December 7 , 2015

U.S. Department of Transportation Docket Operations, M - 30 1200 New Jersey

Avenue, SE Room W12 - 140, West Building Ground Floor Washington, DC 20590 - 0001 Re: **Petition of Scarlet Valley Logistics**  **for an Exemption Pursuant to Section 333 of the**  **FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System** 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, Scarlet Valley L ogistics (“ Petitione r”) hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the following aircraft:

 Yuneec T yphoon Q500  Sense Fl y eBee RTK  3DR Solo  3DR Iris  Delair
- Tech DT 18  Precision Hawk Lancaster Hawkeye Mark III  Microdrone MD4
- 200  Aeryon Scout  Aeryon Sky

ranger  DJIPhantom 3  DJIInspire  DJIS 800/900/ 1000  DJIMatrice  Multirotor G4 Skycrane  Lockheed Martin Indago  QuadH2O Multirotors HexH2O  Blade Chroma  Ascent AeroSy stems Sprite  Trimble UX5 Where all equipment is being referenced they will be referenced as (“THE EQUIPMENT”). **Summary Grant Approval Request** The petitioner requests the agency issue a summary

grant for this application. The EQUIPMENT has been approved on numerous petitions. Inaddition the petitioner is requestingto utilize the UAS/UAV for the same purposes as over 1,000 other exemptions that pertain to

videograph y and photography. **I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED**  Scarlet Valley

L ogistics requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.11 ;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a);  14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  14 C.F.R § 91.103;  14 C.F.R § 9 1.109(a);  14 C.F.R § 91.119;  14 C.F.R § 91.121;  14 C.F.R § 91.151(a) ;  14 C.F.R § 91.203 (a) & (b);  14 C.F.R § 91.405(a);  14 C.F.R § 91.407(a)(l);  14 C.F.R § 91.409(a)(2);  14 C.F.R § 91.417 (a) & (b). **II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS**  This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspace sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft s ys tem where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national security based on the following consideratio ns:
 The size, weight, speed and operational capability ;  Operation in proximity to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency ’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701 - 44716, et seq. A party requesting an exemption must explain the reasons wh y theexemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81. **III. DESCRIPTION OF**  **SCARLET VALLEY LOGISTICS AND**  **ITS SERVICES**  Scarlet Valley

L ogistics intends to utilize UAV's in order to provide aerial imaging, photograph y, videography and cinematography . The contact information for Scarlet Valley L ogistics is as follows: Scott L aird Owner Scarlet Valley Lo gistics 2228 Canterbury

Drive Mechanicsburg, PA 17055 **IV. DESCRIPTION OF PROPOSED**  **UAS OPERATIONS**  Petitioner is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to utilize UAS to conduct aerial operations for clients including aerial photography /videography

services, with a wide variety of applications, to public and private individuals and businesses . These include but are not limited to utilities, railroad transportation , pipeline transportation , oil
- field services , petro/chemical/m anufacturing, construction, agriculture , home and roof inspections, bridge inspections, power line inspections, inspections for real estate claims , education, surveying , flight training, commercial & residential real estate, surveying, land & property mapping, landscap ing , news, law enforcement, advertising & marketing, utility infrastructure , search & rescue, and agriculture
.

**A. The**  **Aircraft** Scarlet Valley

L ogistics hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the following aircraft:

 Yuneec T yphoon Q500  Sense Fl y eBee RTK  3DR Solo  3DR Iris  Delair
- Tech DT 18  Precision Hawk Lancaster Hawkeye Mark III  Microdrone MD4
- 200  Aeryon Scout  Aeryon Sky

ranger  DJIPhantom 3  DJIInspire DJIS800/900/1000

 DJIMatrice  Multirotor G4 Skycrane  Lockheed Martin Indago  QuadH2O Multirotors HexH2O  Blade Chroma  Ascent AeroSy stems Sprite  Trimble UX5 **Yuneec Q500 Typhoon** The Q500 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone s ys tems. The Q500 UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. It is manufactured b y Yuneec, Inc. and has the manufactur er ’ s model designation Q500 Ty phoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery
. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that is not to be used for flight by the PIC. The UAS has the ability

to link with a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. 1. Aircraft a. Dimensions i. Height 240mm (9.45 in) ii. Width 420mm (16.54 in) iii. Diagonal Length W\O Rotor Blades 565mm (22.2 in) iv. Propeller/Main Rotor Diameter 330mm (13.0 in) b. Flight Time up to 25 minutes c. Weight with Battery

and Payload 60.0 oz (1700g) d. Weight without Battery and Payload 40.0 oz (1130g) e. Battery 5400mAh 3S 11.1V L i Po (included) f. Charger 3S 11.1V L iPo DC Balancing Smart Charger with AC Adapter (included) g. Transmitter 10 - channel 2.4GHz with 5.8GHz video downlink (included) h. 3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home i. Maximum Flying Height Default 122m ( 400ft) above Ground Level (Adjustable via the Ty

phoon GUI) j. Maximum Rotation Rate 65°/s k. Maximum Roll Angle 35° l. Operating Temperature Range −5°C to 80°Cm. Radio Control Frequency Band 2.4GHz n. Max. Descent Speed 2m/s o. Max. Flight Speed 8m/s 2. Gimbal a. Ty pe CGO3 b. Weight 6.9oz (195g) c. Focusing Sy stem Aerial Optimized Fixed Focus d. Field of View 115° e. Video Transmission Range i. FCC Compliance: Up to 600m (1968.5 ft) ii. CE Compliance: Up to 300m (984.252 ft) with ST10 f. Video Resolution i. UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS ii. FULL HD: 1080p at 24/25/30/48/50/60/120FPS g. Photo Resolution 12 Megapixels h. Storage (memory) microSD Class 10 ~ 4 to 128 GB i. Control Angle Accuracy ±0.02° j. White Balance Automatic or manual settings k. Transmission Band 5.2GHz

– 5.8GHz l. Input/Operating Volta ge 12V m. Working Temperature −10°C

– 50°C n. Storage Temperature −20°C

– 60°C o. Angular Vibration Range ±0.02° p. Control Range i. Pitch: between −90° and 0° ii. Yaw: between 0° and 360° q. Microphone Yes r. Camera Lens 0.6in (14mm)/f2.8 (1.4in/35mm)

— No distortion s. Sensor 1/2.3 ′′ CMOS 3. Personal Ground Station a. Ty pe ST10+ b. Operating S ys tem AndroidTM c. Number of Channels 10 d. Control Transmission Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Warning: You Must Follow Local Law s and Maintain Visual L ine of Sight of Aircraft at All Times e. Robust Radio Control Modulation Yuneec Protocol f. Video L ink Frequency Band 5.8GHz g. Video Transmission Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (98 4.252 ft) Warning: You Must Follow Local Laws and Maintain Visual L ine of Sight of Aircraft at All Times h. Flight S ys tems Telemetry Data On Screen Display Yes i. LED Backlit L CD Screen Capacitive Multi
- touch 5.5 ′′ j. Tactile (Vibrating) and Audible Feedback Yes k. Bui lt
- in L iPo Battery

