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AT ES OF AMERICA DEP ART MENT OF TRANSPORTAT ION FEDERALAV IA

TION ADMINISTRA

TION DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY

A VE., SE WASHINGTON, DC 20590 **IN THE M AT**  **TER OF THE PETITION FOR EXEMPTION OF:**



## Ky **le Fleischmann**

**FOR AN**  **EXEMPTION SEEKING RELIEF FROM**  **THE REQUIREMENTS OF THE F**  **AA REFORM**  **ACT AND**  **PA RT 1**  **1 OF THE FEDER AL A**  **VI AT**  **ION REGUL AT**  **I ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA** **L REGUL AT**  **IONS SECTIONS C.F** **.R. §§ 61.1 13 (a) & (b); 91.7(a); 91.1**  **19 (c); 91.121; 91.151(a);**

**91.405 (a); 91.407(a) (1); 91. 409 (a) (2); 91.417 (a) & (b).**  **CONCERNING COMMERCIA L OPER** **AT ION OF UNM**  **AN NED**  **AIR CRA**  **FT SYSTEMS**

**PURSUA NT TO SECTION 333 OF**  **THE F AA**  **M ODERNIZA** 

**TION AN**  **D REFORM ACT**  **OF 2012 (PUBLIC L AW** **1 12**  **- 95)** 

Submitted	on	September	24,	2015 Kyle	Fleischmann 3694	East Brentor	Court Meridian,	ID	83642 godisthetruth777@gmail.com

Kyle	Fleischmann’s	Consultant Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.	Suite	#200 Shakopee,	MN	55379 www .GowdyBrothersAerospace.com Info@GowdyBrothers.com2



### Ta **ble of Contents** Ta ble	of	Contents

................................ ................................ ................................ ................................ ................................ ........... 2 GLOSSAR Y	OF	ABBREVIA

TIONS

................................ ................................ ................................ ................................ ............. 3 INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

................................ ................................ ............................ 4 Ex ecutive	Summary

................................ ................................ ................................ ................................ ................................ ...... 4 Expeditious	Summary	Grant	Approval	Request

................................ ................................ ................................ ......... 4 Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:

................................ ................................ .. 5 Commercial	(Mission,	Operation)	Purpose : ................................ ................................ ................................ ............. 5 Regulations	from	which	the	Ex emption	Relief	is	requested:

................................ ................................ ............ 6 The	n ame	and	address	of	the	Petitioner:

................................ ................................ ................................ .................. 7 Background

................................ ................................ ................................ ................................ ................................ ................. 7 Commitment	to Safety

................................ ................................ ................................ ................................ ....................... 8 Expertise	&	Experience

................................ ................................ ................................ ................................ ..................... 8 The	Ex emption	Request

................................ ................................ ................................ ................................ .............................. 9 Opera tor	Requirements

................................ ................................ ................................ ................................ ....................... 11 Aircraft	and	Equivalent	Level	of	Safety

................................ ................................ ................................ ......................... 14 Specific	Uses	Public	Benefits

................................ ................................ ................................ ................................ ............. 18 Equiva lent	Level	of	Safety

................................ ................................ ................................ ................................ ................... 19 14	C.F .R.	§	91.7(a):	Civil	aircraft	airworthiness.

................................ ................................ ................................ ... 20 14	C.F .R.	§91.119:	Minimum	safe altitudes

................................ ................................ ................................ ............. 21 14	C.F .R.	§91.121	Altimeter	Settings

................................ ................................ ................................ ......................... 21 14	C.F .R.	§	91. 151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

................................ .................... 21 14	C.F .R.	§91.405	(a);	91.407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance	Inspections

. 22 Fe deral	Register	Publication

................................ ................................ ................................ ................................ ................... 23 Privacy	and	National	Security

................................ ................................ ................................ ................................ ................ 23 Summary

................................ ................................ ................................ ................................ ................................ ......................... 24 APPENDIX	A
- EXEMPTION	P AT TERN

................................ ................................ ................................ ........................... 26 APPENDIX	B
- TECHNICAL	MANUALS	AN D	SPECIFICA TIONS

................................ ................................ ........... 27 APPENDIX	C
- COMMERCIAL	(MISSION/OPERA TION)	PURPOSE

- FAA	PREVIOUS	APPROVED EXEMPTION	NUMBERS

................................ ................................ ................................ ................................ ....................... 28 APPENDIX	D
- EQUIPMENT
- FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS

................................ . 29 APPENDIX	E
- EXEMPTION	14	C.F .R
- FAA	PREVIOUS	APPROVED	EXEMPTI ON	NUMBERS

................ 30 APPENDIX	F
- MONTHL Y	MAINTENANCE AND	REP AIR	LOG

................................ ................................ ............. 31 APPEN DIX	G

– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERA TIONS	MANUAL	VERSION	1.0

................................ ................................ ................................ ................................ ................................ ................................ ......... 32Page 3 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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## GL**OSSARY OF ABBREVIA TIONS** 

