Southwest I ndependent School District Ruben Villanueva Moreno, Le ad A/V Technician 11914 Dagon Lane San Antonio Tx, 78252 rumoreno@swisd.net October 2, 2015 U.S. Department of Transportation Docket Operations, Room W12

- 140 West Building Ground Floor 1200 New Jersey

Avenue, S.E. Washington, D.C. 20590
Petition of Southwest I

ndependent School District for Exemption pursuant to Section 333 of t he FAA Reform Act.
Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), and 14 CFR Part 11, Southwest I SD and Ruben Villanueva Moreno (collectively , the “Applicant”), operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial photograph y and videograph y, hereb y applies for an exemption from certain Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such ope rations are conducted within and under conditions outlined herein or as may be established b y the FAA as required b y Section 333.1 As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensi ve sUASs under controlled airspace that is (1) limited; (2) predetermined; and (3) controlled as to access. Approval of this proposed exemption would thereby enhance safety

and fulfill the Secretary

of Transportation’s (the “FAA Administrator’s”) responsib ilities to “establish requirements for the safe operations of such aircraft systems in the national airspace sys tem.” Section 333(c) of the Reform Act.
**Summary:** The Applicant is a media/technology department within a Public school district. Lead technicia n Ruben Moreno plans to ope rate a sUAS to provide commercial services including aerial2

surveying, event photography and vide ography , research and development of properties owned by SWI SD and videography and site inspections. The Applicant see ks an exemptio n to operate the 3DR Solo Quadcopter (the “Solo ”) for limited access and for NO Compensation and is NON hirable to third parties, within the National Airspace (“NAS”). The Solo is a vertical takeoff and landing sUAS with a Ground Control Station utilizing electronic tablet or sm art phone systems, Specifications include:

- Cameras of the GoPro variety; Hero3; Hero3+; Hero4

- Flight time 25 min; 20 min w/Pay load

- Range of .5 Miles or .8Km

- Max Speed: 55mph (89km/h)

- Max Ascent 10m/s; 5 m/s in auto pilot mode

- Max descent 10m/s; 5m/s in auto pilot mode

- Max Payload 420 grams

- Max altitude is 400ft

- Motors (4) are 880kv

- Propellers (4): 10” diameter 4.5”

- Autopilot uses PixHawk 2 program

- Software APM:Copter

- Comms 3DR L i nk secure WiFi Network

- Frequency

2.4 GHz

- Weight 3.3 lbs (1.5Kg)/ 3.9 lbs (1.8Kg) with gimbal and GoPro

- Dimensions 10” tall 18” motor to motor

- Flight Battery

L ithium Poly

mer 5200 mAh 14.8Vdc

- Battery charge time Approx. 1.5 hrs

- controller battery

2600m Ah 7.2 Vdc Rechargeable Lithium Ion

- App requirements iOS 8 or later/ Android 4.3 or Later3

The sUAS will operate only in line of sight and will operate in accordance with the User Manual. All flights will occur over SWI SD Properties wi th the District’s duly appointed representative’s prior consent and knowledge.
The sUAS will be operated by Ruben Moreno. Ruben has training and experience operating the Solo. Including approximately 40 hours of su pervised operations as the Operator in charge of the Solo

. Ruben’s experience will ensure that the sUAS is safely operated at all times.
Statutory Authorit y Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a mechanism for seeking expedited FAA authorization of safe civil UAS o perations in National Airspace (“NAS”). Section 333(a) states that the FAA “shall determine if certain unmanned aircraft s ys tems may operate safel y in the national airspace s ys tem before completion of the (comprehensive) plan and rule making required by Se ction 332(b)(1) of this Act or the guidance required b y section 334 of the Act.” In Section 332(b)(1), Congress made it clear that Section provides a mechanism for “expedited operation authorization” if several factors are met. The Applicant meets all requ irements (With the exception of a Private Pilot’s license) to permit FAA approval of commercial UAS operations and such an exemption should be granted.
In accordance with 14 CFR § 11.81, the Applicant provides the following information in support of its p etition for exemption.

**1. Contact Info**  Southwest I

ndependent School District Ruben Villanueva Moreno, A/V Technician 11914 Dagon Lane San Antonio Tx, 78252 rumoreno@swisd.net

**2. The Specific Sections of Title 14 of**  **the Code of Federal Regulations From Which Annapolis Drone Operations, LLC Requests Exemption are:** 4

14 CFR Part 21 Subpart H 14 CFR Part 27, Airworthiness Standards: Normal Category Rotorcraft 14 CFR § 45.23(b) 14 CFR § 61.113(a) & (b) 14 CFR § 91.7(a) 14 CFR § 91.9(b)(2) 14 CFR § 91.103 14 CFR § 91.109 14 CFR § 91.119 14 CFR § 91.121 14 CFR § 91.151(a) 14 CFR § 91.203(a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405(a) 14 CFR § 407(a)(1) 14 CFR § 409(a)(2) 14 CFR § 417(a) & (b) 14 CFR § 91.401

