# Laymon
International LLC



# Laymon International LLC

Airworthiness Exemption Petition
Supporting Information

April 6, 2015

Exploration, Mining and Minerals Import/Export

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# Contents

l Operations Plan Summary 4



### 2 Information Supporting Petition 5

2.1 Petitioner’s Contact Information 5

2.2 Laymon International’s Operations Plan 5

2.2.1 sUAS System Description 6

2.2.2 Flight Conditions 6

2.3.2 Flight Operations 6

2.3 Privacy 7

2.4 Aircraft Safety 7

2.5 Public Safety 10



### 3 Special Exemption Requests 10

3.1 14 CFR 21(h) Airworthiness Certificates 10

3.2 14 CFR 43.7 Persons authorized to approve aircraft, airframes, 10 aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventative maintenance, rebuilding,or alteration

3.3 14 CFR 43.11 Content, form, disposition of records for inspections 10 conducted under parts 91 and 125 and 135.411(a)(1) and 135.419 of this chapter

3.4 14 CFR 45.11 Marking of products 10

3.5 14 CFR 45.21 General 11

3.6 14 CFR 45.23 Display of marks; general 11

3.7 14 CFR 45.25 Location of marks on fixed wing aircraft 11

3.8 14 CFR 45.27 Location of marks on non fixed wing aircraft 11

3.9 14 CFR 45.29 Size marks 11

3.10 14 CFR 47.3(b)(2) Registration required 11

3.11 14 CFR 47.31(c) Application 11

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### 3 Special Exemption Requests Continued...

3.12 14 CFR 61.113 Private Pilot Privileges and Limitations: 11 Pilot in Command

3.13 14 CFR 91.7(a) Civil aircraft airworthiness 12

3.14 14 CFR 91.9(b)(c) Civil aircraft flight manual, markings, and placard 12 requirements

3.15 14 CFR 91.103(b)(2) Preflight action 12

3.16 14 CFR 91.105 Flight crew members at stations 12

3.17 14 CFR 91.109 Flight instructions, Simulated instrument flight 12 and certain flight tests

3.18 14 CFR 91.119(b)(c) Minimum safe altitudes: General 12

3.19 14 CFR 91.121 Altimeter readings 13

3.20 14 CFR 91.151 Fuel requirements for flight in VFR conditions 13

3.21 14 CFR 91.203(a)(b) Civil aircraft: Certification required 13

3.22 14 CFR 91.215 ATC Transponder and Altitude Reporting 13 Equipment and Use

3.23 14 CFR 91.405(a)(d) Maintenance Required 13

3.24 14 CFR 91.407 Operation after maintenance, preventive 13 maintenance, rebuilding, or alteration

3.25 14 CFR 91.409 Inspections 14

3.26 14 CFR 91.417 Maintenance records 14



### List of Attachments:

Attachment 1: DJI Inspire 1 Users Manual Version 1.0 Attachment 2: DJI Inspire 1 Safety Guidelines Version 1.0 Attachment 3: DJI Intelligent Flight Battery Safety Guidelines Version 1.0 Attachment 4: DJI Inspire 1 Maintenance Manual Version 1.0

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# 1. Laymon International LLC Operations Plan Summary

TABLE 1: Operations Plan Summary

4 Overview Laymon International LLC will operate a sUAS for mineral prospecting, data collection, mapping, and real property photography.
Applicant seeks an exemption from the following rules as outlined in 14 CFR Part ll 14 CFR 21(h); 14 CFR 43.7; 14 CFR 43.11; 14 CFR 45.11; 14 CFR 45.21; 14 CFR 45.23; 14 CFR 45.25; 14 CFR 45.27; 14 CFR 45.29; 14 CFR 47.3(b)(2); 14 CFR 47.31(c); 14 CFR 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(c); 14 CFR 91.103(b)(2); 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119(b)(c); 14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203(a)(b); 14 CFR 91.215; 14 CFR 91.405(a)(d); 14 CFR 91.407; 14 CFR 91.409; and 14 CFR 91.417

Aircraft Description sUAS used will be a DJI Inspire 1 weighing less than seven (7) pounds with max speed of 43 knots
Flight Conditions All photogrammetry of mining claims as well as real property data collection, photography and exploration operations will be conducted under VFR, below 400 feet AGL and within 1500 feet laterally of the pilot. Flight ground speeds will be held to no more than 43 knots.
Flight Areas of Operation All flights will safely operate over private or publicly held lands that are over 5 nautical miles from airports, in class G airspace, and in accordance with all federal, state, and local laws.