Voltage / Capacity 3.6V/5200mAh 18.72Wh l. Screen Resolution 854 × 480pxm. Camera Settings White balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take pictures The Q500 has been approved for commercial operat ions in Exemption Nos. 12360, 12730 , 12684, 12680, 12637, 12833, 12923, and 12697 . **Sensefly eBEE** The Sensefl y eBee is a small (37.8 inches wingspan) an d ultra
- light (maximum take
- off weight of 1.7 pounds) platform made of flexible foam that performs pre - programmed precision aerial mapping missions thanks to the on
- board GPS and the related flight management software (eMotion) that allows the operator to safel y and efficiently plan a mission, and then monitor it in real
- time. Thanks to the embedded cam era, protected b y a foam envelope, the eBee takes a collection of high
- definition still images that are used later to generate maps and contour lines of the surveyed area. The four main characteristics of the Sensefl y eBee are: 1. Very light weight The eBee is so light that the operator can launch it by hand and let it land on almost any surface without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a controlled emergency landing) also significantl y reduces the risk of hazardous situations. Finally , the wings of the eBee are detachable and made of flexible foam with no sharp or hard edges and almost no internal strengthening structure. 2. Electric
- powered The eBee is electric powered. A brushless engine technology makes it silent and reliable. The propeller is attached with a rubber band to the body of the plane so that it can easil y flex away in case of contact with any object. 3. Semi
- automatic flight The artificial intelligence incorporated within the eBee autopilot sy ste m continuously anal yz es data from the In ertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator. 4. Option for m anual control Additionally , the eBee provides an override capability that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and take manual control of the aircraft should it become n ecessary to respond emergent circumstances , thanks to the remote controller provided with the sy stem. Technical S pecifications A. Hardware a. Weight (inc. supplied camera) Approx. 0.73 kg (1.61 lb) b. Wingspan 96 cm (38 in) c. Material EPP foam, carbon structure & composite parts d. Propulsion Electric pu sher propeller, 160 W brushless DC motor e. GNSS/RTK receiver L1/L2, GPS & GLONASS f. Battery 11.1 V, 2150 mAhg. Camera (supplied) WX (18.2 MP) h. Cameras (optional) S110 RGB, S110 RE, S110 NIR i. Carry case dimensions 55 x 45 x 25 cm (21.6 x 17.7 x 9.8 in) B. Operation a. Maximum flight time 40 minutes b. Nominal cruise speed 40 - 90 km/h (11
- 25 m/s or 25
- 56 mph) c. Radio link range Up to 3 km (1.86 miles) d. Maximum coverage (single flight) 8 km /3 mi (at 974 m/ 3,195 ft altitude AGL) e. Wind resistance Up to 45 km/h (12m/s or 28 mph) f. Ground Sampling Distance (GSD) Down to 1.5 cm (0.6 in) per pixel g. Relative orthomosaic/3D model accuracy 1 - 3x GSD h. Absolute horizontal/vertical accuracy (no GCPs) Down to 3 cm (1.2 in)/ 5 cm (2 in) i. Multi
- drone operation Yes (inc. mid
- air collisio n avoidance) j. Automatic 3D flight planning Yes k. Linear landing accuracy Approx. 5 m (16.4 ft) The eBEE has been approved for commercial operations in Exemption Nos. 12710, 12673, 12656, 12647, 12619, 12571, 12577, and 12697 . **3DR SOLO** The SOLO is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone s ys tems. The SOLO UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. Specifications: 1. General a. Weight: 3.3 lb / 1.5 kg. b. With Solo Gimbal and GoPro: 4 lb 2. Performance a. Maximum Speed : 55 mph / 88.5 km/h b. Maximum Altitude : 400' / 121.9 m AGL c. Flight Time : Up to 25 minutes 3. Flight Control Sy stem a. Model : Pixhawk 2 b. Software : APM flight control software and GPS 4. Handheld Transmitter a. Display : Color Screen for menu and live flight telemetry b. Battery : Lithium
- poly mer Capacity: 5200 mAh . Voltage: 14.8 VDC L ife: Up to 4 hours c. The 3DR Solo remote controller has an operating frequency of 2.4 GHz for telemetry and control. d. Maximum transmission distance: up to 2,500 ft (outdoors and unobstructed) 5. Mobile App a. Sy stem Requirements: Wi
- Fi enabled iOS or Android mobile deviceb. Wi
- Fi Range : Up to 2640' / 805 m (depending on environment)

6. FPV and Monitoring a. Video Downlink Latency: 180 ms b. Connectivity : 1 x HDMI output on Transmitter 7. Components a. Rotors : 4 x 10 x 4.5" / 25.4 x 11.4 cm self
- tightening props b. Motors Velocity

Constant: 880 kV c. Gimbal Compatibility : Solo Gimbal for HERO3+ and HERO4 GoPro Camera 8. Flight Battery a. Model : Solo Battery

Voltage14.8 VDC b. Lithium
- poly

mer Capacity

5200 mAh The 3DR Solo has been approved for commercial operations in Exemption Nos. 12462, 12494, 12441, 12544, 12433, and 11935 . **3 DR IRIS**  The IRI S is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The IRI S UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. 1. Performance a. Payload Capacity Up to 14.1 oz 1400 g b. Flight Time
- Ty

picall y 16 to 22 minutes (depending on payload weight and other factors) 2. Flight Control Sy stem a. Processor - 32 - bit Pixhawk with Cortex M4 CPU b. GPS
- uBiox GPS with integrated magnetometer c. Receiver
- 3DR Radio, 915 MHz 3. Components a. Rotors 2 x CCW: 9.5 x 4.5" I 24.1 x 11.4 em tiger motor multi
- rotor; self
tightening counterclockwise rotation and 2 x CW: 9.5 x 4.5" I 24.1 x 11.4 em tiger motor multi
- rotor; self
- tightening clockwise rotation b. Motors - 4 x920 KV c. Mount - Integrated GoPro camera mount with vibration dampener d. Flight Battery
- 3S 5100 mAh L iPo 4. Telemetry

Radio a. Frequency - 915 MHz (FCC complaint b. Transmit Power
- Up to 100 mW at 20 dBm (adjustable) c. Receiver Sensitivity
- 25mA d. Receive Sensitivity
- - 117 dBm e. Protocol
- MAVL ink f. Transmission Method 2
- way full
- duplex communication through adaptive TOM Frequency

Hopping Spread Spectrum {FHSS) g. Parallel/Serial Translation
- UART interface {3.3 VDC) I transparent serial link h. Error Corr ection
- Corrects up to 25% of bit errorsi. Firmware
- Open
- source SIK firmware j. Software Requirements
- Configurable through Mission Planner and APM Planner k. Compatible Devices
- Android tablet with OTG (on the go) support and Windows desktop computer l. Connectivity i. Per Radio (Two Included): ii. 1 x Micro
- USB port iii. 1 x 6 - pin DF13 connector iv. 1 x RP - SMA for antenna m. Power Requirements
- 3.7 to 6 VDC {from USB or DF13 connector) n. Dimensions
- 1.1 X 2.2 X 0.5" /26.7 X 55.5 X 13.3 mm 5. General a. Dimensions i. Height: 3.9" /100 mm ii. Motor - to - Motor Dimension: 21.7" /550 mm b. Weight
- With Battery : 2.8 lb /1.3 kg The 3DR IRI S has been approved for commercial operations in Exemption Nos. 12539, 12833, 12579, 12580, 11494A, 12569, 12544, 12488, 12495, 12496, 12461, and 12204. **DELAIR DT -**  **18** The DT
- 18 was conceived and manufactured by Delair
- Tech. Over ten DT
- 18 have been sold to date. Globall y, the DT
- 18 has completed 521 flights for a total of 231 flight hours and 12,600 km covered. The DT
- 18 is hand launched and lands on its belly. It ty picall y lands with a 5m precision. Every aspect of the landing is automatic. It is the first and only UAS certified b y the Direction Generale de l’Aviation Civile (DGAC) for flight beyond line of sight (BLOS) up to 15km from the base station in the French civilian airspace (Scenario S4). However, flights pursuant to the requested exemption will be operated within visual line of sight (VLOS) of the pilot in command (PI C).3 The DT
- 18 is equipped with six control surfaces. It has one aileron on each wing, one flap on each wing, and two ruddervators located on the empennage. The flaps are only used on landing. They are also automatically

deplo yed in case of an over speed to act as speed brakes
. 1. Ty pe of Motors Brushless, outrunner 2. Cruise Speed 31 mph (50 km/h) 3. Max speed 49.7 mph (80 km/h) 4. Power 4S 8900mAh L i
- Po, 270W Max Power 5. Weight 4.4 lbs (2kg) 6. Maximum Endurance 120 minutes 7. Wingspan 5.9 ft/1.8m 8. Fuselage length 3.9 ft/1.2 m 9. Takeoff/landing Hand or catapult/belly or net10. Wind resistance 31 mph (50 km/h)