- 9 1.4175

**3. The extent of relief you seek, the reason you seek the relief, and the reasons why the**  **exemption will not adversely affect safety.**
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airwo rthiness certificates as required by 14 CFR § 91.203(a)(1). Given the size and limited operating area associated with Phantom 3, an exemption from Part 21, Subpart H meets the requirements of an equivalent level of safet y under Part 11 and Section 333 of t he Reform Act. The Federal Aviation Act (49 USC § 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircrafts from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capab ility , and proximity to airports and populated areas of the particular UAS. In all cases an analys is of these criteria demonstrates that a sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed w ill be at least as safe, or safer, than a conventional aircraft (fixed

- wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. Here an equivalent level of safety will be reached because the sUAS to be operated hereunder is less than 55 lbs. fully

loaded, carries neither a pilot nor passenger, and carries no explosive materials or flammable liquid fuels. Based on the sUAS’s light weight and carbon fiber and plastic construction, the sUAS will be at l east as safe, if not safer than a conventionally certificated aircraft performing the same mission. These safet y enhancements, which alread y appl y to civil aircraft operated in connection with existing inspection operations, provide a greater degree of saf et y to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastl y, application of these same criteria demonstrates that there is no credible threat to national securi ty posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 CFR Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the Applicant’s sUAS would otherwise require certification under Part 27, as a rotorcraft, the Applicant requests an exemptio n from Part 27’s airworthiness standard for the same reasons identified in the exemption request from 14 CFR Part 21, Subpart H.6

The Application seeks an exemption from the aircraft marking and identification requirements in 14 CFR 45.23(b), 45.27(a), and 91.9(c). These regulations require that when marks include onl y the Roman capital letter “N” and the registration number is displ ay ed on limited, restricted or light sport category

aircraft or experimental or provisionally certificated aircraft, the operator must also display

certain terms near each entrance to the cabin, cockpit, or pilot station, in letters not less than two inche s or more than six inches high. Here, the sUAS will not be issued an airworthiness certificate and there will be no cabin or cockpit upon which certain words may be display ed. An equivalent level of safety for these exemptions will be reached by having the sUAS marked on its fuselage where the pilot, observer, and others working with the sUAS will see the identification of the sUAS as “Experimental”. The Applicant will also comply with an y further requests for sUAS markings b y the FAA. The regulation provid es that no person that holds a Private Pilot certificate may act as a Pilot in Command (“PI C”) of an aircraft for compensation or hire. Subpargraph (b) allows a private pilot to act as a PIC of an aircraft in connection with any business or employment if t he flight is incidental to that business or employment, and the aircraft does not carry passengers or property for compensation or hire. Because the sUAS will not carry a pilot or passengers and is inherently stable with a sophisticated computer and GPS co ntrols, the proposed operations meet the equivalent level of safety as the regulation b y requiring the PIC operating the sUAS to have significant and extensive experience operating the sUAS in a non

- commercial environment. Furthermore, the area of operatio n is controlled and restricted, and all flights are planned and coordinated in advance according to the User Manual, and the flights are of limited duration and altitude. 14 CFR 91.7 Civil Aircraft Airworthiness. No such airworthiness certificate will be i ssued for the sUAS and therefore this regulation is inapplicable to the Applicant’s sUAS. The Applicant will ensure that the sUAS is in airworthy conditions based upon compliance with the operating documents prior to every flight, and determine that the sU AS are in safe operational condition. Given the size of the sUAS and the requirements contained in the User Manual for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. 14 CFR 91.9 Civil Aircraft flight manual, marking and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The applicant believes the intent of this regulation is to ensure that flight manual information is available to the aircrew while operating the aircraft. The Applicant requests an exemption because the aircraft to too small to carry the documentation, and the7

documentation would not be available to the crew during flight operations. T o obtain an equivalent level of safety and meet the intent of Section 91.9, the Applicant proposes that a User Manual be made available to the crew at the ground station anytime the aircraft is in or preparing for flight. 14 CFR 91.103 Preflight Action The Application seeks an exemption from 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. An FAA approved Flight Manual will n ot be provided for the sUAS, and therefore an exemption is required. An equivalent level of safet y will be provided by following the sUAS Manual’s comprehensive preflight checklist. The PI C will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data, before initiation of flight. 14 CFR 91.119 Minimum Safe Altitudes. The regulation establishes safe altitudes of civil aircraft and states that the minimum safe altitude requiremen ts under which an aircraft may not operate, include 500 feet above the surface and away from any person, vessel, vehicle or structure in non

