U.S. Department of Transportation Docket Operations West Building Ground Floor
Room W12

- 140 1200 New Jersey Avenue, S.E. Washington, DC 20590

Re: Petition of Chronicle UAS for Exemption

Pursuant to 14 C.F.R. Part 11, Chronicle UAS. (“Chronicle UAS” or “Petitioner”) hereby applies for an exemption in order to conduct commercial use operations with the unmanned aerial systems XBOW and Raptor Multirotors and the Atlas Helicopter (“UAS”). I n accordance with the requirements of the Federal Aviation Administration (“FAA”), Petitioner’s UAS operations have been designed to achieve a level of safety equivalent to that provided by the FAA regulations from which an exemption is requested. In supp ort of its exemption request, Chronicle UAS provides the following information.

Petitioner

Chronicle UAS is established by a Retired(CWO2) Chief Warrant Officer who was an exemplary Black Hawk UH 60 Pilot with over 1350 manned flight hours in Iraq and Af ghanistan. He has 6 Air medals, 3 ARCOMS, 3 AAM's , Global War on Terrorisim medals and Expeditionary Medals. Not only is the Petitioner an established Military Combat Pilot, he also is a established UAV Pilot with experience with the Scaneagle, Aerosond e, and Tigershark UAS systems with over 4800 hours of logged flight hours in a Combat Theater with UAS systems. The Petitioner is a established Pilot both in the Manned flight and Unmanned flight industries and not Just a RC Hobbyist claiming to have an ex ceptional amount of flight hours that they only accrued from flying at low altitudes at a RC Hobby field. Chronicle UAS is now looking to put the experience and professionalisim that they have used in Iraq and Afghanistan to use
here in our NAS. Chronicle UAS will provide a service to the Commercial Industry that is at the Top of the unmanned aviation field in experience and professionalisim. Chronicle UAS is now proposing to use its aircraft for the commercial use of various aerial inspections , surveys, s ecurity, and disaster ISR operations.

Proposed Commercial Uses

Chronicle UAS proposes to use the DJI INSPIRE 1, XBOW , Raptor Multirotors

, and the Atlas Helicopter small UAS aircraft for multiple commercial applications, including safety inspections,

se curity, disaster ISR operations and aerial surveying of the following remote or difficult

- to

- access facilities:

• Oil and Gas platforms

• Flare booms/stacks

- both onshore and offshore

• Refineries and processing stations

• Pipelines & Right of Ways

• Power lines & R ight of Ways• Bridges and infrastructure including rail bridges

• Wind turbines

• Solar farms

• Search and Rescue

• Wildfire ISR operations

• Tower Inspections

Chronicle UAS also envisions UAS operations in support of emergency response activities on behalf of
the National Transportation Safety Board, the Department of the Interior’s Bureau of Safety and Environmental Enforcement, the U.S. Coast Guard, and any other federal or state government agency which may require its services and personnel.

All of Chronicle UA S's proposed UAS operations are intended to facilitate safety inspections and aerial surveying in areas where the performance of those functions using todays current methods involves a substantial risk of injury. Many of these Operations must be performed in hazardous environments which may be performed much more efficiently by an unmanned aircraft with the ability to hover and capture images at close range. The commercial UAS applications that Chronicle UAS proposes will result in a significant enhanceme nt of safety, by reducing the risks associated with current inspection methods, and enhancing current inspection techniques.

Proposed UAS Aircraft

Chronicle UAS plans to conduct commercial UA S operations with the DJI Inspire 1, XBOW, Raptor Multirotors

, a nd the Atlas Helicopter . The Inspire 1 and XBOW are a small UAS with a maximum takeoff weight of 18lbs. The Raptor is a small UAS with a takeoff weight of 25lbs and the Atlas helicopter UAS has a takeoff weight of 21lbs At all times while conducting commercial operations, Chronicle UAS will operate ALL AIRCRAFT under line

- of

- sight conditions. The Chronicle UAS Operator will maintain control with a control system, i.e., IPAD, LAPTOP, or pilot control box , in response to commands from a Chronicle UAS em ployee with specialized flight training; aircraft will perform commercial operations autonomously or manually in accordance with a pre

- programmed/determined flight plan. The DJI Inspire 1, XBOW
, and Raptor have four battery powered motors. In the event t hat the Uplink between the control system and the Inspire 1, XBOW or the Raptor is lost or disrupted, the aircraft are designed to hover for approximately 5 seconds attempting to regain the Uplink. If the UAS
has GPS communications and is unable to re

- est ablish communications with the control station, all aircraft rely on an auto

- pilot feature that returns the UAS aircraft to the home point via the original flight path from the launch point. This will help eliminate “fly

- away” incidents.

Operating Conditio ns

Chronicle UAS will conduct commercial operations with the DJI Inspire 1, XBOW, Raptor Multirotors and the Atlas Helicopter only in accordance with a highly

- detailed set of safeguards governing all phases of flight operations. Chronicle UAS will always place a priority upon minimizing risk to personnel, equipment, and the environment. To ensure the highest level of safety, UAS flight operations will only be conducted after an extensive Pre flight briefing (including Chronicle UAS andclient personnel) a complete systems and communications check and a Risk analysis have been
conducted.

