U.S. Department of Transportation, Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

August 4, 2015

Re: Raven Petition for Exemption

Dear Sir or Madam,

Raven is a sUAS delivery platform startup founded by three young engineers with mechanical, robotics, and software engineering backgrounds. This petition is submitted on our behalf pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 11, Ravi Gangele (Raven), a Virginia based startup operating small unmanned aerials systems or sUAS equipped to transport cargo for various industries, hereby applies for an exemption from the Federal Aviation Regulations described below to allow our sUASs to operate under the pretense of research and development, and demonstrations over private property with consent of the landowner and terms of operating specified by the Federal Aviation Administration.

Use cases, or commercial pursuits that the research conducted from the requested exemption will allow Raven to partake in is, but is not limited to, as follows:

• Emergency Aid Supply delivery

• Food delivery

Flights conducted on private property for demonstration purposes will always be pre-planned flights coordinated with the owner or management team of the private property to ensure the landing area designated within line of site is isolated from the vicinity of any person on said property.

Raven sUAS are custom-built multicopters and are fully detailed in Appendix A. We currently have two sUAS models, the F8 and the F6. The F8 is an octocopter 1727 mm in diameter. The F6 is 845 mm in diameter. Both the F8 and F6 sUAS utilize a 3DR Pixhawk flight controller; it is the same unit found in 3DR Iris+ sUAS and numerous other sUAS products sold by 3DR and granted Section 333 exemption for several companies. The Raven F6 and F8 do not have video recording equipment. The focus of Raven sUAS is safe and reliable transport of cargo along a predetermined, and pre-inspected path. From here on, the F6 and F8 will be collectively treated as a singular sUAS due to the indistinguishability of their architectures, and will be referred to as ‘this sUAS,’ or ‘sUAS.’



### 1

## Information Required by 14 C.F.R. §11.81 for this Petition

A. NAME AND MAILING ADDRESS

Ravi Gangele Founder Raven 21892 Larchmont Way Ashburn, VA 20148 703-505-9182 ravi.gangele@flyraven.io

www. flyraven.io



### B. SPECIFIC SECTION(S) OF 14 C.F.R THAT RAVEN SEEKS TO BE EXEMPT FROM

1. 14 C.F.R Section 21.185 (a) Airworthiness Certificate 2. 14 C.F.R Section 45.23 (b) Display of marks; general. 3. 14 C.F.R Section 61.113 (a) (b) Private pilots privilege & limitations PIC 4. 14 C.F.R Section 91.7 (a) Civil Aircraft Airworthiness 5. 14 C.F.R Section 91.9 (b)(2) Civil Aircraft Manual 6. 14 C.F.R Section 91.103 Preflight Actions 7. 14 C.F.R Section 91.109 Flight Instructions 8. 14 C.F.R Section 91.121 Altimeter 9. 14 C.F.R Part 21, Subpart H: Airworthiness Certificates - 14 C.F.R Section 91.203 (a) (1) 10. 14 C.F.R Section 91.405 (a) Maintenance required 11. 14 C.F.R Section 91.407 (a) Operation After Maintenance 12. 14 C.F.R Section 91.409 (a) (1) (2) Inspections 13. 14 C.F.R Section 91.417 (a) (b) Maintenance Records



### C. EXTENT OF RELIEF NEEDED, REASON RELIEF IS BEING REQUESTED, AND HOW SAFETY IS NOT ADVERSELY AFFECTED

14 C.F.R Section 21.185 (a) Airworthiness Certificate

While the FAA is developing standards for sUASs and UAV’s, this sUAS is seeking exemption from the requirements from 14 C.F.R 91.203 (a)(1) and 14 C.F.R Part 21. Since this sUAS will carry no pilot or passengers, fly under 100ft AGL, at a moderate speed, and given this sUASs size and weight it would seem unnecessary to go through the Airworthiness Certificate process to maintain or exceed the equivalent level of safety expected by the FAA. Furthermore this sUAS will operate on either private property or on one of the six FAA testing grounds.



### 214 C.F.R Section 45.23 (b) Display of marks; general

Since there is no cabin or like location on this sUAS placing “Experimental” in 2 inch lettering would be difficult. A practical size lettering of will be placed on the sUAS stating “Experimental”, if deemed necessary by the FAA. We respectfully propose that all relevant documentation and relevant materials be kept with the operator at the time of any flight to uphold the equivalent level of safety that the FAA expects from all aircrafts. Prior FAA rulings have deemed that this would be safe and granted this exemption in the past.