AGL Above	Ground	Level AOI Area	of	Interest AT C Air	T ra ffic	Control AT O Air	T ra ffic	Organization AV Aerial	V ehicle CFR Code	of	F eder al	Regulations COA Certificate	of	Authorization FAA Fe der al	A viation	Administration FA R Fe der al	A viation	Regulation GCS Ground	Control	Station GPS Global Po sitioning	System LOL Loss	of	Link NAS National	Airspace	System NO TA M Notice	To	Airman PIC Pilot	In	Command Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333 SO Safety	Observer SOP Standar d	Operating	Procedures sUAS Small	Unmanned	Aircraft	System sUAV Small	Unmanned	Aircraft	V ehicle UA Unmanned	Aircraft UAS Unmanned	Aircraft	System UA V Unmanned	Aircraft	V ehicle VFR Visual	Flight	Rules VLOS Visual	Line	of	Site VMC Visual	Meteorological	Conditions VTOL Ve rtical	T ake - Off	and	Landing4



## INTRODUCTION AND INTERESTS OF THE PETITIONER
Dear	Sir	or	Madam: Pursuant to Section 333 of the FAA Modernization and Re form Act of 2012 (the “Reform Act”) and 14 C.F .R. Part 11, Kyle Fleischmann, (“K yle Fleischmann ”) Oper ator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on demand commercial UA S operations for a host of industries and applications and to perform the purposes listed below , hereby applies for an exemption from the listed Fe deral Av iation Re gulations (“F AR s”) to allow commercial operation of its sUAV’s/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted	under	either	Section	333	or	Section	49	U.S.C.	§44701(f ) As described more fully below ,	the	requested exe mption	would	permit	the	oper ation of a UA S under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will	oper ate,	whi ch	now	depend	upon	conventional	aircr aft	or	humans	climbing	high on dangerous structures, wa lking in insect laden swamps, and working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Tra nsportation ’s (the FAA Administrator’s) responsibilities to “... e stablish requir ements fo r the safe operation of such aircraft systems	in	the	national	airspace	system.”	Section	333(c)	of	the	Reform	Act. 1


## Ex**ecutive Summary Expeditious Summary Grant**  **Approval Request** The petitioner requests the agency issue a summary gr ant process for this application. Pe titioner has provided in a confidential document attachment labeled as	petitioner	proprietary	information,	specific	ex emption	numbers	whereby	the	F AA has already granted a previous exemption similar or identical to each and every request,	herein. Fo r the FAA’ s benefit, Pe titioner’s Consultant, Gowdy Brothers Aerospace, LLC, has researched, categorized and arranged all 631 exemptions granted as of June 23,

1 Kyle	Fleischmann	relies	upon	the	following	ex emptions	where	specific	ref erence	to an	ex emption	is	not	pr ovided:	Ex emptions	11062	thru	11067,	11080,	11109 through	11112,	11114,	11213,	11062	and	as	recent	as	11857.Page 5 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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- 9551 2015 into a usable searchable database, based upon the following criteria: date submitted, date gr ant issued, time to petition gr ant, petitioner , petitioner’s state, exemption number

,	sUAV equipment	type,	gr ant	purpose	(mission/oper ation),	along with other	supporting	data. Pe titioner has identified four previous approved exemptions for each of the Pe titioners	F

AA	submission	requests:

 Commercial	(mission/operation)	purposes;
 Type	of	sUAV’s	(UAS);
 Title	14	Ex emptions	(exemption	pattern	referenced	in appendix	A) 2 

### Description of T

**ype, Mak e and Models of sUA**  **V/ UA**  **S Requested:** The petitioner is seeking an exemption to commercially operate sU AV’s makes and modes	as	follows: DJI
- Phantom 2, DJI
- Phantom 3, DJI
- Inspir e 1, DJI

– Spreading Wings S800, DJI

– Spreading Wings S900, DJI

– Spreading Wings S1000, DJI

– Matrics 100, Cinestar 8 Octo, Altavian Nova F6500, Blade 350 QX 3, AgEagle, 3DRobotics X8, 3DRobotics Iris, 3DRobotics Solo, SenseFly eBee, Yu neec Q500 Typhon, DraganFlye r X4
- ES, Tr imble UX5,	Micro drones	MD4 Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. Equipment	oper ation	manuals	for	each	sUAVare	included	for	your	reference	and	are considered confidential information for each respective company’s UA S and are affix ed	separately	in	these	documents	labeled	Appendix. 

### Commercial (Mission, Operation) Purpose: This exemption request, once granted wo uld allow the petitioner to operate a small unmanned aerial ve hicle (sUAV), unmanned air craft system (UAS) to conduct bridge Inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of re sidential and

2 Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential busi ness inf ormation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Section	333	(b).6

commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematogr aphy, a nd videography, p recision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction	site	inspection	and	monitoring,	public	entity	support	oper ations,	Aerial imaging for safety

, monitoring and comparing work efforts and comp letion percentages, and security of controlled environment of va rious sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use	including	television,	public	events,	and	cinematogr aphy live feed and live newsgathering, tr aining to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UA S operations within the NAS , special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production 3 , surface mining, closed set filming 4 , disaster	and	catast rophe	events. 