11. C2 range 25 mi/40 km (857 MHz) 12. Data link range 9.3mi/15 km (5.8 Ghz) The DT
- 18 Ground Control Station (GCS) serves as the operator interface, coordinating the mission and communication functions including mission planning, near real
- time mission progress, video display , and function monitoring. The GCS consists of a laptop and mission planning/execution software (SolApp), a case with a built
- in joystick and slider, a back
- up controller, a steerable command and control link antenna, and a steerab le data link antenna. The SolApp program conducts mission planning for the DT
- 18, with complete route planning to include way

points, identify

No - Fl y zones, and take into consideration the terrain height. All of the takeoff and landing is planned in SolApp . The mission planning information is up
- loaded to the DT
- 18 prior to flight. SolApp also has the ability to change and upload all mission planning during flight via the Command and Control link. As part of the mission execution, SolApp has a check
- list that confirms the following:

 DT - 18 assembl y  Internal sensor (magnetometer, GPS, etc) calibration  Payload functionality  Weather inputs  Carrying case controller (joy stick and slider) calibration  Antennae placement and calibration  Uploading of mission inform ation to DT
- 18  During flight, SolApp provides complete management of the DT
- 18 mission.  The following is provided during flight to the operator:

o Moving map showing the location of the DT
- 18 o Speed o Heading o Altitude o Climb rate o Link status o Battery

status o All safety s ys tems and alarms The DT
- 18 s ys tem operates under autopilot during missions, or can be controlled by the joy stick and slider built into the GCS. The joy stick and slider operate through the command control link of the GCS. The DT
- 18 sy stem also inc ludes a back
- up controller, which operates on a separate link from the GCS. The operator can b ypass the DT
- 18 autopilot with the back
- up controller. The command and control and data link antennae are part of the GCS. The two antennae are mounted on a moto rized steerable mount that will automatically track the location of the DT
- 18. The main command and control link between the DT
- 18 and the GCS operates at a frequency of915 MHz (I SM Band). This link provides all the DT
- 18 flight information back to the G CS and

provides any updates to the mission from the GCS to the DT
- 18. The DT
- 18 uses the XBee
- Pro 900HP Modem, which has FCC re gulatory approval. The data link on the DT
- 18 allows for the payload information to be transmitted in near real
- time between the DT - 18 and the GCS. The data link operates at a frequency of 5.8 GHz
. The DELAIR has been approved for commercial operations in Exemption No
. 11524 . **The HAWKEYE** The Precision Hawk Hawkeye Lancaster MK - III UAS is a single electric motor fixed wing aircraft. Wing span is 1.5 m and power is delivered with a 28 cm propeller. Power source is a 12.6 volt, L ithium
- Poly

mer battery with a 3900 mah capacity. Payl oad will be various cameras and sensors. Gross weight will remain below 6 lbs regardless of paylo ad. Flight is controlled b y two (2) on board computers with one dedicated to vehicle control and stability with the second computer dedicated to mission control and vehicle status monitoring. The aircraft is equipped with a global positioning sy stem (GPS), In ertial Measurement Unit (IMU), and Compass that work in unison to stabilize the aircraft and render safety features. The aircraft can be programmed to not fl y above 400 feet AGL and to not fly outside of a pre
- determined flight zone. These s ys tems will also initiate the failsafe function. If the aircraft loses the signal from the transmitter, the GPS sy stem will automatically initiate the failsafe mode and fly the aircraft back to a pre - determined location and land automatically
. The HAWKEYE has been approved for commer cial operations in Exemption Nos. 11273 , 1 1573 , 11551 , and 11345. **MD4** The microdrones md4
- 200 UAV is a miniaturised VTOL aircraft (Vertical Take Off and Landing). It can fl y b y remote control or automatically using our GPS Waypoint navigation software
. The md4
- 200 aerial vehicle consists of a carbon fiber body , boasts a fl yi ng time of 30 minutes and can carry

a load of up to 250 g. Rain, snow and dust pose no particular problem for microdrones UAVs. The ultra
- lightweight robust and weather

– resistant carbon fibre body enables the md4
- 200 to reach an operating height of up to 1000 met er s - ideal for aerial photography and aerial inspections. 1. Technical Specifications a. Vehicle mass: 800g b. Payload mass (recommended): 150g c. Payload mass (maximum): 250g d. Maximum take
- off weight: 1100g e. Battery : 4S L iPo, 14.8V, 2300mAhf. Climb rate: 7.0 m/s

g. Cruising speed: 8.0 m/s h. Peak thrust: 15.5N i. Endurance: i. up to 30 min ii. Endurance can alway s vary with wind/weather, payload and age of battery iii. with 150g payload the average is 15min j. Flight radius: i. max. 500m on C&C ii. max. 6000m on WP k. Service ceiling: 2000m ASL 2. Operational Conditions a. Temperature range: - 10..40°C b. Humidity : max 90% r.H. c. Wind tolerance: i. steady pictures up to 4 m/s ii. max. up to 8 m/s d. Dimensions i. Diameter: 540mm ii. Height: 230mm The MD4 has been approved for commercial operations in Exemption No. 11171A . **Aeryon SCOUT**  **and RANGER** The Scout and Sky

Ranger are quad
- copter typ e vertical takeoff and landing small UAS, with four rotors mounted on booms and four legs. Payloads are mounted underneath the fuselage on a gimbal mount. Communications use common frequencies and are digitall y encry pted, which reduces the risk of hijacking and video interception. The aircraft are controlled with a tablet based interface, reducing pilot fatigue and workload. The aircraft are piloted by

the use of a stylus, pointing to an area on a moving map display . Altitude is controlled by

using a slider bar on the touch screen interface to command the aircraft to climb or des cend. The sy stem is full y stabilized and GPS guided. Custom or commerciall y available map data in several formats may

be used for operator orientation. The aircraft can be flown real
- time by the operator or pre - programmed to fly a series of GPS way

points. While the aircraft is fl yi ng its pre
programed flight path, the operator alway s has full control of the vehicle and can change its flight path or altitude immediately . Flight information such as position, altitude, environmental conditions, signal link strength, GPS signal strength, battery voltage, and other flight data is displayed to the operator in real time. The aircraft itself is constantly monitoring environmental and sy stem conditions and will alert the operator to any abnormalities. The aircraft have many built in failsafe mechanisms that will allow return to the point of origin and vertical landing if an emergency condition exists.The aircraft and payloads are gy ro stabilized, allowing for exceptional imaging and resolution quality at safe dist ances from infrastructure, which is essential for safe and effective inspections. The aircraft have a quick
- change payload interface with common interfaces including USB and Ethernet, which allows custom payloads to be developed. The sy stem is able to det ect the type of payload connected, and configure it and operate it appropriatel y. The payload capacity of the s ys tem is 250 g (0.55 pounds). Offered payloads include gimbal
- mounted digital still and video cameras, a near IR camera for remote sensing, a FL IR night
- vision camera, and a stabilized 10x Optical Zoom camera. **Aeryon Scout Technical Specifications** • Deploy

ment : Vertical Take
- off and Landing
• Operation : Range 1 Mile
• Operational Duration : Up to 20 Minutes
• Operational Velocity : Up to 30 mph
• Wind L imits : Up to 30 mph (Gusts up to 50 mph)
• Dimensions : 31.5 in. x 31.5 in x 7.9 in
• Max Weight : 3.4 pounds
• Power Source : 11.1V Intelligent LiPo Battery **Aeryon Sky Ranger Technical Specifications** • Deploy

ment : Vertical Take
- off and Landing
• Operation Range : 2 Miles
• O perational Duration : Up to 50 Minutes
• Operational Velocity : Up to 30 mph
• Wind L imits : Up to 40 mph (Gusts up to 55 mph)
• Dimensions : 40 in. x 40 in. x 9.3 in.
• Max Weight : 5.3 pounds
• Power Source : 14.8V Intelligent LiPo Battery **Command and Control Systems** The Aeryon Ground Control Station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. Displayed on GCS:
• Position
• Navigation Route
• Altitude
• Heading
• Battery

voltage and time remaining• GPS signal strength

• Radio link strength
• Aircraft status to include error messages or fai lures
• Date/time
• Sensor position and orientation relative to sUAS On
- board Flight Instruments