- congested areas. Section 91.119(d)(1) allows for a helicopter to operate at less than those altitudes when it can b e operated without hazard to persons or property on the surface, provided that each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopter by the FAA. To provide the intended photography and inspections the sUAS will normally need to be operated within a range of between 50 and 200 feet from the propert y b eing filmed or photographed, and therefore an exemption is required. The Applicant submits that an equivalent level of safet y ma y be achieved because o perations will only be flown over property

or persons where permission has been obtained and careful pre

- planned flight path has been performed. The aircraft will be operated at a low altitude allowing, if the power fails, for an emergency landing without undue hazard to persons or property on the surface. Based on the small size of the UAS, the hazard to persons, vehicles and structures is limited when compared to manned aircraft, which should be considered in granting the exception. 14 CFR 91.121 Altimete r settings. This regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fl y b elow 400 feet above ground level (“AGL”) and will not need to maint ain cruising altitudes in order to prevent conflict with other aircraft. An equivalent level of safet y will be achieved b y following the procedures set8

for in the User Manual, and the PIC will use the GPS altitude indicator to constantly monitor the sUAS h eight, thus ensuring operation at safe altitudes. 14 CFR 91.151 Fuel Requirements for flight in VFR Conditions. The regulation provides that no person may begin a flight in an airplane under VFR conditions unless there is enough fuel to fly to the first po int of intended landing and to fly after that for at least 30 minutes, or if in a rotorcraft for at least 30 minutes. The Applicant believes that the intention of this paragraph is to provide an energy reserve as a safet y buffer for delays to landing. The battery

powering the sUAS provides for approximately 23 minutes of powered flight. An equivalent level of safety can be achieved b y limiting flights to 20 minutes or 25% of remaining battery power, whichever happens first. This restriction would be more th an adequate to return the sUAS to its planned landing zone from an ywh ere within its limited operating area. Operation of the sUAS with less than 30 minutes of reserve fuel does not engender the type of risks that. Moreover, operation will be limited to con trolled areas where only people and propert y owners or official representative who signed waivers will be allowed. Based on these considerations an equivalent level of safety will be ensured. 14 CFR 91.203(a) & (b) Civil Aircraft: Certifications Required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be “disp lay ed at the cabin or cockpit entrance so that it is legible to passengers or crew.” Here the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carry ing passengers or crew. To obtain an equivalent level of safety

an d meet the intent of Section 91.203, the Applicant proposes that documents deemed appropriate for the sUAS be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the info rmation found on airworthiness and registration certificates be permanently affixed to the aircraft view placard containing the following information plus the word experimental to satisfy the requirement of 14 CFR 45.23. 14 CFR Subpart E, Sections 91.401

- 9 1.417

– Maintenance, Preventive Maintenance, and Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworth y condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 r equire that the aircraft be “approved for return to service by a person authorized under 43.7” after maintenance and inspection. I t is the Applicant’s intention that the PIC perform9

maintenance and inspection of the aircraft and “be authorized to approve t he aircraft for return to service.” The Operator will ensure that the aircraft is in an airworth y condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance pe rformed b y the Operator is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated re pair facility . The Operator w ill document work performed in accordance with 91.417. Due to the size, construction and simplicity

of the aircraft, the PIC can ensure an equivalent level of safety is reached.
**Safety and Benefits of the UAS to the Public as a whole** The Applicant will use the sUAS in a variet y o f applications that generall y require expensive and full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer numerous benefits over the use of full

- sized manned aircraft for real prop ert y inspections, and event film and still photography. The safe operation of sUAS will allow a wider range of individuals to obtain the benefits of aerial photograph, at a manageable and reasonable cost. The public as a whole will benefit from the safer a nd more cost

- effective availability of aerial photography. Replacing larger manned aircraft carry ing crew and flammable materials with small UAS carryi ng no passengers or crew provides increased safet y for pilots and crew. By granting the Applicant’s reque sted exemptions, the FAA will assist with the development and safet y of commercial sUAS operations. Therefore, the FAA has good cause to grant this application. **A Summary for Publishing in the Federal Register** Southwest I

ndependent School District and Rube n Villanueva Moreno seeks an exemption from the following rules: 14 CFR Part 21; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 1 4 CFR 91.203(a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417(a) & (b). Annapolis Drone Operations, LCC seeks this exemption for the purposes of conducting aerial photograph y, videograph y and inspections for commercial , l egal, construction and insurance industries, and event photograph and videograph y Southwest Independent School District does not intend to operate the sUAS outside of the United States.

**Conclusion.**10

As set forth herein, Southwest Independents School Distric t seeks an exemption pursuant to 14 CFR 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the 3DR Solo Quadcopter UAS commerciall y, without an airworthiness certificate, for the limited purpose of co nducting aerial video and photography over certain properties of the Southwest I ndependent School District within the Greater San Antonio and surrounding areas . By

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate o f the FAA Modernization and Reform Act of 2012 while also advancing the interest of the public, by allowing the safe, efficient and economical operation of the 3DR Solo Quadcopter UAS commercially within the NAS.

Dated: October 2, 2015

Southwest In dependent School District Media and Public Relations Dept.

Ruben Villanueva Moreno, L ead Technician 11914 Dragon Lane San Antonio Tx, 78252 Cell: (210) 294

- 0338 Office: (210) 6224408 Email: rumoreno@swisd.net11