### Regul **ations from which the Exemption Relief is requested:** 14	C.F .R.	§	61.113	(a)	&	(b) 14	C.F .R.	§	61.133(a) 14	C.F .R.	§	91.7(a) 14	C.F .	R.§	91.119 14	C.F .R.	§	91.121 14	C.F .R.	§	91.151	(a) 14	C.F .R.	§	91.405	(a) 14	C.F .R.	§	407	(a)	(1) 14	C .F .R.	§	409	(a)	(2) 14	C.F .R.	§	417	(a)	&	(b) See	Appendix	E

3 Motion	Picture	and	Television	Flight	Oper ations	Manual	is	herein	attached	as Appendix	G.
4 Motion Picture	and	Television	Flight	Oper ations	Manual	for	closed	set	filming	is herein	attached	as	Appendix	G.Page 7 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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### The name and address of the Petitioner: Attn:	K yle	Fleischmann 3694	East	Brentor	Court Meridian,	ID	83642 Please	direct	any	question	or	comment	regarding	this	petition	to	P etitioners Con sultant:	Gowdy	Brothers	Aerospace,	LLC. 8170	Old	Carriage	Court	N.,	Suite	#200 Shakopee,	MN	55379 www .GowdyBrothersAerospace.com Info@GowdyBrothers.com


### Back **ground** The Pe titioner

, Kyle Fleischmann is a highly accomplished, capable, experienced and trusted	professional. Kyle Fleischmann, is an independent contr actor based in Meridian, ID. Kyle provides precision agriculture, video and photo, including television publ ic events and cinematogr aphy to a variety of clients. Now , Kyle wa nts to use the drones listed below in a commercial enterprise by offering the services list above. Kyle has had some good recreational experience operating the Phantom 1 and the Inspire 1. K yle does not have a pilot's license but he does plan on taking the sport pilot course in the	near	future.	K

yle always follows and pr actices	safety	rules	and	regulations	and	is committed to adhering to all applicable standards and regulations while flying o r flight planning. Kyle has his certification at the University of UXV in Phoenix, AZ for UA V	Pilot	T ra ining.8



### Commitment to Saf**ety** As part of its commitment to safety and innovation, Kyle Fleischmann is asking for this exemption in part, to re duce the risk of injury to its employees and contr actors who participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natur al habitat, buildings and other structures within	the	United	States.



### Ex **pertise & Experience** Kyle Fleischmann due to his professional experience as a trusted sUAV p ilot is extremely qualified	and	is	considered	an	up	and	coming	subject	matter	expert	in	the Idaho	area	for	UAS	of	all	types,	models	and	makes.Page 9 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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## The Ex**emp tion**  **Re quest**  Kyle Fleischmann proposes the use of the sUAV’s will be for capture of high resolution imagery and video of residential or commercial applications and purposes to a level of quality that allows the Pe titioner to use the imagery to identify ,	record ,	memorialize	events	and	objects	according	to	the	purposes	noted. The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure to conduct bridge inspections, flar e stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photogr aphy and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to el ectrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematogr aphy, a nd videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety , monitoring and comparing work efforts and completion percentages, and security of controlled environment of va rious sites, aerial video and live video feed to assist with search and rescue oper ations under the authority and support of local authority officials, aerial video and photography fo r public and private use including television, public events, and cinematography live feed and live newsga thering, tr aining to persons individually or belonging to both private and public organizations to increase awareness	and	improve	safety	for	current	and	future	UAS	operations	within	the	N AS, special events: including high schools, colleges, professional sp orts, open air events and fairs research, risk management and assessment, motion picture production, surface	mining,	closed	set	filming,	disaster	and	catastrophe	events. The UA S will be operated by Kyle Fleischmann and or contr acting operators on occasio n to capture high

- resolution imagery/video of large structures (wide and tall) such as wa rehouses, high rise buildings, bridges, and construction sites, as well as “birds eye” views of fire and explosion sites. Given the small size of the sUAV’s invo lve d, no more than 55 lbs., majority of the speed of operation be between 5

- 15 mph and the restricted environment within which they will operate, the Pe titioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisione d that the FAA must, by exemption, allow commercial operations of	UASs	to	commence	immediately. This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Re form Act. This law directs the Secret ary of Tra nsportation	to	consider	whether	certain	unmanned	aircr aft	systems	may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Re fo rm Ac t. In making this determination, the Secreta ry is required to determine which types of UA Ss do not create a hazard to10

users of the NAS o r the public or pose a threat to national security in light of the following:

 The	UAS’	size,	weight,	speed,	and	operational	capability;
 Oper ation	of	the	UAS	in	clo se	proximity	to	airports	and	populated	areas;	and
 Oper ation	of	the	UAS	within	visual	line	of	sight	of	the	Oper ator
. Re form Act § 333 (a). Lastly, i f the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secr e tary shall establish requirements for the safe operation of such air craft in the national airspace system.” Id.	§333(c)	(emphasis	added). 5 The Fe deral	A

viation	Act	expressly grants the	F AA the	authority	to	issue	ex emptions. This statutory authority ,	by	its	terms,	includes	e xe mpting	civil aircraft,	as	the	term	is defined under §40101 of the Act: The Administrator may gr ant an	ex emption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702
- 44716 of this title if the Administrator finds the exemption is in the public interest. 49 U. S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to gr ant exemptions reaches such issues as authorization of commercial operat ion of aircraft without an FAA issued pilot’s	license. Kyle Fleischmann in filing this application is re questing that the FAA combine the grant of the Section 333 exemption with a standard Certificate of Oper ation (COA) that will allow commercial operatio ns of its Kyle Fleischmann ’s sUAV w ithout the necessity	of	filing	for	a	COA	f or	each	flight,	unless	such	flight	is	to	be	conducted	in	an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 exemptions,	provide	the	separation	needed	from	other	aircraft. In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as den oted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained, Kyle Fleischmann requests that operations over congested or densely populated areas be allowed. The new sUAV’s do have GPS geo fenc ing,	it	will	oper ate	at	a	very	low	altitude,	within	confined	areas,	at	low	speed	and weighs no more than 55 lbs.. Such operations will only be under

