Page 3 of 18 Table of Contents

Glossary of Abbreviati ons.......................................................................4

List of Attachments

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

Introduction and Interest of Petitioner............... ........................................5

Unmanned Aerial System s......................................................................5

Unmanned Aircraft Pilot in Command (PIC) .................................................9

Operations of sUAS

............................................................ ..................11

Requested Exemptions from Regulations ....................................................14

Public Interest.................. .................................................................17

Conclusion.....................

................................................ ..................18Page 4 of 18 Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation MAAP Mid Atlantic Aviation Partnership

NAS National Airspace System

PIC Pilot in Command PQS Personnel Qualification System

Section 333 FAA Modernization an d Reform Act of 2012, Section 333 SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VT Virginia Polytechnic Institute

VO Visual Observer

VLOS Visual Line of SightPage 5 of 18 List of Attachments

(1) HAZON Standard Operating Pro cedures Extract, Chapters 1-4 and

Checklists/Forms (2) DJI Phantom 2 Operating Manual (3) DJI S1000+ Operating Manual (4) Draganflyer X4-ES sUAV Operating Manual (5) Draganflyer Ground Station Operating Manual (6) Certificate of Authorization (COA) 2014-ESA-152 (7) Certificate of Authorization (COA) 2014-ESA-153 (8) Certificate of Authorization (COA) 2014-ESA-160 (9) Fire Fly 6 Operating Manual (10) Penguin V2 Operating Manual (11) Range Video RV Jet Operating Manual (12) DJI Phantom 1 Operating Manual (13) DJI Inspire 1 Operating Manual

Thirteen attachments liste d are referenced in the request for exemption and contain trade secret and commercial pr oprietary information that HAZON has not and will not share with others except under appropriate confidentiality agreements . The HAZON Standard Operating Procedures (SOP) attachment contai ns operating conditions and procedures that have been developed exclusively by HAZON, and that are not available to the public. HAZON is requesting that these attachments be treated as pr oprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from release under the

Freedom of Information Act. See 5 U.S.C. 552 et seq

.

Section 1: Introduction and Interest of Petitioner

HAZON, Veteran owned and operated, is th e leading developer of sUAV service operations, training, safety and management programs. The mission of HAZON is to support, develop and validate unmanned syst em operations. Our goal is to provide unmatched quality and safety.

HAZON has safely conducted FAA approved COA, (2014-ESA-160) for infrastructure inspection with Virginia Tech (VT/MAAP). HAZON has two active FAA approved COAs (2014-ESA-152, 3) for precision agriculture inspection/ data collection with the VT test site.

Section 2: Unmanned Aerial Systems

Regarding the Unmanned Aircraft System

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and property on the ground. Sp ecifically, petitioners should describe the design and operational c haracteristics for the type(s) of UAS they intend to operate, e.g. aircraft perfor mance and performance limitations, operating procedures, and aircraft loading in formation in as much detail as possible. This could be provided in the petition or in an Aircra ft Flight Manual or similar document.Page 6 of 18 NOTE: The FAA will consider all information and data submitted by the petitioner that describes the UAS developmental and operational history. This could include statistical data or other documentation for the specific de sign and performance characteristics of the UAS, including the operational history and opera tional failure modes, obtained through previous Research & Development (R&D) and/or flight test activities, e.g. operations conducted under a COA, with a civil airworthiness certifica te, or under other authorized operating conditions.

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the peti tion, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. NOTE: The Aircraft Flight Manual and Ma intenance and Inspection Manual may be separate documents or combin ed in a single document

3. The petitioner should describe the Radio Freq uency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communica tions Commission (FCC) or other appropriate government oversight agency requirements. NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC requirements upon request

.

General Information Pertaining to All Proposed sUAS

HAZON will operate less than fifty-five pound sUAS, with the ability to conduct sUAS Flight Crew training, wi th payloads capable of supporting this mission.

Prior to each flight the PIC shall inspect the s UAS to ensure it is in a condition for safe flight. If the inspection rev eals a condition that affects the safe operation of the sUAS, the aircraft will be prohibited from operati ng until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenan ce and alterations must be properly documented in aircraft records. All discrepancies noted shall be documented as

described in the HAZON SO P (Chapter 1, Para 111).

Any sUAS that has undergone maintenance or al terations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight cri tical component, shall undergo a functional test flight in accordance with the manufacturers manual and HAZON SOP (Chapter 1, Para 111). The PIC who conducts the functional test flight shall make an entry in the sUAS aircraft logbook of the flight.

HAZON shall follow the manufacturer’s sUAS ai rcraft/component, maintenance, overhaul, replacement, inspection and life limit requirem ents, with particular attention to flight critical components that may not be a ddressed in the manufacturer’s manuals.