– The sUAS is equipped with an Inertial Navigation Sy stem (3
- axis gy roscope, magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement. On

– board computer s ys tems

– The sUAS is equipped with on
- board computer sy stems to monitor (sensors, battery , etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry , etc.). On
- board guid ance and navigation equipment

– The sUAS can operate autonomously ; it does not require any input from ground
- based equipment, or from the pilot to hover in place. Frequency

Allocations

– 900 MHz and 2.4 GHz. Fly away protection

– To prevent a “fl y away” or other potentially dangerous situations, the aircraft emplo ys a s ys tem of fail
- safes that will either return the aircraft to its home origin point or land the aircraft in its present position
. Takeoff and Landing

– The sUAS has vertical lift autonomous launch and recovery . A Landing Zone (“LZ”) is designated b y the operators and identified in the GCS software. For launch procedures the aircraft will take off and hover 3 meters directl y above the LZ and hold until further operator instruction is given. The aircraft will automatically adjust for wind during this period. Navigation Sy stem

– Specific maps, such as air sectional and geographic maps, can be downloaded to the display screen and overlaid with GPS positional data. Way points can be created before and during flight operation creating specific locations and sequences for the aircraft. Redundant Sy stems

– The sUAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal sy stem performance, a singl e sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. **Emergency Procedures and System Failures** Engineered Failsafe Mechanisms Lost CommunicationsThe sUAS does not need constant signal from the t ablet to continue fl yi ng. Communication

outages are detected b y the sy stem and are reported to the pilot. During the communication outage the aircraft will hover in place, climb to a pre
- set safe altitude, and then fly to its takeoff location. If communication is still not established the aircraft will descend slowly and make a landing at the point of takeoff. All of this is accomplished without input from the operator. If the aircraft receives interference or another overpowering signal, the s ys tem will simply go into its lost communication procedure as stated above. It will climb to a safe altitude, fly home and land. Communications Data Security All communication links are encry pted. The communication sy stem and protocol is designed in such a way

that control of the aircraft cannot be taken over b y accident. The video feed is also encry pted. Any unauthorized person attempting to receive the video would see a scrambled picture. Battery L ife The battery

voltage and flight time remaining are displayed to the operator throughout the flight. When 3 minutes of flight time is remaining, a warning is given to the operator. If the operator does not bring the aircraft home, the sy stem will return home (takeoff point at a safe transit altitude) on its own. The sUA S is equipped with an intelligent battery monitoring s ys tem that will allow it to leave its present position and fl y home with reserve battery power to make a safe landing under current environmental conditions. Ignition Source Resistant The aircraft are equipped with a sealed LiPo battery pack and is operated by 4 brushless electric motors. The brushless motors, by their design, do not spark or arc while being operated. The operating temperature of the motors and the battery is extremel y low. Potential C omponent Failures The aircraft have highl y engineered s ys tems monitoring software. Examples include battery health and temperature, voltage going to the motors, GPS accuracy , magnetic anomalies, vibration sensing, and yaw detection. There is a warning pri or to any major failure, giving time to safel y manage the situation. If the failure is considered “non
- fatal,” it will return home and land. If it is considered “fatal,” it will set down immediately at its present position. Automatic pre - flight checks prev ent the UAS from taking off if problem conditions are present. Defined “No Fl y Zones” T he navigation software allows for preplanning No Fly Zones which can allow the operator to maintain clearance from any “prohibited areas.” The Scout and Sky Ranger will operate with geo - fencing. This technology allows the operator to effectivel y put a GPS based perimeter around the area of operations which will keep the aircraft in a designated “operational box” regardless of normal or emergency operations. The geofence is custom designed and can be adjusted based on each location of operation. Visual L ine
- of

- Sight LossAll flight operations will be conducted with the sUAS within visual sight of the pilot. I f for some

reason the pilot’s view becomes obstructed and line
- o f
- sight is lost, the aircraft will hover in position until line
- of

- sight is reestablished. The SCOUT and RANGER have been approved for commercial operations in Exemption No s. 11209, 11240, 11265, 11252, 11259, 11436, 11576, 11673, 11665, 11830, 11230A, 12077, 11447B, 12140, 12387, 12195, 13076, 12658, and 11534 . **Phantom 3** Petitioner will operate the DJ I PHANTOM 3 (the “PHANTOM”) manufactured by DJ I Innovations. The PHANTOM is a battery operated quadcopter with a maximum flight time of 25 minutes. The vehicle weighs approximately 2.82 pounds with a maximum takeoff weight of approximately 3 pounds. It has fixed landing gear, vibration dampers, small frame air incline and minimalized gimbal mount, which allows for a 94 degree of view from the camera. Although the vehicle’s ground speed has a maximum of 35 mph, it will be operated between 2 and 2 5 miles per hour, and it will operate at or below 400 feet AGL. The PHANTOM’s manufacturer specifications are shown in the Appendix of the Quick Start Guide and the USER Manuals for each airframe. The UAV/UAS/UA which Petitioner will be operating i s the DJ I Phantom 3. The inherent safety features, sophistication, programmability , GPS navigation, return home capability , airport vicinity no - fl y feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for th e purposes of this petition. This is a radio controlled UAVs that has the capacity for software upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the programming of the PHANTOM is an automatic return home feature that automatically directs the craft back to point of take
- off should communication with the transmitter be lost. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots . Maximum flight time is 25 minutes. Gross weight is 2.82 pounds. The PHANTOM has a communication link between the camera and aircraft allowing the operator or Pilot in Command (PI C) to monitor battery level, altitude (AGL), distance from PI C, camera im agery , and also control camera angle. The software for the PHANTOM allows the operator or PIC to set maximum altitude AGLfor each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGLas examples. The 400 foot maximum AGL is by default programmed into the UAV's software pre
- flight to insure compliance with FAA standards adding to the safety capabilities of this UAV. This UAV is programmed to remain in position when controls are released, maintaining altitude and GPS location. The PHANTOM has an altitude and radar monitoring function that allows the operator more precise determination of height, direction of flight and distance from the operator/PIC. The operator/PIC can monitor GPS lock status while the UAV is in flight, with the ability to anticipate loss of GPS locking so the operator/PIC can land the UAV as a precaution
.**The Inspire**

Petitioner will operate the the DJ I INSPIRE 1 (the “INSPIRE”) manufactured by DJI Innovations. The INSPIRE is a battery oper ated quadcopter with a maximum flight time of 18 minutes. The vehicle weighs approximately 6 pounds with a maximum takeoff weight of approximately 9 pounds. It has retractable landing gear, vibration dampers, small frame air incline and minimalized gimbal mount which allows for a 94 degrees of view from the camera. Although the vehicle’s ground speed has a maximum of 49 mph, it will be operated between 2 and 3 5 miles per hour, and it will operate at or below 400 feet AGL. The INPIRE’s manufacturer’s s pecifications are shown in the Appendix of the Quick Start Guide and the USER Manuals. The UAV/UAS/UA which Petitioner will be operating is the DJ I Inspire 1. The inherent safety features, sophistication, programmability , GPS navigation, return home capability , airport vicinity no - fl y feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the purposes of this petition. This is a radio controlled UAVs that has the capacity for software upgrades. It is light, less than 10 pounds including battery and camera. Incorporated into the programming of the INSPIRE is an automatic return home feature that automatically directs the craft back to point of take
- off should communication with the transmitter be lost. The Inspire has a c ruising speed of 15 knots, with a maximum speed of 42 knots. Maximum flight time is 18 minutes. The INSPIRE has a communication link between the camera and aircraft allowing the operator or Pilot in Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera imagery , and also control camera angle. The software for the INSPIRE allows the operator or PI C to set maximum altitude AGL for each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default programmed into the UAV's software pre
- flight to insure compliance with FAA standards adding to the safety capabilities of this UAV. This UAV is programmed to remain in position when controls are released , maintaining altitude and GPS location. The INSPIRE has an altitude and radar monitoring function that allows the operator more precise determination of height, direction of flight and distance from the operator/PIC. The operator/PI C can monitor GPS loc k status while the UAV is in flight, with the ability to anticipate loss of GPS locking so the operator/PIC can land the UAV as a precaution. **Spreading Wings S800/S900/S1000** The SPREADI