- taken with the approval of the land or home owner , as set forth herein, and will comply with the requiremen ts that operations be no closer than 500 feet to the adjacent building

5 5 Applicant interprets this provision to place a duty on the Administrator to not only process applications for exemptions under section 333, but fo r the Administrator to craft conditions for the safe operation of the UA S, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements	for	approval.Page 11 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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### Operator Requirements
Given the sUAV

p roposed by Kyle Fl eischmann, Oper ators should not be required to hold	a	private	pilot	license.	K yle	Fleischmann	believes	that	1)	the	operator ,	instead	of understanding how to operate a	passenger	carrying	aircr aft,	should	have	knowledge and experience that enables the saf e o peration of a small, re motely piloted sUAV should understand airspace restrictions and know how to ensure separation from other aircraft as well as non - participants and property; 2) the sUAV h as built

- in technical capabilities that limit the potential fo r unsafe operation and 3) there are other	security	screening	mechanisms	already	in	existence	that	K yle	Fleischmann	will utilize to ensure the operators are acting consistently with national security interests. Given the sUAV safety features outlined below , Kyle Fleischmann proposes that its operations under this Ex emption request should not be required to hold a commercial or private pilot certification. Instead, Oper ators should be required to: have	successfully	completed,	a t	a	minimum,	F AA	private	pilot	ground	instruction	and passed the FAA Private Pilot written examination or FAA
- recognized equivalents; have	completed	K

yle	Fleischmann ’s	tr aining	pr ogram	for	operation	of	the	UAS. Kyle Fleischmann notes that 1) the FAA has f ound that safety factors permitted operation of sUAV’s by Oper ators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were	present;	and	2)	that	the	Notice	of	Proposed	Rulemak ing	entitled	Oper ation	and Certification of Small Unmanned Aircraft Syste ms, 80 F. R. 9544 (F ebruary 23, 2015) (“NPRM”), does not require the operator to hold a private pilot license or a thir d class	medical. Adva nced sUAV’s has	a navigation and control s ystem and auto - pilot	that	allows	it	to execute ve ry accur ate pr e - programed flights. Flights are pre - programmed with GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights under auto - pilot are not directed by positive m anua l input, but through pre programmed flight par ameters that are executed by the auto - pilot. In the case of unplanned events, the Oper ator inputs preprogrammed evasive maneuve rs from the control	unit,	and	the	autopilot	ex ecutes	those	maneuve rs.	Pre
- programme d	Oper ator interventions include: initiation of holding at pr esent position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency	power	cut	off	and	land	(flight	termination	system).	Additional	automated safety functions and saf ety enhancing features of the Adva nced sUAV’s may include the	following:12 1) Auto
- pilot detection of lost GPS or of insufficient satellites initiates an immediate	landing, 2) L ow power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.	Low	power	below	10%	triggers	an	immediate	landing, 3) I f the auto - pilot detects a lost

- link to the ground controller , the UAS w ill hold position at its current location for 5 seconds and if the signal is not restored, execute	a	return to	home	and	land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in	flight	in	the	event	of a	loss	of	control	or	un

- commanded	deviation	from	the flight	path, 5)		The	aircraft,	weighs	less	than	55	lbs.,	full y	loaded, 6)		The motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals, 7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum	of	400	feet	AGL. See Fe dera l Av iation Administration, Notice N
- 8900.227, Unmanned Aircraft Systems (UAS) Oper ational Approval, at 20
- 21 (July 30, 2013); As the FAA has determined in Ex emptions 11062 thru 11067,11080 and 11110 (the “Ex emptions”), in comparing the requirements for priva te pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, wa s sufficient to allow private pilots	to	oper ate	sUAV’s	under	those	ex emptions. Bas ed upon that analysis, Kyle Fleischmann believes successful completion of FAA private pilot ground school is a suitable predicate to operating the sUAV u nder this exemption. Kyle Fleischmann proposes that the Oper ator accumulate required sUAV flight tr aini ng hours through the operation of sUAV’s ra ther than flight hours in conventional aircraft. Those hours are more relevant to the operations proposed herein than hours gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Thos e air craft are orders of magnitude heavier than the sUAS and carry not only the pilot himself, but also passengers and fuel, none of which is carried in the sUAS. These conventional aircraft fly over all sorts of airspace without the	permission	or	knowledg e	of	the	landowner

. A handheld ra dio controller controls the	sUAV a nd the	vehicle	is	oper ated within	the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are releva nt to UA S operations, can be taught in the tr aining proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55 pound aircraft, operating at less than 30 mph during filming operations are those taught in ground school and in flight tr aining with the particular UA S and not gained from accumulating flight hours in a fix ed wing or rotorcraft	gas	or	jet	A	powered	aircraft	completing	cross	country	flights	and	take	offs and	landings	at	controlle d	and	uncontrolled	airports.Page 13 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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- 9551 As to national security review of pilots, each of Kyle Fleischmann ’s pilots/oper ators will obtain internally provided certified tr aining ( Ground and Practical) from Kyle Fleischmann to oper ate the sUAV