HAZON shall carry out their maintenance, insp ections and record keeping requirements, in accordance with the operator’s manual. Mainte nance, inspection, and alterations must bePage 7 of 18 noted in the aircraft log book, including to tal flight hours, description of work accomplished, and the signature of the authori zed maintenance technician returning the sUAV to service. HAZON SOP (Chapter 1, Para 111).

Each sUAS operated under the proposed exem ption shall comply with all manufacturer System and Safety Bulletins.

HAZON technicians will receive and document training referenced in the manufacturer’s operations manual.

HAZON technicians shall make a record entry in the sUAS logbook or equivalent

document of the corrective action taken against discrepancies discovered between inspections.

Before conducting operations, the radio freque ncy spectrum used for operation and control of the sUAS shall comply with the Federa l Communications Commission (FCC) or other appropriate government oversig ht agency requirements.

DJI Phantom 2

HAZON seeks an exemption to operate DJI Phantom 2 sUAS, for compensation or hire. The DJI Phantom 2 is comprised of a quad rotor unmanned aircraft and a handheld ground

control station. The Phantom II has a maxi mum gross weight of approximately 2.8 pounds, diameter (rotor span) 23.75 inch es, width of 12.5 inches, and height of 8.1 inches. The Phantom II is equipped with four rotors driven by four lithium polymer battery powered

electric motors.

Design and operational characte ristics are provided in DJI Phantom 2 Operating Manual (Page 35). Flight crews sha ll conduct pre-flight inspecti ons as documented in HAZON SOP (Chapter 2 Para 202) and DJI Phan tom 2 Operating Manual (Page 24).

DJI S1000+

HAZON seeks an exemption to operate a DJI-S 1000 sUAS for compensation or hire. The DJI-S1000+ is comprised of a multi-rotor unm anned aircraft and two handheld ground

control stations. The DJI-S1000 has a maximu m gross weight of approximately 24 pounds, diagonal wheelbase of 41.4 inches, and height of approximately 18 inches. The DJI- S1000 is equipped with eight rotors driven by eight lithium polymer battery powered electric

motors.

Design and operational characte ristics are provided in DJI S1000+ Operating Manual (Page 22).

Flight crews shall conduct pr e-flight inspections as docum ented in HAZON SOP (Chapter 2 Para 202) and DJI S1000+ Operating Manual (Page 4).Page 8 of 18 Draganflyer X4-ES

HAZON seeks an exemption to operate a Dr aganFlyer X4-ES sUAS for compensation or hire. The DraganFlyer is comprised of a quad rotor unmanned aircraft and two handheld ground control stations. The DraganFlyer has a maximum gross weight of approximately 5.6 pounds, diameter (rotor span) of 42 inches, widt h of 34 inches, and height of 11 inches. The DraganFlyer is equipped with four rotors driven by four lithium polymer battery powered electric motors.

Design and operational characteristics of the Draganflyer X4-ES are provided in Draganflyer X4-ES Operating Manual (Pages 77-80) and Ground Sta tion Operating Manual (Pages 75-76).

Flight crews shall conduct pr e-flight inspections as docum ented in HAZON SOP (Chapter 2 Para 202), Draganflyer X4-ES Operating Ma nual (Pages 52-54) and Draganflyer Ground Station Operating Manual (Pages 62-64).

Penguin V2

HAZON seeks an exemption to operate the Pe nguin V2 sUAS for compensation or hire. The Penguin V2 is a fixed wing brushless moto r pusher prop sUAS. It has a wingspan of 67.7 inches and a length of 48.5 inch es. It has a wing area of 3.9 ft 2 , and is powered by a lithium polymer battery. It has a maximum fli ght weight of 4.8 pounds. It is made of EPO foam and the wing and fuselage are reinfor ced with wood, aluminum alloy and carbon fiber piping. It has an observed normal cruise air speed of about 25 mph. Design and operational characteristics of the Penguin are provided in the Penguin V2 Operating Manual (Page 2).

Flight crews shall conduct pr e-flight inspections as docum ented in HAZON SOP (Chapter 2 Para 202) and Penguin Oper ating Manual (Pages 9-10).

FireFly 6

HAZON seeks an exemption to operate the Fire Fly 6 sUAS for compensation or hire. The FireFly 6 is a hybrid sUAS that can conduct ve rtical take offs and landings (VTOL) and

then can transition to conventional horizontal fl ight. It is powered by six brushless motors and two to four lithium polymer batteries. It has a wingspan of 60 inches and a length of

37.4 inches with a maximum f light weight of 9.0 pounds. The FireFly 6 has a normal cruise air speed of 30 mph, and a maximu m air speed of 57 mph during conventional horizontal flight.