NG WINGS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic laptop, tablet, or smart phone s ys tems. The DJ I SPREADING WI NGS has a maximum gross weight of approximately 8.2kg, whilehaving a length of 0.9m, a width of 0.9m, a height of 0.6m, and a maximum speed of

approximately

20 knots. The DJ I SPREADING WI NGS UAS is equipped with six main electric powered rotors driven b y L ithium Poly mer batteries. The multi
- rotor can carry a payload of up to 13 pounds, and has been operated with a payload of high
- resolution DSLR cameras, infrared cameras, and video cameras for photography, videograph y, geospatial analysis and photogrammetry
. DJISpreading Wings S800 1. Specifications a. Frame Diagonal Wheelbase 800mm b. Frame Arm Length 350mm c. Frame Arm Weight (with Motor, ESC, Propeller) 356g d. Center Frame Diameter 240mm e. Center Frame Weight 550g f. Landing Gear Size 460mm(Length)×425mm(Width)×320mm(Height) (Top width: 155mm) g. Retractable Landing Gear Weight (Including Battery Tray) 1050g 2. Motor a. Stator Size 41×14mm b. KV 400rpm/V c. Max Power 500W d. Weight (with Cooling Fan) 158g 3. ESC a. Current 40A OPTO b. Voltage 6S L iPo c. Signal Frequency

30Hz ~ 450Hz d. Drive PWM Frequency 8KHz e. Weight (with Radiators) 35g 4. Foldable Propeller (1552) a. Material Engineering plastic Size 15×5.2 inch b. Weight 13g 5. Flight Parameters a. Takeoff Weight 6.0Kg ~ 8.0Kg b. Total Weight 3.7Kg c. Power Battery

L iPo (6S 、 10000mAh~15000mAh 、 15C(Min)) d. Max Power Consumption 3000W Hover e. Power Consumption 800W(@ Takeoff Weight 6.7Kg) f. Hover Time Max: 20 min (@15000mAh & 6.7KgTakeoff Weight) g. Working Environment Temperature
- 10 ~ +40 C The DJ I S800 has been approved for commercial operations in Exemption Nos. 11252 and 11225. DJISpreading Wings S900 1. Aircraft a. Diagonal Wheelbase

– 900 mmb. Frame Arm Length

– 358mm c. Frame Arm Weight

– 316g d. Center Frame Diameter

– 272mm e. Center Frame Weight

– 1185g 2. Propulsion a. Stator Size

– 41x14mm b. kV

– 400rpm/V c. Max Power

– 500W d. Weight (witch Cooling Fan)

– 158g 3. ESC a. Working Current

– 40A b. Working Voltage

– 6S LiPo c. Signal Frequency

(Hz)

– 30~450 d. Drive PWM Frequency

– 8kHz e. Weight (with Radiators)

– 35g 4. Propeller a. Size 15x5.2 inch b. Weight

– 13g 5. Flight Parameters a. Takeoff Weight Minimum

– 3.3kg b. Takeoff Weight Maximum

– 8.2kg c. Power Battery

– LiPo 6S 10Ah

– 20Ah 15C(Min) d. Max Power Consumption

– 3kW e. Hover Power Consumption

– 1kW f. Approximate Flight Time

– 20 min. g. Working Environment Temperature

– - 10C ~ +40C h. Hover Accuracy

(Ready to Fly)

– Vertical: 0.8m Horizontal: 2.5m i. Max Yaw Angular Velocity

– 200deg/s j. Max Tilt Angle

– 35deg k. Max Ascent Speed

– 6m/s l. Max Descent Speed

– 2 m/s m. Max Flight Speed

– 15m/s (NOT RECOMMENDED) The DJ I S900 has been approved for commercial operations in Exemption Nos. 11224, 11240, 11250, 11256, 11279, 11280, 11295 and 11305. DJISpreading Wings S1000 1. Frame a. Diagonal Wheelbase 1045mm b. Frame Arm Length 386mm c. Frame Arm Weight (Including Motor, ESC, Propeller ) 325g d. Center Frame Diameter 337.5mm e. Center Frame Weight (With L anding Gear Mounting Base, Servos) 1330g f. Landing Gear Size 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) 2. Motora. Stator Size 41×14mm b. KV 400rpm/V c. Max Power 500W d. Weight(With Cooling Fan) 158g 3. ESC a. Working Current 40A b. Working Voltage 6S LiPo c. Signal Frequency

30Hz ~ 45 0Hz d. Drive PWM Frequency 8KHz e. Weight(With Radiators) 35g 4. Foldable Propeller (1552/1552R) a. Material High strength performance engineered plastics b. Size 15×5.2inch c. Weight 13g 5. Flight Parameters a. Takeoff Weight 6.0Kg ~ 11.0Kg b. Total Weight 4.2Kg c. Power Battery

L iPo (6S 、 10000mAh~20000mAh 、 15C(Min)) d. Max Power Consumption 4000W e. Hover Power Consumption 1500W (@9.5Kg Takeoff Weight) f. Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight) g. Working Environment Temperature
- 10 °C ~ +40 °C 6. Gain Value Settings a. For A2 Flight Controller i. Basic: Roll 120%, Pitch 120%, Yaw 120% ii. Attitude: Roll 170%, Pitch 170%, Vertical 120% b. For WooKong - M Flight Controller i. Basic: Roll 180%, Pitch 180%, Yaw 120% ii. Attitude: Roll 180%, Pitch 180%, Vertical 120% The DJ I S1000 has been a pproved for commercial operations in Exemption Nos. 11280, 11279, 11278, 11863, 11260, 11253, 11228, 11160, and 11161. **The DJI**  **MATRICE** The MATRI CE is a battery operated quadcopter with a maximum flight time of 18 minutes. The vehicle weighs approximately 5.3 pounds with a maximum takeoff weight of approximately 7.5 pounds. The MATRI CE is a fully customizable and programmable flight pl atform. It is equipped with DJI’s eas y- to - fl y technology and optimized for easy programming through the DJ I SDK. The MATRI CE has guidance which is a revolutionary visual sensing s ys tem. With a powerful processing core, integrated visual cameras, ultrasoni c sensors, and the most advanced computer vision algorithms in the world. Guidance includes five sensor modules and one central processor. Guidance continuously

scans the nearby

environment and detects obstacles in real time. When used with a DJ I flight c ontroller, it can tell your flight system to automatically avoid collision,even at high speeds. Guidance ’ s vision positioning s ys tem is effective at altitudes of up to 65

feet (20 meters)
. DJ I ’ s new N1 flight controller keeps the MATRICE stable and resp onsive
. The MATRI CE has an upgraded version of the respected DJ I E800 electric propulsion sy stem. Four powerful, brushless motors and four lightning fast Electronic Speed Controllers are integrated into the platform, providing complete control during flight. The MATRI CE has an e nhanced GPS with a foldable mount helps track the MATRI CE’s position in real time, while enabling faster satellite acquisition, more accurate position holding and flight planning. **The SKYCRANE** The SKYCRANE is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) T he SKYCRANE is equipped with the latest MUL TIROTOR flight
- control, which allows an unprecedented flight and image stability . This is ensured by a 32 - bit p rocessor of the MULTIROTOR flight
- control with about 10 times more computing capacity, the most modern hardware components and a referenced GPS sy stem. Substantially

enhanced is the flight performance by the newl y developed engines. Brushless motors made by

Plettenberg as well as individually designed three
- blade rotors with winglets enable the most effective and s ilent uplift ever in this class. In comparable flight stability , due to the latest 32
- bit dual
- processor technology , which corrects the flight p osition 512 times per second and enables secure drone flight. No - Panic
- Fun ction allows the UAV keeps its current position and place.