14 C.F.R Section 61.113 (a) (b) and 61.133(b) Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

This sUAS will not carry a pilot or passengers and all flights will be pre-planned and on private property or one of six FAA testing areas all controlled remotely. We believe that with the size of this sUAS and the precaution we will take, we will achieve equivalent if not higher levels of safety than a commercial pilot. Prior FAA rulings have granted this exemption without a Pilot inCommand (PIC). We propose that these requirements as well as a deep level of preprogrammed control and many built-in technical capabilities via Mission Planner software. This software lets the operator and the operator’s team, view all aspects of the flight in real time. This Mission Planner software allows for advanced features that were only previously available tolarger and more complex unmanned aircrafts. This software has features that have several failsafes in place to enabling this sUAS to have consistently safe, reliable and well-documented flights. The Mission Planner software would assist the operator in the flight of sUAS, ensuring a safe, predetermined path. To clarify, the operator is always in control of the sUAS while the software aids the operator in ease of use through streamlined telemetry readouts, and simple flightpath routes.

Features that the Mission Planner software are as follows:

• A “Return to home/Return to Launch” feature that would immediately return the sUAS if any

emergency situation would occur

• No-Fly Zones are pre-built into the software to ensure no flights are within this area

• A live telemetry feed of the sUAS before, during, and after the flight.

Flight safety is the most important priority of this sUAS. This sUAS has created a platform that exceeds the safety levels of any manned aircraft by taking the operator out of the aircraft and any potentially unsafe situations by keeping limiting the operator’s ability in only a safe range. We would also like to note that the FAA has in the past granted this exemption.

With the conditions and restrictions in place the equivalent level of safety will be provided without a private or commercial pilot.



### 314 C.F.R Section 91.7 (a) Civil Aircraft Airworthiness

If the exemption 21.185 were granted (there will no airworthiness certificate issued) there would be no FAA regulation to determine airworthiness. The operator of the flight would then determine the airworthiness. Prior FAA rulings have granted this exemption under the same circumstance. With the specification of this sUAS and all flights being done on private property or at one of six FAA testing areas this sUAS would achieve the equivalent level of safety. An equivalent level of safety would also be achieved with a combination of several monitoring systems on board the sUAS as well as following FAA guidelines (on when deemed safe to fly) and a written protocol that the operator of the sUAS will use before, during and after each flight. (This includes but is not limited to inspecting the sUAS before/after each flight, planning each flight prior to flying, insuring weather conditions for flying, being aware of all airports and no fly zones, etc.)

14 C.F.R Section 91.9 (b)(2) Civil Aircraft Manual

Due to the size and configuration of this sUAS, it would be impossible to carry the flight manual on the aircraft. Keeping the flight manual on the ground with the operator at the time of the flight would maintain an equivalent level of safety. The FAA has granted this exemption before under the same circumstances and also deemed it unnecessary to seek relief from 14 C.F.R section 91.9 but we would like to make sure that this is documented to ensure this sUAS is compliant with FAA regulations.

14 C.F.R Section 91.103 Preflight Actions

If granted section 91.9 (b) exemption the flight operator will make sure all pre-flight conditions and checks are completed before take off. These include but are not limited to weather, aircraft battery levels, flight plan, wind speeds, along with the overall condition of the aircraft. The FAA has granted this exemption in the past and has deemed the operator of a sUAS of this size and specification is qualified to complete all pre-flight checks. Safety is the number one priority of each flight and the operator will achieve the equivalent levels of safety with is exemption.

14 C.F.R Section 91.109 Flight Instructions

While the operator is using the primary radio transmitter, Mission Planner, the ground control station software of the sUAS running on a laptop and using a second radio transmitter, can allow the instructor and student to simultaneously control the sUAS, along with fail-safe programming in place to safely land the sUAS or place it in Loiter mode if needed. We believe this method should meet the purpose of 91.109 with a parallel level of safety. It should be noted that the FAA has granted exemption for this type of setup.



### 414 C.F.R Part 21, Subpart H: Airworthiness Certificates - Section 91.203 (a) (1)

The sUAS at max weight will be less than 55 pounds and unmanned. This sUAS will not be able to carry or display certifications and registration documents onboard. The equivalent level of safety will be achieved by keeping these documents on the ground during flights. The FAA has deemed this safe in the past and approved this exemption.

14 C.F.R Section 91.151(a): Fuel Requirements for Flight in VFR Conditions

The sUAS has two batteries onboard that provide 15 minutes of flight time, and all flights that take place with said sUAS would be under 5 minutes long. To exceed the level of safety the FAA expects, this sUAS would return to its “Launch/Home” position prior to having a low battery. With this safety precaution in-built into this sUASs system, we would eliminate any risk that could have been created by not having a 30-minute reserve on the batter prior to a flight. Furthermore, all flights would be conducted on private property; with no pilot or passengers onboard and due to the specifications of this sUAS we would uphold and exceed the equivalent level safety without having a 30-minute reserve.