Flight crews shall conduct pr e-flight inspections as docum ented in HAZON SOP (Chapter 2 Para 202) and FireFly 6 Operating Manual (Page 36).Page 9 of 18 RV Jet

HAZON seeks an exemption to operate the RV Jet sUAS for compensation or hire. The RV Jet is a pusher propeller flying wing powered by a lithium polymer battery and a brushless motor. It features 2 wingspans ( 76.7 inches or 61 inches) and is 25.7 inches long. It can reach flight times in excess of 45 minutes, and it carries the payload in a nose mounted non-stabilized camera gimbal. Desi gn and operational characteristics of the Penguin are provided in the RV Je t Operating Manual (Pages 1-12).

Flight crews shall conduct pr e-flight inspections as docum ented in HAZON SOP (Chapter 2 Para 202).

DJI Phantom 1

HAZON seeks an exemption to operate DJI Phantom 1 sUAS, for compensation or hire. The DJI Phantom 2 is comprised of a quad rotor unmanned aircraft and a handheld ground

control station. The Phantom 1 has a maximu m gross weight of approximately 2.6 pounds, and a diagonal (motor center to motor center) diameter of 13.8 inches. The Phantom 1 is equipped with four rotors driven by four lithium polymer battery powered electric motors.

Design and operational characte ristics are provided in DJI Phantom 1 Operating Manual (Page 16). Flight crews sha ll conduct pre-flight inspecti ons as documented in HAZON SOP (Chapter 2 Para 202) and DJI Phan tom 1 Operating Manual (Pages 4-5).

DJI Inspire 1

HAZON seeks an exemption to operate the Insp ire 1 sUAS for compensation or hire. The DJI Inspire 1 is comprised of a quad rotor unmanned aircraft and up to two handheld ground control stations. The In spire 1 has a normal flight weight of approximately 6.5 pounds. Its dimensions are 438mm by 451mm by 301mm. The Inspire 1 is equipped with four rotors driven by four lithium pol ymer battery powered electric motors.

Design and operational characte ristics are provided in DJI Inspire 1 Operating Manual (Pages 57-59). Flight crews shall conduct pr e-flight inspections as documented in HAZON SOP (Chapter 2 Para 202) and DJI Insp ire 1 Operating Manual (Page 49).

Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including information such as: the level of airman certificate held; any applicable training re lated to the operation; and any minimum hours of flight experience required by the PIC(s), both total fli ght time and the time with the particular UAS. If the operation would use vi sual observers, petiti oners should describe their roles and qualifications.Page 10 of 18 5. Petitioners should describe the medical standards and certifica tion of the PIC(s) directly responsible for the op eration of the UAS.

All HAZON Flight Crews, includ ing PIC and Visual Observers (VO), will be qualified as directed by HAZON SOP (Chapter 1, Para 108).

All flight crew members, including PIC and VO, will have an understanding of, and comply with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, applicable to the airspace where th e sUAS will operate. Specifically all flight crew members will receive training on the ru les and responsibilities described in 14 CFR Part 91 Sections 91.111, 91.113 and 91.115 regarding cl oud clearance, flight visibility and the pilot controller glossary, including standard ATC phraseology and communication.

The PIC must possess at least a current priv ate pilot certificate and third class medical

certificate. The PIC must also meet the flight review re quirements specified in 14 CFR

Section 61.56 in an aircraft in which the PI C is rated on his/her p ilot certificate.

Prior to operations conducted for the purpose of sUAS Flight Crew training (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), a minimum of 25 hours of tota l time as a sUAS pilot and at least ten hours logged as a sUAS pilot with similar s UAS type (fixed wing or rotary). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, pr oficiency, and experien ce building flights are requested to be conducted under this grant of exception to accomplish the required flight cycles and flight time. Duri ng training, proficiency, and e xperience building flights, all persons not essential for flight operations will be considered non-participants and the PIC will operate the sUAS with appr opriate distance from non-partic ipants in accordance with

14 CFR Section 91.119.

Prior to operations conducted for the purpose of sUAS Flight Crew training (or similar operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR Section 61.51(b), a minimum of five hours as a sUAS PIC operating the make and model of the sUAS to be utilized for operati ons under this requeste d exemption, and three take-offs and landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and landing currency flight s are requested to be conducted under this grant of exemption to accomplish the require d flight time and 90 day currency. During training, proficiency, experience building, and take-off and landing currency flights all personnel not essential for flight operations are considered nonpart icipants, and the PIC must operate the sUAS with appropriate dist ance from nonparticipants in accordance with

14 CFR Section 91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. This condition and limitation is consistent with all FAA approved Exemptions.Page 11 of 18 Section 4: Operations of sUAS

Regarding the Operation of the Unmanned Aircraft

6. Petitioners should fully describe thei r intended UAS operation(s). Petitioners should describe how the proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at least equivale nt to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure public safety, which includes persons and property both in the air and on the ground. This can be described in the petition, in an Operations Manual, or similar document. NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, NAS safety considerations, and the safety of the non-participating persons and property during the operational period and within the operational area.