. This review and certi fication could reasonably ve t the Oper ators against any known terrorist or no fly listings that are relevant and publically	available. Kyle Fleischmann additionally asks that the exemption be issued without the requirement for a visual observer . As set fo rth herein, an equivalent level of safety is provided by the size, speed and control capabilities of the aircraft, as well as the operational procedures that will be applicable to all flight hereunder

. These obviate the	need	for	the	visual	observer . The	O perator	will	be	oper ating	the	aircr aft,	al ways within	line	of	sight.	He	or	she	will wa lk and follow the aircraft around the inspection area so that while it is flying its pre - programed and at times, manual flight path, the UA S will al ways b e directly in hi s or her line of sight. The Oper ator will not be distracted by viewing the pictures taken during the flight. Rather , once the sUAV

i s launched, the Oper ator’s only duty will be to wa tch the flight of the UA S over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances fr om the launch area will not be necessary as the Oper ator will al ways h ave the aircraft in his or her di rect sight. The observer also will not be necessary because the Oper ator will conduct a pre - flight inspection of the area, will and if needed, cordon off the area and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	oper ating. Kyle Flei schmann again notes that the NPRM does not require the use of a visual observer . Given the clear direction in Section 333 of the Re fo rm Act; the authority contained in the Fe deral Av iation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety , reduction in envir onmental impacts, including reduced emissions associated with allowing battery powered sUAV’s for these functions instead of turbine or gas power airc ra ft/rotorcraft and operations	with	pilots	having at least a private pilot license, the grant of the re quested exemptions is in the public interest. 6

6 Should the FAA determine that it cannot gran t such an exemption fo r operations without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the FAA already has, Kyle Fleischmann will operate its aircraft with pilots	holding	at	least	a	pri va te	pilot	certificate	issued	by the	F AA.	In	that	event, Kyle Fleischmann requests that the exemption be granted with conditions similar to those	contained	in	numbered	paragr aphs	14

- 15	in	Ex emption	1113614



### Aircraft and E

**quivalent Level of Safety** The Pe titioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Ex emptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112 ,	and	11213	and	as	recent	as	11857. These limitations and conditions to which Kyle Fleischmann (referred to as “Oper ator”) agrees to be bound when conducting commercial operations under an FAA	issued	ex emption	include:

1) Oper ations authorized by this grant of exemption are limited to the aircraft described in the Oper ator’s manual, which is a multi

rotor weighing up to 55 pounds: Proposed operations of any other aircraft will require a new petition or a petition to amend this	gr ant. 2) The UAm ay not be flown at an indicated airspeed exceeding 30 mph	(10	mph	during	inspections). 3) The UAm ust be operated at an altitude of no more than 400 feet above ground level (A GL), as indicated by the procedures specified in the Oper ator’s manual. All altitudes reported to AT C must	be	in	feet	A GL. 4) The	UA	must	be	oper ated	within	visual	line	of	sight	(VLOS)	of	the Aircraft Oper ator at all times. This requires the Aircraft Oper ator to be able to use human vision unaided by any device other than corrective	lenses.. 5) The	Ex emption	H older’s	Manuals	must	be	amended	to	include	all conditions and limitations required by the FAA. The Manuals must be maintained and made ava ilable to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exempt ion and the procedur es outlined in the Ex emption Holder’s Oper ator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Oper ator must follow the procedures as outlined in its Aircraft’s man ual. The Ex emption Holder may update or revise its Manuals. It is the Ex emption Holder’s responsibility to tr ack such revisions and present updated and revised documents to the Administrator uponPage 15 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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request. The Ex emption Holder must also present updated and revised documents if it petitions for an extension or amendment of this exemption. If the Ex emption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Ex emption Holder must petition	for amendment	to	its	ex emption. 6) Prior	to	each	flight,	the	Aircr aft	Oper ator	must	inspect	the	UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UA S, the aircraft is prohibited from o perating until the necessary maintenance has	been	performed,	and	the	UAS	is	found	to	be	in	a	condition	for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly	documented	in the	aircraft	records. 7) Any UA S that has undergone maintenance or alter ations that affect the UA S operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption ho lder’s Manuals. The Aircraft Oper ator who conducts the functional test flight	must	make	an	entry	in	the	UAS aircraft	records	of	the	flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemptio n Holder’s Oper ator’s	manual. 8) The Ex emption Holder must follow the manufacturer’s UA S aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be a ddressed in the manufacturer’s	manuals. 9) The Ex emption Holder must carry out its maintenance, inspections, and record ke eping requirements in accordance with the Oper ator’s Manuals. Maintenance, inspection, and alter ations must be noted in the aircraft logb ook, including total flight	hours,	description	of	work	accomplished,	and	the	signature of	the	authorized	technician	returning	the	UAS	to	service. 10) The authorized technicians must receive and document tr aining referenced	in	the	Ex emption	Holder’s	Manuals. 11) E ach UA S operated under this exemption must comply with all manufacturer	System	and	Safety	Bulletins. 12) The Ex emption Holder’s maintenance personnel must make a record entry in the UA S logbook or equivalent document of the16 corrective action taken against disc repancies discovered between	inspections. 13) Prior to commencing operations,	the	Aircr aft	Oper ator shall have logged at least 25 hours of total time as a UAr otorcraft pilot and at least ten hours logged as a UApilot with a similar UAtype and 5	hours	in	the make	and	model. 14) If the UA S loses communications or loses its GPS signal, the UA must return to a pre - determined location within the private or controlled