All UAS flights will be conducted by a minimum of three qualified personnel, including a qualified Mission Commander. No flights may be initiated unless a preflight chec klist has been completed and signed by mission essential personel. The checklist procedure will include a detailed inspection of the DJI Inspire 1, XBOW, Raptor, or Atlas and essential communications systems prior to the initiation of any operations. Mos t importantly from a safety perspective, operations directly overhead are not permitted.

There are several additional mandates that Chronicle UAS employees must observe in connection with all commercial operations with Inspire 1, XBOW, Raptor, and Atlas U AS systems including the following:

• No flights through an established Air Defense Identification Zone (ADIZ)

• UAS flights shall not exceed 500 feet above ground or above the sea level per FAA Advisory Circular 91

- 57

• All flights will be conducted in Class G airspace

• All flights will be conducted within line

- of

- sight of UAS operator

• All flights will be conducted in accordance with Class G airspace visibility requirements

• Wind speed shall not exceed 25 knots

• UAS operations will be conducted only during daylight hours

• A Notice to Airmen (NOTAM) will be filed with the FAA prior to each UAS operation

• All Chronicle UAS crews will have an air

- air radio system for communication with low flying air traffic in the area surrounding UAS operations (programmed with 123.025
common Air

- Air Frequency, and the local frequency for the area of operation)

• All Chronicle UAS crews will have an up to date Helicopter Safety Advisory Conference Air Frequency card.

At no point in time will Chronicle UAS aircraft be allowed to share airspace with commercial aircraft. If conducting operations within three miles from any manned airport runway, Chronicle UAS will notify the airport operator or the airport tower, as the case may be, in compliance with FAA Advisory Circular 91

- 57. Chronic le UAS will terminate any UAS operations when an approaching commercial aircraft is within
five nautical miles.

Operator RequirementsChronicle UAS's commercial UAS operations will build on its years of experience as an exemplary operator of UAS's in a Combat Theater of Operations. All Chronicle UAS employees will have undergone and successfully completed a rigorous competency assessme nt evaluation before being able to operate the XBOW, Raptor, and Atlas UAS systems. Operators must demonstrate not only a superior knowledge of the technical issues associated with UAS systems, including the full range of the capabilities and
limitations of the Inspire 1, XBOW, Raptor, and Atlas, but also must show sound piloting techniques and the ability to navigate around structures. Chronicle UAS will enforce the company’s policy of “working under the more stringent rule.”

Chronicle UAS operators will undergo an extensive program of simulator training as well as hands on flight training in a simulated inspection environment. Simulator training will allow these employees to gain experience with the specific flight characteristics of the Inspire 1, XBOW , Raptor, and Atlas prior to any actual commercial operations.

The following requirements will apply to any commercial UAS operations conducted by Chronicle UAS:

• A pilot

- in

- command (PIC) will be designated at all times for each flight

• The PIC will be dir ectly responsible for, and have final authority over the operation of
the UAS

• The PIC will not perform concurrent duties as the visual observer

• The PIC will be qualified on the aircraft he is flying/operating

• The PIC will exercise control over the UAS both manually and autonomously in the case of an (EP) emergency procedure or situation governing a manual operation.

Given their hours and experience with piloting UAS systems in a Combat Theater in Afghanistan and Iraq, the amount of required simulator trai ning, and the operational procedures applicable to Chronicle UAS employees operating the Inspire 1, XBOW, Raptor, and Atlas for commercial purposes, Chronicle UAS PICs should not be required to hold an FAA pilot certificate. The commercial UAS operations by Chronicle UAS will immitate the conditions under which the FAA will issue a Certificate of Waiver or Authorization to UAS operators without requiring pilot certification. All operations will be in Class G airspace, conducted during daylight hours unde r visual line

- of

- sight flight procedures no more
than one

- half nautical mile laterally from the PIC. All Chronicle UAS PICs also will hold, at a minimum, a
valid FAA second

- class medical certificate. In accordance with the qualifications established by t he FAA for the pilots of UAS aircraft operating pursuant to a COA. PICs should therefore be deemed qualified once they have successfully completed an FAA private pilot ground instruction course and passed the
FAA Private Pilot examination or an FAA

- recogni zed equivalent.The manager for Chronicle UAS's commercial UAS operations is Julio Jo, a UAS industry expert. Julio Jo has over 1350 hours of Piloting a UH

- 60 Blackhawk in the United States Army in a Combat environment, and over 4800 hours of logged fl ight hours in Afghanistan and Iraq Combat Theaters on 3 different ELOS UAS Systems. This knowledge and experience has been incorporated into the training, flight procedures, maintenance, and recordkeeping developed for Chronicle UAS's commercial UAS
operat ions.

Exemption Request

Chronicle UAS is requesting an exemption from FAA regulations in order to conduct commercial UAS operations with the Inspire 1, XBOW, Raptor, and Atlas aircraft. Attached as Exhibit A is a list of each FAA regulation from which Chronicle UAS is requesting an exemption and the justification for each such exemption. In accordance with FAA requirements, in the case of each requested exemption, Chronicle UAS is suggesting alternate methods of compliance that will provide a level of safety equivalent to that provided by the regulation from which an exemption is sought.