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimum flight visibil ity and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an Operations Manual,

or similar document.

The sUAS shall remain clear and yield the right of way to all other manned aviation operations and activit ies at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes report ed to ATC will be in feet.

The multi-rotor sUAS shall not be flown at a ground speed exceeding 30 mph.

Fixed wing and hybrid sUAS shall be flown at a ground speed not to exceed the maximum design limitation air speed of 57 mph as stated in the operating manuals.

sUAS Operations will be conducted under vi sual meteorological conditions (VMC). The sUAS will not be operated less than 500 feet be low or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

If the sUAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned ope rating area and land or be recovered in

accordance with HAZON SOP.

The sUAS PIC must abort the flight in the ev ent of unpredicted obstacles or emergencies in accordance with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (conside ring wind and forecast weather conditions) there is e nough power to fly at normal crui sing speed to the intended landing point and land th e sUAS with 25% battery power remaining.Page 12 of 18 The sUAS operated in accordance with this proposed exemption shall be identified by serial numbers, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

The sUAS documents required under 14 CFR 91. 9 and 91.203 shall be available to the PIC

at the Ground Control Station of the sUAS anytime the aircraft is operating. Those

documents shall be available to the Administ rator or any law enforcement official upon
request.

Any sUAS incidents, accidents or flight opera tions that transgress the lateral or vertical boundaries of the operational area as defined by th e applicable COA shall be reported to the FAA’s UAS Integration Office (A FS-80) within 24 hours. Acci dents shall be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB

Web site: www.ntsb.gov

.

Unless otherwise specified in this petition, the sUAS PIC, and the sUAS operations shall comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61

and 91.

8. Petitioners should describe the characteristics of the ar ea of intended operation(s) and the associated potential hazards, in accor dance with the statutory mandate under Section 333 regarding proximity to populated areas. These issues can be addressed in the petition, an Operations Manual, or similar document.

The sUAS shall not be operated over congested or densely populated areas. These areas include but are not limited to the yellow ar eas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectiona ls), or Terminal Area Charts (TAC). Each

work site will also be eval uated based on local conditions.

Operations of sUAS may be conducted at dist ances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary; but never so close to present an undue hazard. This is consistent with Exemption No. 11138.

Operations of sUAS may be conducted at di stances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such pe rmission, and the PIC makes a sa fety assessment of the risk from operations and determines that it does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at leas t 500 feet from all nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipati ng persons from the sUAS and/or debris in the even t of an accident. HAZON shall ensure that nonparticipating persons remain under such pr otection. If a situation arises wherePage 13 of 18 nonparticipating persons leave su ch protection and are within 500 feet of the sUAS, flight operations will cease immediately. This is consistent with Exemption No. 11138.

All operations of sUAS sh all be conducted with the permission from the land

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

9. Petitioners should describe if they intend to operate in the pr oximity of any airports, in accordance with the statutory mandate under Sec tion 333 regarding proximity to airports.

The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the ope ration is conducted in accordance with a NOTAM as required by the operator’s COA. Th e letter of agreement with the airport management will be made available to the Administrator upon request. This is consistent with Exemption No 11159.

10. The UAS must be operated w ithin visual line-of-sight (V LOS), in accordance with the statutory mandate under Section 333(b)(1). Pe titioners should describe how they intend to comply with his mandate.

The sUAS must be operated within VLOS of th e PIC and VO at all times. This requires the

PIC to be able to use human vision to see the sUAS unaided by any device other than corrective lenses, as specified on the PI C’s FAA issued medical certificate.

All sUAS operations must utilize a VO. Th e VO may be used to satisfy the VLOS requirement as long as the PIC always main tains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC and VO must be designated before the flight and cannot transfer hi s or her designation for the du ration of the flight. The PIC must ensure that the VO can perform the f unctions prescribed in HAZON’s SOP (Chapter 1, Para 103).

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not be conducted during night as defined in 14 CFR 1.1.