- access property and land or be recovered in accordance	with	the	Ex emption	Holder’s	Manuals. 15) The Aircraft Oper ator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Ex emption	Holder’s	Manuals. 16) The Aircraft Oper ator is prohibited from beginning a UA S flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the ex emption must be identified by serial number , registered in accordance with 14 CFR part 47, and have i dentification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large	as	pr acticable. 18) Before conducting operatio ns, the ra dio frequency spectrum used for operation and control of the UAm ust comply with the Fe deral Communications Commission (FCC) or other appropriate	government	oversight	agency	requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must b e ava ilable to the Oper ator at the Ground Control Station of the UA S any time the aircraft is operating. These documents must be made ava ilable to the Administrator or any law enforcement official	upon	request. 20) The UAm ust remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultr a - light vehicles, par achute activities, par asailing activities,	hang	gliders,	etc.).Page 17 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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21) The UAm ay not be operated by the Aircraft Oper ator from any moving	d evice	or	vehicle. 22) UA S	oper ations	may not	be	conducted during	night,	as	defined	in 14	CFR	1.1. 23) All operations must be conducted under visual meteorological conditions	(VMC).	The	UA	may	not	be	oper ated	less	than	500	feet below or less than 2,000 feet horizon tally from a cloud or when visibility	is	less	than	3	statute	miles	from	the	Operator
. 24) During operations the UAm ay not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA
- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOT AM, if as required by the	Oper ator’s COA.	The	letter	of	agreement	with	the airport management must be made ava ilable to the Administrator upon	request. 25) The UAm ay not be operated over congested or densely populated	areas	unless	the	conditions	set	for	in	#26	are	satisfied. These populated areas include but are not limited to the ye llow areas depicted on Wo rld Aeronautical Charts (W AC ), Secti onal Aeronautical Charts (Sectionals), or Te rminal Ar ea Charts (T AC ). However , aeronautical charts may not reflect pertinent local information. Ultimately , it is the Oper ator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1). 26) Flight operations must be conducted at least 500 feet from all nonparticipating persons, ve ssels, ve hicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an acc ident. The Aircraft Oper ator must ensure that nonparticipating	persons	remain	under	such	protection.	If	a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations	must	cease	immediately	and/o r; b. The aircraft is operated near ve ssels, ve hicles or structures where the land owner/controller has granted permission and/or the Aircraft Oper ator has made a safety assessment of	the	risk	of	operating	closer	to	those	objects	and;18 c. Oper ations near the Airc ra ft Oper ator do not present an undue	hazard	to	the	Oper ator	per	§	91.119(a). 27) All operations shall be conducted over private or controlled

access	property	with	permission	from	the	land	owner/controller or authorized representative. Pe rmission from land own er/controller or authorized representative will be obtained for	each	flight	to	be	conducted. 28) Any incident, accident, or flight operation that tr ansgresses the later al or ve rtical boundaries of the operational area as defined by the applicable COA must be r eported to the FAA’ s UA S Integr ation Office (AFS

- 80) within 24 hours. Accidents must be reported	to	the	National	T ra nsportation	Safety	Board	(NTSB)	per instructions	contained	on	the	NTSB	W eb	site: www

.ntsb.gov

. 

### Specific **Uses Public Benefits** Kyle Fleischmann proposes use of its sUAVp rovided equivalent or augmented levels of	safety	for	each	of	the	uses	proposed	herein: The	present	systems	of	photography	and	videography	and	mapping	of	inspecting	the roofs, agriculture la nd, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are now conducted by either humans wa ding through swamps, climbing on the roofs and structures that are steep, tall, slippery ,	weakened	or	otherwise	hazardou s	or	by	the	use	of	conventional	aircr aft. The current procedures can result in significant injuries to the people who must climb	on	the	roofs or re quire the	use	of	aircr aft	that	are	orders	of	magnitude	greater in size than the sUAV

. Either method, manual inspection or large conventional aircraft, results in incr eased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fix ed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those	undertaken	with	a	sUAV

. The present syst em exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site because the aircraft must be flown to and from the site. By contr ast, the sUAV i s carried to the site and tr ansits no other property .	Conve ntional	aircraft	carry	flammable	fuels	that	are	not	carried	by	the	UAS and emit pollutants associated with internal combustion engines. The sUAV’s proposed	herein	ar e	battery	powered	and	have	no	emissions.Page 19 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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### Eq **uivalent Level of Safety**
**14	C.F .R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and	Limitations;	Pilot	in**  **Command;** Section 61.113(a) & (b) limit private pilots to non - commercial operations. Unlike a conventional aircra ft that carries a pilot, passengers, and cargo, the Kyle Fleischmann ’s sUAV

i s re motely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to	be	pilot	in	command	of	an	ai rcraft	for	compensation	or	hire. Kyle	Fleischmann	respectfully	proposes	that	Oper ator	requirements	should	take	into account	the	char acteristics	of	the	particular	UAS.	K yle	Fleischmann ’s	sUAV

has	a	high degree of pre - programmed control and va rious built

- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. The Kyle Fleischmann ’s sUAV h as navigation and control system comprised of a Ground Control Station (GCS) an d auto - pilot system that can be pre - programmed to set operational boundaries. All flights are pre programmed with precision GPS guidance.. In the case of unplanned events, the Oper ator may input pre - programmed evasive maneuve rs from the control unit, and the onboard autopilot executes those maneuve rs. Pre
- programmed Oper ator interventions include initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency	power	cut	off	and	lan d	(Flight	T ermination	System). Additional automated safety functions and safety enhancing fe atur es of the Kyle Fleischmann ’s	sUAV’s	may	include	the	following: 1.1. Auto
- pilot detection of lost GPS or of insufficient satellites initiates an immediate	landi ng. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%	levels.	Low	power	below	10%	triggers	an	immediate	landing. 1.3. If the auto - pilot detects a lost