Method for See and Avoid Pilot in command (PIC) will operate within a visual line of sight VLOS capability. PIC and VO will communicate verbally at all times.
Lost-Link and Flight Recovery In the rare event of lost-link, the DJI Inspire is pre-programmed for a safe designated return to home base controlled landing area.

Pilot Qualifications Laymon International veteran sUAS PIC’s are experienced in all areas of operations and flight training with the aircraft flown, as described in petitioner’s flight operations.
Inspection, Maintenance,Training, and Safety All Safety Management Systems, Maintenance, Inspection, and Training will be carried out as described in Laymon International’s Operations Manual and (attachments 1,2,3,4).

# 2. Information Supporting Petition

2.1 Petitioner’s Contact Information

Laymon International LLC 21143 Hawthorne Blvd. #418 Torrance, California 90503 Tel: 310-463-1259 Email: t homas_laymon@laymoninternational.com



### 2.2 Laymon International LLC Operations Plan

2.2.1 sUAS System Description The approved exemption will permit the flight operation of a sUAS based on the DJI Inspire 1 unmanned quad rotor aircraft. The complete flight ready aircraft weighs less than seven (7) pounds with a max airspeed of 43 knots. Flight telemetry includes altitude, flight speed, battery condition, and distance from home point. Return to home point for radio loss of link is also integrated.

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### Table 2: Aircraft Specifications

Model T600 (DJI Inspire 1)
Weight (Battery Included) 2935 g
Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m
Max Angular Velocity Pitch: 300°/s Yaw: 150°/s
Max Tilt Angle 35°
Max Ascent Speed 5 m/s
Max Descent Speed 4 m/s
Max Speed 22 m/s (no wind)
Max Flight Altitude 4500 m
Max Wind Speed Resistance 10 m/s
Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Dimensions 438x451x301 mm



### Table 3: Controller Specifications

Operating Frequency 5.725~5.825 GHz / 2.400~2.483 GHz
Battery 6000 mAh LiPo 2S
Transmitting Distance 2 km

### 2.2.2 Flight Conditions

The sUAS will at all times fly within 1500 feet lateral to the PIC. Altitude will be no higher than 400 feet AGL. Flight ground speeds shall not exceed 43 knots. All flights will be within class G airspace and beyond 5 nautical miles of any airport. All flights will be day time only, in the visual-line-of-sight and operated only during days of clear visibility and low wind conditions.

Data Collection and photogrammetr ic flights of mining claims and real properties will be done in very remote areas of Federal Bureau of Land Management lands in addition to privately held property. Photo and video data will also be taken of potential mineral prospect locations deemed too dangerous for full sized aircraft, to determine the value of a more detailed exploration.

All flights will occur in potential mining and real property locations in the western states of California,Nevada, Utah, Arizona, and Colorado.



### 2.2.3 Flight Operations

All locations will be strictly controlled for access by only the PIC, observer and other relevant safety personnel. The PIC will have 100+ hours of logged sUAS experience and the observer/spotter will be an equally qualified sUAS pilot. Airspace assessment must be completed both prior to preflight and again just prior to take off. Flight planning for each flight includes obtaining any regulatory permission, land-use permissions, preforming a risk assessment, and map study of planned flight area. Observer and support ground crew members will secure planned and alternate operating zones, establishing communications, and identifying emergency contingencies



### . The standard pre-flight check list and procedures are as follows:

1) The flight battery and transmitter battery must be fully charged.

2) Always turn on the transmitter first and then the Quadcopter Multi-Rotor.

3) Check for visible damage such as loose screws, broken, unbalanced or damaged propellers, faulty connectors or solder joints, landing gear, etc.

4) The propellers must be in a good condition and securely mounted.

5) The rotors must spin smoothly. Must ensure that there are no objects are in the rotational plane of the propellers or within a distance that poses a risk of obstruction.

6) Confirm the appropriate audible beeps when switched on for GPS calibration and communications link, and directional and battery charge lighting are on.

7) Ensure that the selected channel on the remote control is free and within range of the transmitter.

68) Ensure the sensors are calibrated (when the motors are off move yaw and throttle stick into upper left corner until it beeps).

9) Check gimbal and camera functions.

10) After starting the motors, check that all motors are running and rotate evenly. Initiate takeoff at a low altitude and confirm all flight controls and telemetry are functioning normally.