 Technical range 2,000 meter min.  Autopilot with 250 meter flight radius, position hold, coming home, automatic altitude c ontrol  Brushless gears from Plettenberg with handcrafted three
- blade rotors  Li ght and unbreakable full carbon frame  Two - way

data telemetry

with language assistance  High performance flight battery (2 units)  Attitude control 512 times per second Yes  Automati c treble control 24
- bit barometric Yes  Autonomous flight max. 500 way points Optional  Auto start / auto landing assistant Optional  Battery

redundancy Yes  Cantilever beam plug s ys tem Optional  Camera suspension Optional  Digital option port (for future applications) Yes  Digital RC transmitter pilot Optional  Dimens ion Ø 114 cm, H. 50cm  D rive redundancy Yes  Emergency

L anding Yes  Device hull insurance Europe Optional Flight Control MULTIROTOR G4 Dual 32 bit Yes

 Flight Control redundancy Optional  Flight data log 128 bit  Flight training and flight practice certificate Optional  GPS flight assistant (position Hold, Coming Home) Yes  Inspection (12 months, 25 flight lines, 350 starts) Optional  L1 GPS Yes  Live
- View 5.8 GHz Diversity Yes  M ax. airsp eed 40 - 50 km/h  M ax . Flight time (ideal) 12 Minutes  M ax. Take
- off weight (ideal) 12000 g  Pack size 97x97x 25cm (demontiertes Gimbal)  Payload (incl. camera suspension and flight battery) 6500 g  Servo connectors 6  Wind stable up to 10 - 15 m/s **The INDAGO**  The INDAGO is manufactured b y Lockheed Martin. The INDAGO ‘s autopilot has a high degree of pre
- programmed control and various built
- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set f orth in the exemption application. Hands
- on experience with the INDAGO are a far more effective guarantee of flight safety than a commercial pilot certificate would be, until the FAA UAS Pilot Certificate requirements catch up to the SUAS technology
. The INDAGO‘s autopilot has an all
- digital software platform with advanced features previousl y restricted to full size unmanned aircraft. Automated features and advanced fly
- safe controls enable safe, reliable operation, as well as advanced networking capab ilities and sy stem extensibility
.  The sy stem will be flown in manual mode at all times.  Flight time and battery minutes are displayed at all times. The sy stem will return home and land automaticall y if user
- configurable limits are reached  Flight safety i s a priority, no matter the operating environment or project. SUAS offer superior safety over manned aircraft b y removing the need for people to be onboard in potentially

dangerous situations. With multiple built
- in safety features, SUAS platforms are comp arable to manned operations with respect to safety  The INDAGO automatically detects potential issues
- with configurable automated response behavior such as a return
- home and automatic
- landing routines  The INDAGO self

- calibrates all of its sensors and performs required failsafe pre
- flight tests prior to takeoff to check for errors  The INDAGO has the ability to automatically

return to base in a loss of link situation so the aircraft can’t fl y horizontally or verticall y be yond the pre
- planned flight area  The INDAGO has battery minutes and flight time displayed at all times. The sy stem will return home and land automatically if user
- configurable limits are reached The INDAGO auto
- detects a loss of GPS, warns the pilot and initiates a landing based on

user specified timelines  Low battery

on the INDAGO triggers a return to base for landing and battery replacement  If the INDAGO detects a loss
- of
- link with the Ground Control Station the vehicle will return to base and perform an automatic landing at the takeo ff point or other user defined return home point **The HexH2O** T he HexH2O RTF (“HEX”) is manufactured b y HEX H2O Multirotors with the Naza
- M V2 Flight Control Sy stem manufactured by DJ I Innovations. The HexH2o has an epox y fiber/carbon fiber waterproof body that buoys and also utilizes DJI motors and props. The HEX is a battery

operated hexcopter with a maximum flight time of 25 minutes. The vehicle weighs approximately

7 pounds with a maximum takeoff weight of approximately 10.4 pounds. It has buo yancy

aids to either side of the hull, vibration dampers, and minimalized gimbal mount, which allows for a 110 degree of view from the camera. Although the vehicle’s ground speed has a maximum of 25 mph, it will be operated between 2 and 5 miles per hour, and it will operate at or below 400 feet AGL. The UAV/UAS/UA which Petitioner will be operating is the HexH2O . The inherent safety features, sophistication, programmability , GPS navigation, return home capability , and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much saf er UAV for the purposes of this petition. This is a professional grade radio controlled UAVs that has the capacity for software upgrades. It is light, less than 12 pounds including battery and camera. Incorporated into the programming of the HEX is an auto matic return home feature that automatically directs the craft back to point of take
- off should communication with the transmitter be lost. The HEX has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 10.4 pounds. The HEX has a communication link between the camera and aircraft allowing the operator or Pilot in Command (PI C) to monitor battery level, altitude (AGL), distance from PI C, camera imagery , and also control camera angle. The software for the HEX allows the operator or PI C to set maximum altitude AGLfor each flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default programmed into the UAV's s oftware pre
- flight to insure compliance with FAA standards adding to the safety capabilities of this UAV. This UAV is programmed to remain in position when controls are released, maintaining altitude and GPS location. The HEX has an altitude and radar monitoring function that allows the operator more precise determination of height, direction of flight and distance from the operator/PIC. The operator/PI C can monitor GPS lock status while the UAV is in flight, with the ability t o anticipate loss of GPS locking so the operator/PIC can land the UAV as a precaution.The HEX features a waterproof carbon fiber body that floats and features extra props in the event

that if one fails, the aircraft can remain fl yi ng. In addition, the UAV features an internal fan and exterior
- mounted heat sink to prevent overheating. **Blade Chroma** 1. Motor to Motor Distance: 15.7 in (400mm) 2. Rotor Ty

pe: Quadcopter 3. Prop Diameter: 10.2 in (260mm) 4. Approximate Flight Time: 30 minutes 5. Battery : 11.1V 3S 5400mAh L i
- Po 6. Height: 9.50 in (242mm) 7. Weight: 45.9 oz (1.3 kg) 8. Motor Ty

pe: 4 × 780Kv Brushless Outrunner 9. Control L ink: 2.4GHz 10. Video L ink: 5.8GHz 11. Video L ink Range: 1,970 ft (600m) 12. Satellite Navigation Sy stem: GPS, GL ONASS 13. Completion Level: Ready
- to - Fly **Sprite** 1. Fully autonomous autopilot with GPS, including way point navigation, "follow me", and return to home 2. 2 - axis stabilized gimbal compatible with GoProTM 3. Real
- time telemetry 4. Fully enclosed, compact, ultra
- durable 5. Users can define geo
- fencing and altitude limits through Sprite's flight control sy stem 6. Dimensions & Performance a. Airframe is constructed mostly of injection molded ABS b. Length: 13.2 inches (350mm) c. Diameter: 3.8 inches (100mm) d. Weight: 2.6 lbs. (1,200g) with battery and standard camera e. Displacement: 215 cu. in. (3,520 cc) f. Endurance: approximately 10
- 12 minutes on a 11.1v L iPo battery (gearing, blade and motor optimization is ongoing) g. Speed: up to 10 m/sec h. Range: 10 minutes at 10 m/sec = 6km under autonomous flight i. Signal range: depends on equipment. Ty pical ly 2km +/
- , up to 50km possible with long range gear j. Telemetry