- link to the ground controller , the UA S will hold position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not restored,	execute	a	return	to	home	and	land. 1.4. Re dundant “kill switches” that enable completely shutt ing the aircraft down in flight in the event of a loss of control or un - commanded deviation	from	the	flight	path. 1.5.	The	aircraft,	weighs	less	than	55	lbs.,	fully	loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1. 7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude)	or	a	maximum	of	400	A GL.20

Given these safety features, Kyle Fleischmann proposes that Oper ators of Kyle Fleischma nn ’s sUAV

s hould not be required to hold a commercial or private pilot certification. Instead, Oper ators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FA A Private Pilot written examin ation or FAA
- recognized equivalents; have completed the manufacturer’s	or	K

yle	Fleischmann ’s	tr aining	progr am	for	operation	of	the	UAS. Kyle Fleischmann notes that the FAA has found that safety factors permitted operation of UAS s by Oper ators with these q ualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Fe deral Av iation Administration, Notice N
- 8900.227, Unmanned Aircraft Systems (UAS) Oper ational Approval, at 20
- 21 ( July 30, 2013). Likewise, Kyle Fleischmann notes that the NPRM does not require that the Oper ator hold a private	pilot	license	issued	by	the	F AA. Given	these	conditions	and	restrictions,	an	equivalent	level	of	safety	will	be	pr ovided by allowing operation of the Kyle Fleischmann ’s sUAV w ithout a private pilot’s certificate	or	a	commercial	pilot’s	certificate,	under	the	conditions	set	forth	herein. The risks associated with the operation of the Kyle Fleischmann ’s sUAV ( given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operation s contemplated by Part 61 with conve ntional aircraft (fix ed wing or rotorcraft), that allowing operations of the UA S as set forth above meets or exceeds the present level of safety provided under 14 C.F .R. § 61.113(a) & (b) and does not rise to the level o f requiring a commercial pilot to operate the aircraft under § 61.133(a).


### 14 C.F**.R. § 91.7(a): Civil aircraft airworthiness.** This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UA S without an airworthiness certificate, no standard will exist for airworthiness of the UA

. Given the size of the aircraft and the requirements that the Oper ator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exe mptions to conduct similar operations in	Ex emptions	11062	through	11067,	11080	and	11110.Page 21 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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### 14 C. **F. R. §91.119: Minimum safe altitudes**  Section 91.119 establishes safe altitudes for operation of civil air craft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person oper ating the helicopter complie s with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AG L,	an	ex emption	may	be	needed	to	allow	such	operations. The equivalent level of safety will be achieved given the size, weight, and speed of the UA S as well as the location where it is operated. No flight will be taken without the permission of the property owner , facility owner

, and/or local officials. Because of the	adva nce	notice	to	the	property	owner	and	participants,	all	affected	individuals will be aware of the planned flight operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AG L in the aerial photography industry

. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

- UA S operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Ex emptions 11062	through	11067,	11080	and 11110.


### 14 C.F**.R. §91.121 Altimeter Settings** This regulation requir es each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “... to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the Kyle Fleischmann ’s sUAV

, in manual or emergency mode, will not have a barometric altimeter display

, but instead a GPS altitude display , an exemption will be needed. The Oper ator

, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety

. The FAA has gr anted exemptions to conduct similar operations in Ex emptions 11062 through 11067, 11080	and	11110.


### 14 C.F**.R. § 91.151(a): Fuel Requirements f or Flight in VFR**  **Conditions**
Section 91.151(a) prohibits an individual from beginning “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 n ormal cruising speed

– (1) During the day , to fly after that for at least 30 minutes; or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.”22

The battery powering the sUAS provides approximately 40 minutes of powered flight. To m eet the 30
- minute res erve requir ement in 14 CFR §91.151, sUAS flights would	be	limited	to	approximately	10	minutes	in	length.	Gi ve n	the	limitations	on	the UA S’ proposed flight area and the location of its proposed operations within a predetermined	area,	a	longer	time	frame	for flight	is	reasonable. Pe titioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Ex emption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FA R 91.151 (a)). Oper ating the sma ll UA S, in a tightly controlled area where only people and property owners or official representatives who have signed wa ive rs will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) wa s intend ed	to	alleviate	given	the	size	and	speed	of	the	small	UAS. Pe titioner believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Ex emptions 2689F , 5745, 10673, 10808 and	Ex emptions	11062,	through11067,	11080	and 11110.