During Flight:

1) Maintain visual line of sight with aircraft at all times.

2) Confirm aircraft altitude is no greater than 400 feet AGL at all times.

3) Confirm aircraft is within 1500 lateral feet of PIC at all times.

4) Keep ground speeds under 43 knots at all times.

5) Confirm all planned flight path airspace is free of all obstacles.

6) Monitor battery life and properly land sUAS within 25% battery life remaining.

7) Flight times shall never exceed 15 minutes in length.

8) If the sUAS loses communications or loses its GPS signal, the UAS will be returned to the pre-determined location within the Security Perimeter and land.

9) Land in designated and controlled landing zone and properly power down aircraft and transmitter.

Note: Additional safety guidelines are found in (attachments 1,2,3)



### 2.3 Privacy

Due to the extreme remoteness of proposed flight locations there is little concern flights will cause invasions of privacy. All flights will occur over controlled access of both public or private property with prior property owners consent. Consent will be secured in situations where privacy could become a concern.



### 2.4 Aircraft Safety

Laymon International LLC agrees to be bound by the following operational conditions while conducting commercial operations and that these limitations provide for an equivalent or higher level of safety under the current regulations:

1) The sUAS must weigh 7 pounds or less including energy source(s).

2) The sUAS must be flown at a ground speed not exceeding 43 knots.

73) Flights must be operated at an altitude not to exceed 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

4) The sUAS must be operated within a visual line of sight (VLOS) of the PIC and visual observer (VO) at all times. The PIC must be able to use vision unaided by any device other than corrective lens as specified on the PIC’s U. S. drivers license.

5) All operations must utilize a visual observer. The VO will NOT take the place of the PIC in maintaining VLOS capability. The PIC and VO must be able to verbally communicate at all times. The PIC will confirm that the VO can perform the duties required of a VO.

6) The Operators manual and grant of exemption will be made available to the administrator upon request. The operator must follow the procedures as outlined in the operator’s manual unless a discrepancy exists between the conditions and limitations of the exemption in which case the conditions and limitations of the exemption will take precedence and must be followed. Operators and safety manuals will be made available during all sUAS flight operations.

7) Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

8) The sUAS must NOT undergo any maintenance or alterations that affect the sUAS operation or flight characteristics, e.g., replacement of a flight critical component.

9) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

10) Regarding distance from non-participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for insuring safety.

11) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a pre-determined location within the security perimeter and land or be recovered in accordance with the operator’s manual (attachment 1).

12) The sUAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual (attachment1,2).

13) Each sUAS flight operation must be completed within 15 minutes flight time or with 25% battery power remaining, whichever occurs first.

814) All sUAS operated in accordance with an exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have an identification (N Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

15) Any sUAS operated must comply with all manufacturer Safety Bulletins.

16) The sUAS must remain clear and yield the right of way to all other manned operations and activities at all times

. 17) Operation of sUAS must not be conducted during night. All operations must be conducted under visual meteorological conditions (VMC).

18) The sUAS must not operate in Class B, C, or D airspace. The UA may not operate within 5 nautical miles of the geographic center of a non-towered airpor t.

19) The PIC will only be permitted to operate after demonstrating the ability to operate in a safe manner including evasive and emergency maneuvers and maintaining proper distances from all structures, people, vessels, and vehicles. Dedicated training only sessions will take place to ensure the proficiency and experience of the PIC and will be done so with the appropriate distance from non participants.

20) The sUAS may not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

21) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined controlled landing area.

22) The PIC is prohibited from beginning a flight unless given the weather, the sUAS has enough power to conduct its operation and have a minimum reserve power for five minutes flight time.

23) The sUAS will display all assigned registration and identification numbers and markings as large as practical and in accordance with applicable CFR’s.

24) The sUAS will not be operated from any moving vehicle or device.

25) All operations shall be conducted over private or controlled property with permission from the property owner or authorized representative for each flight.

26) NTSB will be notified within 24 hours of any incident, accident, or flight transgresses of lateral or vertical boundaries.

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### 2.5 Public Safety

T he safety achieved using an unmanned aircraft with no passengers or crew, weighing considerable less than a full sized aircraft, and carrying no flammable fuel load, operating under the flight conditions outlined in section 2.4, Aircraft Safety, would be in the public interest. In addition, using a sUAS would reduce risk of injury to personnel mapping and prospecting in remote areas where natural hazards such as cliffs, ledges, ravines, and other natural obstacles commonly occur.