link is available in both 433MHz and 915MHz. The optional transmitter for conventional, manual flight control is a 2.4GHz sy stem. **The Trimble UX5**  The Trimble UX5 aerial imaging rover follows a pre - programmed path where takeoff, flight, and landing require minimal human intervention. If required, the crew operating the aircraft from the ground can intervene to change the flight path or to land. In some cases, such as communicationsfailure or loss of GPS signal, a pre
- programmed intervention is automatically activated to re
establish signal loss or to terminate the flight early and complete a safe landing. The UX5 aerial imaging rover holds a camera that takes aerial images over the defined ar ea. The UX5 is a fixed
- wing aircraft, weighs less than 6 pounds fully loaded, flies at a maximum speed of no more than 74.5 knots indicated airspeed (KIAS), and a cruise speed of 49 KIAS, carries neither a pilot nor passenger, carries no flammable fuels, and operates exclusively within a pre - disclosed area. In addition, the UX5 has a semi
- autonomous navigation and control s ys tem comprised of a Ground Control Station (GCS) and auto
- pilot sy stem. All flights are pre
programmed with precise global positionin g s ys tem (GPS) guidance and do not require human intervention **Hardware** Ty pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Fixed wing Weight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.5 kg (5.51 lb) Wingspan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 m (3.28 ft) Wing area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 dm Dimensions . . . . . . . . . . . . 100 cm x 65 cm X 10.5 cm (39.37 in x 25.59 in x 4.13 in) Material. . . . . . . . . . . . . . . . EPP foam; Carbon frame structure; Composite elements Propulsion. . . . . . . . . . . . . . . . . . . . Electric pusher propeller; brushless 700 W motor Battery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.8 V, 6000 mAh Camera. . . . . . . . . . . . . . . . . . . . . . 24 MP mirrorless APSC wi th custom 15 mm lens Controller. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Trimble Tablet Rugged PC **Operation** Endurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 minutes Range . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 km (37.28 mi) Cruise speed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 kmh (50 mph) Maximum ceiling
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5000 m (16,404 ft) Pre - flight s ys tem setup time. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 minutes Take off Ty

pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Catapult launch Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 degrees Landing Ty

pe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Bell y landing Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 degrees Landing space (L x W) Ty pical . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 m x 6 m (66 ft x 20 ft) Recommended. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 m x 30 m (164 ft x 98 ft) Weather limit . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 kmh (40.39 mph) and light rain Communicati on & control frequency . . . . . . . . . . . . . . . . . . . . . . . . . 2.4 GHz (FHSS) Communication & control range. . . . . . . . . . . . . . . . . . . . . . . . Up to 5 km (3.10 mi) Considering the programmability and safety features of these UAVs, it serves as the best option to protect the Public and NAS for the purposes of this petition. **Similarities, Distinctions and Differences**Scarlet Valley L ogistics is using UAV s that have the capability for taking off and landing at a single point, identical to a helicopter. There are no runway s, aided take off apparatuses, nor routes that need to be flown to operational areas , thus allowing for a reduced and more confined area of flight. The motors, rotors, propellers, body /frame, landing pads, etc. for the UAV s utilized in this petition are not complicated. Engineering and design allows lay man maintenance. Pre
- flight inspections for cracks, damage or other phys ical conditions that could hamper safe flight will be conducted prior to any and all missions. Post flight inspections will also be conducted in order to aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thorough inspection of the UAV s shall be conducted and flight response tested should a hard landing or crash occur insuring that the UAV s can operate in a safe manner before conducting any further missions. Like the Astraeus Petition , Petitioner requests waiver or exemption for markings due to the small size of the fuselage for THE EQUIPMENT . Scarlet Valley

L ogistics requests modification, waiver or exemption and clarification (within reason) concerning the S ection 91.119 prohibition of flight in congested areas. Petitioner requests waiver for this condition to allow reasonable and responsible operations in congested areas of subdivisions and neighborhoods. In compliance with Section 90.151 (a) THE EQUIPMENT are battery operated UAV s /UAS s with battery

level monitoring capability . Full y charged battery flight time is rated at 18 - 120 minutes, with videos/photos taking much less time to record. Operator or PIC is warned when battery level is low. Scarlet Valley

L ogistics requests waiver/exemption from Section 91.203 (a) since p osting of special flight authorization would not be possible since THE EQUIPMENT ha s no cabin and are not large enough to carry a certificate. **B. Scarlet Valley Logistics**  **’s Proposed Operations Demonstrate an**  **Equivalent Level of Safety**  **1. General Description of Proposed Flight Operations**  Scarlet Valley

L ogistics proposes to operate within the limitations and performance specifications listed in the USER MANUALS , which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory

structure because the proposed operations represent a safet y enhancement to the protocols. The proposed operations do not create any hazard to users of the national airspace s ys tem or pose a threat to national security
. THE EQUIPMENT are battery operated quad copter s and fixed
- wing aircraft with a maximum flight time of 18
- 120 minutes. THE EQUIPMENT weighs approximately 8

–25 pounds. It has vibration dampers and small frame air incline. THEEQUIPMENT ’s ground speed is a maximum of 2 5 - 56 mph but it will be operated between 2 and

2 5 miles per hour, and it will operate at or below 2 00 feet AGL. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. THE EQUIPMENT carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated b y the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of THE EQUIPMENT . The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology , is mitigated b y placing limits on altitude, requiring stand
- off distance from clouds, permitting day time ope rations onl y, requiring that the aircraft be operated within visual line of sight , and requiring THE EQUIPMENT to yi eld right of way to all other manned operations. Additionally , the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014 - 0352, at p. 13 . The petitioner’s aircraft has the capability to operate safely

after experiencing certain in
- flight failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifical ly low battery RTH and failsafe RTH . The aircraft is also able to respond to a lost
- link event with a pre coordinated, predictable, automated flight maneuver. **2. Reasons why the exemption would not adversely affect safety or how the**  **exemption would provide a level of safety at least equal to the existing rule.**  Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, Scarlet Valley L ogistics proposed operations using THE EQUIPMENT would “not create a hazard to users of the national airspace sy stem or the public or pose a threat to national security .” Reform Act Section 333(b ) ( 1). 1. The aircraft will be identified by serial number, registered w ith the FAA, and have identification (N
-Number) markings as large as practicable. 2. Flights will be operated within visual line of sight of the pilot in command (PI C). 3. Prior to each flight, a zero altitude initiation point will be established and confirmed f

or accuracy

by PI C. 4. Maximum flight time for each operational flight will be approximately 15 - 20 minutes. 5. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. 6. The aircraft will be operated during daylight and in VFR conditions. 7. Flights will be operated at a lateral distance of at least 50 feet from any persons or property not associated with the operation who have not given prior permission. 8. Flights will be limited t o a groundspeed of 5
- 25 mph. 9. Minimum crew for each flight will consist of a PIC and an Observer.10. The PI C will possess at least a sport pilot certificate and a valid state driver’s license. 11. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 12. The flight operations will yield the right of way to other manned aircraft operations. 13. All persons who are not involved with flight operations w ill be required to stay 5 0 feet from the edge of the flight operation perimeter. 14. Scarlet Valley

L ogistics will provide NOTAM details to the FAA 24 hours prior to each flight. 15. All required permissions and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 16. Prior to commencing operations, Scarlet Valley L ogistics will obtain a Certificate of Waiver or Authorization (COA) from the FAA if flying above 200 feet AGL. 17. If the aircraft loses communications, it will have the capability to return to a pre determined location within the operational area and land. 18. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 19. The flight will be aborted in case of unpredicted obstacles or emergencies. 20. Each flight will be recorded in an Operations L og Book. 24. Maintenance on the aircraft will be recorded in a Maintenance Lo g Book. **3. Flight Recovery, Lost Communications, and Lost GPS Procedures**  The flight recovery , l ost communications, and lost GPS procedures are fully documented in the User Manuals. **V. SPECIFIC FAR EXEMPTIONS REQUESTED**  Scarlet Valley

L ogistics seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations. L isted below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedure s and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

**A. 14 C.F.R. Part 21, Subpart H** 
**– Airworthiness Certificates and 14 C.F.R.**  **§ 91. 203(a)(1)**  The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS s selected provide an equivalent level of safety when compared to aircraft normall y used for the same application. These crite ria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014
- 0352 at 13 - 14, 22. If, however, the FAA determines that there are some characteristics of THE EQUIPMENT that fail to meet the requirements of the Reform Act, an exemption is requested.**Equivalent Level of Safety:** THE EQUIPMENT are safe when taking into account its size,

weight, speed, and operational capability
. THE EQUIPMENT weighs approximately 2.6 - 25 pounds and either wil l be flown at speeds of 5 - 25 miles per hour, and in visual line of sight of the operator . THE EQUIPMENT do es not carry pilots, passengers, explosive materials, or flammable liquid fuels. THE EQUIPMENT will be operated within the parameters of the User Manu als. Scarlet Valley

L ogistics will also provide the FAA with advance notice of all operations via a NOTAM and coordination with the local Flight Standards District Office ( FSDO ) . The proposed operations will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

**B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Ro**  **torcraft** 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent THE EQUIPMENT would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**C. 14 C**  **. F**  **. R**  **. §**  **45.11 :**  **Marking of Products**

— prescribes, in pertinent part, that the manufacturers of aircraft, engines and propellers mark such aircraft, engines, or propellers with an approved fireproof identification plate. Scarlet Valley

L ogistics requests an exemption from 14 CFR 45.11. The Identified Sy stem, due to its small size, does not have room for fireproof identification plates t o be placed in it. **D. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and** 

**Identification Requirements** 14 C.F.R. §45.23(b), Markings of the Aircraft states: When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light
- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light
- sport, “experimental ,” or “provisional,” as applicable. 14 C.F.R. § 45.27(a) states: **Rotorcraft.** Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. 14 C.F.R. § 91.9(c) states:No person may operate a U.S.
- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. In a pre vious Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N
-Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable. ” See Exemption No. 11062, Docket No. FAA 2014 - 0352, at p. 14. **Equivalent Level of Safety:** Petitioner will mark all THE EQUIPMENT with their N
- Number in a prominent spot on the fuselage with markings that are as large as practicable.