### 14 C.F**.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections**  These	regulations	require	that	an	aircr aft	Operator	or	owner	“shall	have	that	aircr aft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in par agr aph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...,” and others shall inspect or maintain	the	aircr aft	in	compliance	with	Part	43. Given that these sec tions and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Pe titioner
. Maintenance will be accomplished by the Oper ator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits An equivalent level of safety will be achieved because these small UA Ss are ve ry limited in size and will carry a small payload and operate only in defined areas for limited	periods	of	time.	If	mechanical	i ssues	arise,	the	UAS	can	land	immediately	and will	be	oper ating	from	no	higher	than	400	feet	A GL.	As	provided	in	the	Aircraft	Flight Oper ations Manual the Oper ator will ensure that the UA S is in working order prior to initiating flight, perform required ma intenance, and ke ep a log of any maintenance performed. Moreover , the Oper ator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety

. The FAA has gr anted exemptions for	similar	operations	in	Ex emptions	11062	through	11067,	11080	and	11110.Page 23 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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## Fe **der al R**  **egister Publication**
Pursuant to 14 C.F

.R. Pa rt 11, the following summary is provided for publication in the	F ederal	Register

,	should	it	be	det ermined	that	publication	is	needed: Pe titioner	seeks	an	exemption	from	the	following	rules: 14	C.F .R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commer cially a small unman ned ve hicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematogr aphy, a nd videography, p recision agriculture with on board sensors, wildlif e and forestry monitoring and mosqu ito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officia ls, aerial video and photography for public and private use	including	television,	public	events,	and	cinematogr aphy live feed and live newsgathering, tr aining to persons individually or belonging to both private and public organizations to increase awarene ss and improve safety for current and future UA S operations within the NAS , special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface minin g, closed set filming, disaster	and	catastrophe	events. 

## Priv **acy and National Security** All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’s	prior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in area s	where	the	owners	will	have	consented	to	the	inspections	or	otherwise	have agreed	to	allow	the	UAS	and	the	Oper ator	to	be	in	the	area	where	operations	will take	place. The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	r aise	nationa l security	issues.24



## Summary Approval of exemptions allowing commercial operations of sUAV’s fo r petitioner to operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematogr aphy, a nd video graphy , precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assi st with search and rescue operations under the authority and support of local authority officials,	aerial	video	and	photogr aphy for public	and	priva te use	including television, public events, and cinematogr aphy live feed and live new sgathering, tr aining to persons individually or belonging to both private a nd public organizations to increase awareness and impr ove safety for current and future UA S operations within the NAS , special events: including high schools. colleges, professional sports, open air event s and fa irs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and	catastrophe	events,	will	enhance	safety	by	reducing	risk. Conventional operations, using jet or piston powered aircraft, ladders or placing people	in	swamps,	on	r oofs or tall,	hazardous or weakened	structures,	exposes	them to higher risks than those created by use of a sUAV’S. Conventional aircraft that operate a t extremely low altitudes just feet from the subject being inspected and in extreme pr oximity to people and structures present the risks associated with ve hicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such air craft must fly to and from the project location. In contr ast, a sUAV w eighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the re duced mass and lack of combustible fuel	carried	on	bo ard.	The	sUAV is	carried	to	the	target	area	and	not	flown.	The	sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated	with	manned	aircraft	flights. The operation of small UA Ss, weighing less than 55 lbs., conduc ted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested her ein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the cont rol of the customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people	or	the	use	of	individuals	to	climb	the	structures	to	conduct	the	op erations. Satisfaction of the criteria provided in Section 333 of the Re form Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– pr ovide mor e thanPage 25 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
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- 9551 adequate justification for the grant of the requested exemptions allowing commercial oper ation of Pe titioner’s UAS f or the Purposes outlined herein and are consistent with exemptions already granted, including Ex emptions number 11171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely, Kyle	Fleischmann 3694	East	Brentor	Court Meridian,	ID	83642
and Stephen	Gowdy Chief	Pilot, Gowdy	Brothers	Aerospace,	LLC Consulting	Agent	for	K

yle	Fleischmann26



### APPENDIX A **- EXEMPTION P**  **AT TERN** 
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business inf ormation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Section	333	(b). Submitted	under	separ ate	cover .Page 27 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
- 496
- 9551 

### APPENDIX B **- TE** **CHNICAL MANU ALS AN** **D SPECIFICA TIONS** 
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form Act Secti on 333	(b). Submitted	under	separ ate	cover .28



### APPENDIX C **- COMMERCIAL (MISSION/OPERA**  **TION) PURPOSE -**  **FA A**  **PREVIOUS APPROVED EXEMPTION NUMBERS**
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential bu siness inf ormation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Section	333	(b). Submitted under separate cover .Page 29 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
- 496
- 9551 

### APPENDIX D **- EQUIPMENT**  **- FA** **A PREVIOUS APPROVED EXEMPTION NUM** **BERS**
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business inf ormation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act Section	333	(b). Submitted	under	separ ate	cover .30



### APPENDIX E **- EXEMPTION 14 C.F**  **.R -**  **FA A PREVIOUS APPROVED**  **EXEMPTION NUMBERS**
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business inf o rmation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Section	333	(b). Submitted under separate cover .Page 31 Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www .GowdyBrothersAerospace.com 763
- 496
- 9551 

### APPENDIX F **- MONTHL**  **Y MAINTENANCE AND REP**  **AIR L OG** 

Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business inf ormation that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Secti on	333	(b). Submitted	under	separ ate	cover .32



### APPENDIX G **– MO**  **TION PICTURE AND TELEVISION FLIGHT OPERA TIONS**  **MANU AL VERSION 1.0** 
Pe titioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business inf orma tion that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Re form	Act	Section	333	(b). Submitted	under	separ ate	cover .