# 3. Special Exemption Requests

3.1 14 CFR 21(h): Airworthiness Certificates

Laymon International LLC requests an exemption from 14 CFR 21(h). Based on the light weight, minimal size, reduced speed, and use in controlled remote areas this exemption meets the requirements for an equivalent level of safety as outlined in Section 333.



### 3.2 14 CFR 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventative maintenance, rebuilding,or alteration

Laymon International LLC requests an exemption from 14 CFR 43.7 Given the sUAS is more similar to a model aircraft all inspections will be done as recommended by the manufacturer. All repairs other than simple propeller changes will be done by the manufacturer or one of their authorized repair centers. Maintenance will be preformed as outline in the manufacturer’s maintenance guidelines (attachment 4 ). All maintenance and repair will meet the requirements for the equivalent level of safety pursuant to section 33 given the intended use and remote location of the sUAS.



### 3.3 14 CFR 43.11: Content, form, disposition of records for inspections conducted under parts 91 and 125 and 135.411(a)(1) and 135.419 of this chapter

Laymon International LLC requests an exemption from 14 CFR 43.11. Currently the FAA has not certified any inspections for sUAS and due to its size there is no room for maintenance placards. Maintenance records will be kept on file by Laymon International LLC.



### 3.4 14 CFR 45.11: Marking of products

Laymon International LLC requests an exemption from 14 CFR 45.11. Due to it’s small size and flight characteristics, fireproof placards would cause a potential hazard to the aircraft with the additional weight or location.

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### 3.5 14 CFR 45.21: General

Laymon International LLC requests an exemption from 14 CFR 45.21. The FAA currently has no registration procedures for sUASs however if a registration number can be assigned, placement on the aircraft will be done in the most practical and visible means available.



### 3.6 14 CFR 45.23: Display of marks; general

Laymon International LLC requests an exemption from 14 CFR 45.23. Due to the small size of the sUAS full size aircraft marks are not feasible. If a designation is assigned by the FAA, Laymon International LLC will place assigned designation marks on the aircraft in the most practical and visible manner available.



### 3.7 14 CFR 45.25: Location of marks on fixed wing aircraft

Laymon International LLC requests an exemption from 14 CFR 45.25. The sUAS is a multi rotor aircraft and does not possess fix wings and as such 14 CFR 45.25 is inapplicable.



### 3.8 14 CFR 45.27: Location of marks on non fixed wing aircraft

Laymon International LLC requests an exemption from 14 CFR 45.27. Due to the sUASs small size it has no cabin, fuselage, boom, or tail.



### 3.9 14 CFR 45.29: Size of Marks

Laymon International LLC requests an exemption from 14 CFR 45.29. Due to size constraints of the aircraft this requirement cannot be met. However with approval of an exemption an aircraft mark will be affixed in the most practical locations.



### 3.10 14 CFR 47.3(b)(2): Registration required

Laymon International LLC requests an exemption from 14 CFR 47.3(b)(2). The FAA currently has no procedures for registration of an sUAS. If a registration number is assigned by the FAA, Laymon International LLC will place assigned designation marks on the aircraft in the most practical and visible manner available.



### 3.11 14 CFR 47.31(c): Application

Laymon International LLC requests an exemption from 14 CFR 47.3(c). Currently compliance for 14 CFR 47.31(c) is not possible since the FAA does not yet have procedures to register sUAS.



### 3.12 14 CFR 61.113: Private Pilot Privileges and Limitations: Pilot in Command

Laymon International LLC requests an exemption from 14 CFR 61.113. The PIC of the sUAS does not possess a commercial or private pilots license.

11However, the proposed use of an unmanned aircraft with no passengers or crew, weighing considerable less than a full sized aircraft, and carrying no flammable fuel load, operating in remote areas, using a skilled sUAS PIC, will achieve the equivalent level of safety of current operations by manned aircraft with a private pilots license.



### 3.13 14 CFR 91.7(a): Civil aircraft airworthiness

Laymon International LLC requests an exemption from 14 CFR 91.7(a). Given the rules of operation and maintenance listed above, an equivalent level of safety can be achieved since no standard of air worthiness currently exists and no air worthiness certificate can be issued.



### 3.14 14 CFR 91.9(b)(c): Civil aircraft flight manual, markings, and placard requirements

Laymon International LLC requests an exemption from 14 CFR 91.9(b)(c). There is no method for approval of sUAS manuals currently, there is no place to carry such a manual on board the aircraft, and no pilot on board to reference it. The flight manual must however be kept at the ground control location for PIC reference. As referenced earlier due to the aircraft small size full sized marking are not possible. With an exemption the proper marking can however be prominently place on the sUAS in the most visible manner.



