: www.bizUAS.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, bizUAS Corp, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft for photogrammetry, inspection, and analyses. All operations shall be conducted within and under the conditions and limitations outlined previously b y the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals.

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

a. 14 CFR Part 21, subpart H
b. 14 CFR Part 61.113(a) and (b)

c. 14 CF T Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. bizUAS Corp wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) photogrammetry

, industrial inspections and analyses.This relief is sought because commercial use of sUAS is currently prohibited by law unless performed under an exemption.
b. This exemption will cover u se of the following airframes

, all of which will weigh less than 55

po unds including payload and energy sources : i. MULTIROTOR service

- drone Eagle V2 (see www.service

drone.com/en/shop/uav/multirotor

- g4

- eagle/multirotor

- g4

- eagle

- v2 ) with fully redundant flight control and flight recorder

ii. DJI Phantom 2 (see www.dji.com/product/phantom

- 2 )

iii. Other models to be a dded by future amendment to this exemption.

3. Public benefit:

a. Use of s UAS technology to obtain imagery , information and data currently obtained by use of manned flight or manual methods : i. Reduces statistical risk to human life due to manned aircraft accidents (e.g.,
infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).

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

economy.
iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from
manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C.
b. Aircraft will comply with maintenance and inspection requirements of the manufacturer . A ll repair a nd maintenance work will be conducted or approved by qualified personnel such as those authorized by Robotic Skies (or equivalent) , and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight , and who
will remain stationary on the ground during the flight operations : i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 ( private pilot license ) screened by
the TSA

2. A Third Class medical certificate issued under 14 CFR 67.

3. A b i

- annual flight review under 14 CFR 61.56

4. Successful completion of a UAS knowledge test in a specified form.

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or UAS
fixed

- wing in the case of fixed

- wing flight operations under this exemption).

S uch cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the pr ior 90 days . Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer.

iii. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificate s of Authorization

.
e. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. bizUAS Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) which include lost communication and other emergency and safety procedures.

iii. C onducted in VMC conditions during daylight hours

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

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

assessments will be co nducted prior to each flight

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

. vii. Flight ground speeds will not exc eed 50 knots

. viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical mile s of an airport

. ix. N ot be made near persons as required in 14 CFR 91.119 and not over persons on the ground without their prior permission

.

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

. xi. N ot exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever
occurs first.

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

xiii. b izUAS Corp will maintain liability insurance of at least $1,000,000 issued by a major
aviation insurance underwriter

. xiv. Any applic able local FSDO requirements.

xv. All other applicable regulations concerned with the operation of aircraft.
f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraf t with well

- defined and tested lost link procedures.

Please advise us of any additional information or changes that may be required.

Sincerely,

Bernd Lutz, PhD
CEO, b izUAS Corp