11. Petitioners should describe any procedur es they would implem ent for conducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the planned ope ration can be completed safely. These procedures can be addressed in the petiti on, an Aircraft Flight Manual, Operations Manual, or similar document.

HAZON will conduct preflight safety risk assessments to determine that the sUAS is in a condition for safe flight (14 CFR Section 91.7(b)) and that th e planned operation can be completed safely. Specific procedures are addressed in HAZON’s SOP (Chapter 2, Para 202), and sUAS Operation Manuals.Page 14 of 18 12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) pr ior to operations – such as motion picture and television filming, or pipeline and powerline patrol – petitioners should describe their intended coordination in this regard for their proposed operation(s).

HAZON’s operations do not requ ire a notification to Flight Standards District Offices (FSDOs).

13. The FAA intends to require entities who obt ain an exemption under this process to also obtain a Certificate of Waiver or Aut horization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS.

HAZON shall obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this requested grant of exemption. Additionally, HAZON will request a Notice to Airmen (NOTAM) not more than 72 hours, but not less than 48 hours prior to the operation.

Section 5: Requested Exem ptions from Regulations

Considered Regulation Title Recommended Action

14 C.F.R Part 21.185 Airworthiness

Certificate HAZON recommends that in consideration of the size, weight, speed and limited operating area

associated with these aircraft and their operation, the Secretary of Transportation determines that these

aircraft meet the conditions of

Section 333. Relief is not

necessary

. 14 C.F.R. Part 45.23(b) Display of ma rks HAZON sUAV shall 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 will be as large as practicable. Relief is not necessary. 14 C.F.R. Part 61.113(a) Private pilot privileges and

limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with

limitations and conditions specified in this petition.Page 15 of 18 14 C.F.R. Part 61.133(b) Commercial pilot privileges and

limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with

limitations and conditions specified in this petition. 14 C.F.R. Part 91.7(a) Civil Aircraft

Airworthiness HAZON recommends that in consideration of the size, weight, speed and limited operating area

associated with this aircraft and its operation, the Secretary of Transportation determines that these

aircraft meet the conditions of

Section 333. Relief is not

necessary

. 14 C.F.R. Part 91.9(b)(2) &(c) Civil Aircraft Flight Manual, Marking,

and Placard Requirements The FAA has previously determined

that relief from these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. Relief is not

necessary

. 14 C.F.R. Part 91.103 Preflight Action HAZON will perform . Relief is not

necessary

. 14 C.F.R. Part 91.109(a) Flight Instru ction HAZON will conduct all flight training through procedures specified in Training Instruction during dedicated training sessions. Based on previous decisions made by the FAA for sUAS petitions regarding this regulation, relief is
not necessary. 14 C.F.R. Part 91.119(c) Minimum Safe

Altitude Aircraft will be operated below 400 AGL, but not over congested areas. Request relief with limitations and conditions specified in this petition.14 C.F.R. Part 121 Altimeter Settings The proposed aircraft have a

barometric altimeter and GPS derived altitude capabilities.

HAZON recommends that the

altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations. Request

relief with limitations and conditions specified in this petition. 14 C.F.R. Part 91.151(a) Fuel Requirements

in VFR Prior relief has been granted for

manned and unmanned aircraft to operate at less than prescribed

minimums. Request relief with

limitations and conditions specified in this petition. 14 C.F.R. Part 91.203(a) and (b) Certifications Required Original intent of these regulations was to display an aircraft’s airworthiness, certification and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, relief is not necessary

. 14 C.F.R. Part 91.405(a) Maintenance Required Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.407(a)(1) Operation after

Maintenance Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.409(a)(1) and (2) Inspections Request relief with limitations and conditions specified in this petition. 14 C.F.R. Part 91.417(a) and (b) Maintenance

Records Request relief with limitations and conditions specified in this petition.

Page 16 of 18Page 17 of 18 Public Interest

HAZON’s operations of sUAS to conduct sUAS flight crew training in realistic outdoor settings will be a significant improvement over flight training inside buildings. For safety reasons, it is essential for pers pective sUAS flight crew to train in the environment and conditions they will encounter during flight operations for compensation or hire. Some examples include flying in proximity to struct ures, over farmer’s fields, in windy and gusty conditions, and in hot and cold environments. Although indoor training should be a part of any complete training program, HAZON will us e battery-powered sUAS in outdoor venues

that serve as safe and effici ent alternatives to only conducting training inside buildings. The flight data, inspection results, recorded observations and lessons learned from these operations will be compiled to further enhance its current safety program.

The applicant proposes that the exemptions request ed herein apply to civ il aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the propos ed operations represent a significant and real safety enhancement to the limited training of sUAS flight crews restricted to inside buildings only.