### 3.15 14 CFR 91.103(b)(2): Preflight action

Laymon International LLC requests an exemption from 14 CFR 91.103(b)(2). Since all flights are to be carried out 5 nautical miles from any airport and only in class G airspace CFR 91.103(b)(2) does not apply. However, preflight operations will take place with approval of an exemption.



### 3.16 14 CFR 91.105: Flight crew members at stations

Laymon International LLC requests an exemption from 14 CFR 91.105 as there will be no crew members aboard the sUAS.



### 3.17 14 CFR 91.109: Flight instructions, Simulated instrument flight and certain flight tests

Laymon International LLC requests an exemption from 14 CFR 91.109. Remote controlled sUAS are designed or constructed without dual controls. The equivalent level of safety is provided by the limited size, speed, weight, and altitude of the aircraft in addition to no pilot or crew aboard the aircraft.



### 3.18 14 CFR 91.119(b)(c): Minimum safe altitudes: General

Laymon International LLC requests an exemption from 14 CFR 91.119(b)(c). Laymon International LLC will operate the sUAS at an altitude not to exceed 400 feet AGL for safety. With the sUAS’s small size and weight an equivalent level of safety to manned flight can be maintained while flying closer than 500 feet from structures and the ground.

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### 3.19 14 CFR 91.121: Altimeter readings

Laymon International LLC requests an exemption from 14 CFR 14 CFR 91.121. The sUAS being flown will have live feedback of altimeter and will maintain an altitude below 400 feet AGL at all times. With PIC and VO using line of sight operation and telemetry, equivalent safety levels will be met.



### 3.20 14 CFR 91.151: Fuel requirements for flight in VFR conditions

Laymon International LLC requests an exemption from 14 CFR 91.151. Petitioner believes that an equivalent level of safety can be met by limiting flight times of the sUAS to 15 minutes or until 25% battery charge remains whichever is greater. Due to the limited flight times of a sUAS it is not possible to comply with Part 91.151.



### 3.21 14 CFR 91.203(a)(b): Civil aircraft: Certification required

Laymon International LLC requests an exemption from 14 CFR 91.203(a)(b). Currently there are no FAA procedures for providing an air worthiness certificate. With the automatic return to home feature, in the rare event of a radio control link disruption, the reduced speed, distance of flight, light weight, and 400 feet. AGL altitude limit, and no on board flight crew will combine to provide a greater degree of safety to the public than conventional flight operations with air worthiness certificates.



### 3.22 14 CFR 91.215: ATC Transponder and Altitude Reporting Equipment and Use

Laymon International LLC requests an exemption from 14 CFR 91.215. ATC transponders are not commercially available in a size and weight that can be affixed to the sUAS and be flown safely. Given the flight operation parameters, their will be no need for air traffic control communication and a request for exemption is requested for CFR 91.215.



### 3.23 14 CFR 91.405(a)(d): Maintenance Required

Laymon International LLC requests an exemption from 14 CFR 91.405(a)(d). Since sUAS will be flown without passengers and these sections concern inspection requirements for passengers, Laymon International LLC requests an exemption. As noted earlier placard placement on the small form factor of an sUAS is not practical and also should be exempted. Log books detailing repairs and maintenance will be keep on file.



### 3.24 14 CFR 91.407: Operation after maintenance, preventive maintenance, rebuilding, or alteration

Laymon International LLC requests an exemption from 14 CFR 91.407. To achieve an equivalent level of safety Laymon International LLC will follow the maintenance requirements outlined in the DJI maintenance manual (attachment 4) as well as maintain detailed inspection and maintenance records.

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### 3.25 14 CFR 91.409: Inspections

Laymon International LLC requests an exemption from 14 CFR 91.409. This section is applicable more for large manned aircraft with longer flight times than that of an sUAS. Laymon International LLC believes that the pre and post flight inspections outlined in Section 2.2.3 above will meet the equivalent level of safety required.



### 3.26 14 CFR 91.417: Maintenance records

Laymon International LLC requests an exemption from 14 CFR 91.417 as it pertains to aircraft with an air worthiness certificate. To achieve an equivalent level of safety Laymon International LLC will keep all maintenance records and a complete listing of parts replaced.

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