**E. 14 C.F.R. § 61.113:**  **Private Pilot Privileges and Limitations** Scarlet Valley

L ogistics seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PI C matches the airspace in which the PI C will be operating, as well as requiring certifications if the pilot is carryi ng passengers or cargo for hire. While THE EQUIPMENT will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA
- 2014 - 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additiona l cost and restrictions attendant with requiring the PI C to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a p rivate pilot. The PI C will possess at least a sport pilot certificate , a valid US driver’s license, and w ill have completed a Basic Operator Course for THE EQUIPMENT . The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS
- specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. FAA 2014 - 0352, at p. 18. The proposed operations can achieve an equivalent level of safety b y requiring the knowledge and experience in THE EQUIPMENT operations described above. The restrictions Scarlet Valley L ogistics has placed on THE EQUIPMENT operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA
- 2014 - 0352. Petitioner will operate in re stricted areas (the s ites) away from persons and property not involved in the operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified s ites. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.**F. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness** 

Scarlet Valley

L ogistics seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Ac cordingl y, Petitioner requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft;**  **14 C.F.R. §§ 91.203(a** **) and (b): Carrying Civil Aircraft Certification and Registration**  Pursuant to 14 C.F.R. § 91.9(b)(2): (b)No person may

operate a U.S.
- registered civil aircraft
-

... (2)For which an Airplane or Rotorcraft Flight Manual is required b y § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a)Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1)An appropriate and current airworthiness certificate. (b)No person may

operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Scarlet Valley

L ogistics does not request an exemption from this section but instead notifies th e FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PI C during flight. The Chief Counsel’s Office ha s held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19 - 20, and Grant of Exemption No. 8607.

**H. 14 C.F.R.**  **§ 91.103: Preflight Action**  Scarlet Valley

L ogistics s eeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA
- approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. Under these circumstances, the FAA has stated that no exemption is required. See Grant

of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA
approved Flight Manual is required. **Equivalent Level of Safety:** An equivalent level of safety will be provided by following the User Manuals. The PIC will take all required preflight actions
- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas
- before initiation of flight. The User Manuals will be kept at the ground station ; with the operator at all times.

**I. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  Scarlet Valley

L ogistics seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls.” UASs and remotel y piloted aircraft, by

their design, do not have functional dual controls. Instead, flight control is accomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with the aircraft via radio communications. **Equivalent Level of Safety:** When flight instruction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of THE EQUIPMENT , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. These flights will comply with the provisions in the User Manuals. Accordingl y, Petition er proposed method of operation provides superior levels of safety.

**J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas**  Scarlet Valley

L ogistics requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Se ction 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with s imilar flight restrictions as those imposed by Aerial Media International
. See Grant of Exemption No. 11062, p. 20 - 21. **Equivalent Level of Safety:** Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, an d given the lack of flammable fuel, any risk associated with these operations is far less than those that presentl y exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of THE EQUIPMENT , as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set forth in the User Manuals and herein, THE EQUIPMENT will be operated at s ites, away from persons or structures not involved in the operation. All persons who are not involved with Petitioner operations wi ll be required to be at least 50 feet from the flight operation perimeter.**K. 14 C.F.R.**  **§ 91.121: Altimeter Settings** 

This pet ition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport. THE EQUIPMENT use both barometric pressure sensors and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that THE EQUIPMENT do not have a barometric altimeter setting. The altitude of the aircraft is monitored b y the PI C on the ground control station and by the visual observer. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual li ne - of
- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20 - 21. As the User Manuals indicate, THE EQUIPMENT will be operated at or below 400 feet AGL and compl y with the limitation s in the Grant of Exemption No. 11062. **L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Scarlet Valley

L ogistics requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states : (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 intended landing and, assuming normal cruising speed

– (1) During the day , to fl y 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 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. Here, the technological limitations on THE EQUIPMENT battery power means that no meaningful flight operations can be conducted while still mai ntaining a 30 minute reserve. The aircraft is battery

powered with a maximum flight time of between 18
- 25 minutes. Petitioner proposes that the maximum flight time for each operational flight will be 18 - 2 5 minutes. The aircraft will be safely

landed with n o less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21 - 22. The User Manuals providing an equivalent level of safety b y s afel y landing with no less thanthe greater of (a) 20% b attery life remaining or (b) three minutes of flight time remaining and otherwise compl yi ng with the flight restrictions above.

**M. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and**  **(b): Maintenance Inspections**  Scarlet Valley

L ogistics seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F .R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which THE EQUIPMENT will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved be cause maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, and inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14 - 15. As provided in the Manuals, flights will not be conducted unless a flight operations checklist is performed that includes all of the airc raft’s components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post - flight maintenance. The Manuals set requirements for both annual maintenance and preventative maintenance. **VI. PUBLIC INTEREST**  Granting Scarlet Valley

L ogistics petition for exemption furthers the public interest. National policy set b y Congress favors earl y integration of UAS into the NAS in controlled, safe working environments as proposed in this petition. By granting this peti tion, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 33 3 of the Reform Act. Scarlet Valley

L ogistics will operate in a manner that will ensure the public’s safety and will set the example for others to emulate. It is well established that UAS provide an additional tool for the filmmaking industry , adding a greater degree of flexibility, which supplements the current capabilities offered b y m anned aircraft
. **VII. PRIVACY**  All flights will be conducted in accordance with any federal, state or local laws regarding privacy
. All flights will occur over private or controlled access property with the property owner’ s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they will be made anony

mous.**VIII. NATIONAL SECURITY** 

Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue. Furthermore, the security screening conducted b y the Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to no t pose a threat to national security. **IX. SUMMARY FOR FEDERAL REGISTER**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Scarlet Valley

L ogistics seeks an exemption from the following rules in order to conduct aerial operations for clients including aerial photograph y/videograph y services, with a wide variety of applications, to public and private individuals and businesses . These include but are not limited to utilities, railroad transportation , pipeline transportation , oil
- field services , petro/chemical/m anufacturing, construction, agriculture , home and roof inspections, bridge inspections, power line inspections, inspections for real estate claims , education, surveying , flight training, commercial & residential real estate, surveying, land & property mapping, landscap ing , news, law enforcement, advertising & marketing, utility infrastructure , search & rescue, and agriculture : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27 ; 14 C.F.R § 45. 11 ; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 1 4 C.F.R § 91.121; 14 C.F.R § 91.151(a) ; 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b). The exemption will enhance safety b y reducing risk to the operator, the general public and property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation, and flight operations. **X. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act
- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security considerations
- provides more than adequate justification for the grant of the requested exemptions to permit Scarlet Valley L ogistics to operate THE EQUIPMENT . Granting the requested exemption will benefit the public interest as a whole in many way s, including (1) significantly improving safety and reducin g risk b y alleviating human exposure to danger; (2) improving the quality of services Scarlet Valley L ogistics can provide to its customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraftRespectfully submitted, By : /s/ Scott Laird Owner Scarlet Valley

L ogistics