14 C.F.R Section 91.405 (a), 91.407 (a), 91.409 (a) (1) (2), 91.417 (a) (b) - Maintenance required, Operation After Maintenance, Inspections and Maintenance Records

Maintenance of this sUAS will be performed by the operator in accordance with the instruction material provided by the manufacturers of all components of this sUAS. When these instructions are followed from each given manufacturer, an exceeded amount of safety would be achieved in the C.F.R because of the characteristics of this sUAS, as follows: Moderate size and mechanical simplicity The lack of a pilot, crew, passengers, and cargo Flights will be done on private property or one of six FAA testing grounds The entire team is trained to have a deep understanding of all the maintenance points of the aircraft prior to and after the flight

All of the flight data will be logged into the software Mission Planner’s logs and are available for the operator and their team to review at anytime. This sUASs frame is unique among most other sUAS, in that, it is made from strong but light carbon fiber.



### 5

## D. Public Benefits

With our sUAS models, the F6 and F8, we would be able to prove reliable and quick transportation of emergency supplies to natural disaster areas in the United States. Our exemption is to conduct the appropriate research and development of the F6 and F8 to serve this purpose in the future through agencies such as FEMA and the American Red Cross. Commercial businesses such as golf courses would be able to utilize a Raven sUAS to deliver food in a quick and safe manner, while boosting their business with increased food revenue. Raven is a safe and affordable alternative to traditional land and air based delivery methods.



### 6

## Appendix A - Technical specifications of the Raven sUAS models

RAVEN F6

• Weight (including battery, no payload): 8 lb.

• Weight with max payload; max takeoff weight: 12.5 lb.

• Fuel type: Two Lithium Polymer batteries monitored via telemetry for low voltage levels

• Motors: 6 Electric brushless DC motors; KDE 2814XF

• Landing type: Vertical landing, Two T-shaped carbon fiber landing legs

• Size:

• Diameter: 845 mm (including 13” propellers)

• Height: 298 mm

• Frame type: Tarot 680 Pro carbon fiber frame, hexacopter configuration



### RAVEN F8

• Weight (including battery, no payload): 20 lb.

• Weight with max payload; max takeoff weight: 39 lb.

• Fuel type: Two Lithium Polymer batteries monitored via telemetry for low voltage levels

• Motors: 8 Electric brushless DC motors; KDE 4012XF

• Landing type: Vertical landing, Two T-shaped carbon fiber landing legs

• Size:

• Diameter: 1227 mm (including 18” propellers)

• Height: 546 mm

• Frame type: Tarot T18 carbon fiber frame, octocopter configuration



### RELIABILITY While the Raven F6 and F8 sUAS utilize different motor sizes, both are supplied by KDE, a leading manufacturer of reliable, high-performance, heavy-lift sUAS motors. They also provide extensive documentation on motor performance and maintenance. Routine wear on components such as motors (ball bearings), and batteries will be both observed by physical and software-based inspections prior to and after flights.



### 7 We respectfully request that pages 7-11, i.e Appendix A, B, and C not be republished for public viewing.

## Appendix B - Motor Specifications

Motors being used on the Raven F6 sUAS:



### 8Motors being used on the Raven F8 sUAS



### 9

## Appendix C - Sample Flight Path

10 Safety Precautions:

• Private Golf course / Country club will help us determine safe, secluded landing areas and make patrons aware.

• No flights during bad weather i.e rain, high wind.

• Flights can ONLY occur when course is near empty, and no patrons playing within 30 ft. from the flightpath.

• Flightpath has been surveyed and is well within the operator’s line of sight.

• Only one sUAV will operate at a time.

• Operator will be operating the sUAS via an industry standard radio transmitter, and a secondary operator will be monitoring the sUAS and it’s flight via the assistance software Mission Planner on a laptop next to the operator.

• Secondary operator in addition to operator would be able to activate failsafes such as Loiter or Return to Launch if deemed
necessary.

• Max altitude will be 100 ft. and more than 5 miles from any airport. Golf Course example

### 11 Private field test example (disaster relief testing)

Safety Precautions:

• Private property owner aware of sUAS operations.

• No flights during bad weather i.e rain, high wind.

• No humans are in or near the vicinity of the flightpath.

• Flightpath has been surveyed and is well within the operator’s line of sight.

• Only one sUAV will operate at a time.

• Operator will be operating the sUAS via an industry standard radio transmitter, and a secondary operator will be monitoring the sUAS and it’s flight via the assistance software Mission Planner on a laptop next to the operator.

• Secondary operator in addition to operator would be able to activate failsafes such as Loiter or Return to Launch if deemed necessary.

• Max altitude will be 350 ft. and more than 5 miles from any airport.