Chronicle UAS's request is consistent with the FAA’s policies for the granting of exemptions. It also is in accordance with the direction provided by Congress in Se ction 333 of the FAA Modernization and Reform Act of 2012 (“FAA Modernization Act”), instructing the Secretary of Transportation to determine which UAS aircraft operating “within visual line of sight” may be integrated into the National Airspace System (“N AS”) before the development of regulations governing the commercial use of other types of UAS aircraft. Because of the relatively small size, light weight, speed and operational capabilities of the XBOW, Raptor, and Atlas, as well as the strict visual lin e of sight protocols under which these UAS will be operated. The Inspire 1, XBOW, Raptor and Atlas aircraft may be safely operated without creating a hazard to other users of the NAS or a threat to national security. The Inspire 1, XBOW, Raptor, and Atlas operated as proposed herein, is therefore the type of UAS that ought to be the subject of operational approval by the Department of Transportation prior to the issuance of regulations governing the operation of small unmanned aircraft systems generally.

The UAS operations to be conducted by Chronicle UAS pursuant to the requested exemption offer significant safety enhancements over current methods of providing the same commercial services. Chronicle UAS's aircraft have the ability to fly into difficult

- to

- access areas that present considerable hazards to other methods of inspection, including those involving close

- up inspections by human beings by means of Rope Access. In evaluating Chronicle UAS's request for an exemption, the FAA should consider not j ust the ability of Chronicle UAS to achieve a level of safety equal to or greater than that afforded by the regulations from which an exemption is sought, but also the safety benefits to be achieved from using UAS aircraft for services now performed by oth er means at considerable greaterrisk to human life. As demonstrated below, the FAA can allow these benefits to be realized without compromising its obligation to promote the highest level of aviation safety.

Respectfully submitted,

Julio Jo, CEO

Chronicle UAS

www.chronicleuas.com

469

- 396

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EXHIBIT A

Chronicle UAS's.

– EXEMPTION REQUEST

Chronicle UAS requests an exemption from the following regulations of the Federal Aviation
Administration:

Chronicle UAS is willing to include any markings that may be required by the FAA in connection with its commercial UAS operations, with the understanding that the surface area of the XBOW, Raptor , and Atlas will not permit lettering that is larger than one inch in height

1. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. § 91.203: Civil Aircraft: Certifications Requ iredUnder 14 C.F.R. § 91.203, all U.S.

- registered aircraft are required to have a certificate of airworthiness issued by the FAA. Part 21, Subpart H of the FAA’s regulations establishes the procedural requirements for the issuance of airworthiness cert ificates by the FAA.

Equivalent level of safety analysis : The strict operational limitations under which Chronicle UAS will conduct flights for commercial UAS applications (e.g., daylight operations, use of Class G airspace, all flights within line

- of

- s ight of the operator) are at least as restrictive as the limitations that apply to the operation of limited or restricted category, experimental or provisionally

- certificated aircraft. The Inspire 1, XBOW, Raptor, and Atlas do not carry a pilot or any oth er passengers and their small size reduce the danger that any collisions with the ground or structures will involve anything more than the loss of the UAS aircraft. Autonomous programming, that upon loss of the uplink with its ground control station, wil l guarantee the aircraft will return to its preprogrammed "Home" waypoint and eliminates the potential for “fly away” incidents. Chronicle UAS will follow the rules also outlined in the NPRM
107.13 for the restricti ons on guarantying the airworthi ness of t he aircraft before operations.

2. 14 C.F.R. § 61.133(a): Commercial Pilot Privileges and Limitations

FAA regulations generally require that an aircraft may engage in operations for compensation or hire only if it is flown by a person holding a commercial pilot certificate. 14 C.F.R. § 61.133(a). Chronicle
UAS submits that hands

- on experience with the flight characteristics of the XBOW, Raptor, and Atlas aircraft generally are a far more effective guarantee of flight safety than a commercial pi lot certificate would be in connection with Chronicle UAS's proposed commercial UAS program.

Equivalent level of safety analysis . A joy stick / tablet / Ipad operated UAS, such as the XBOW, Raptor, and Atlas have flight characteristics substantially dif ferent from a manned aircraft. The propulsion system and control surfaces on the Inspire 1, XBOW, Raptor, and Atlas respond to inputs that are transmitted remotely from either a joy stick / laptop / or Ipad located on the control station. A commercially licensed pilot would need to “unlearn” the principles of flying a manned aircraft in order to successfully operate the XBOW, Raptor, and Atlas . Whereas, an operator who had done all of his or her “flying” on the Inspire 1, XBOW, Raptor, and Atlas , with no previous flight experience with manned aircraft, would know no other type of aviation but would be intimately familiar with the maneuvering of
the Inspire 1, XBOW, Raptor, and Atlas UAS.

Chronicle UAS therefore emphasizes UAS training (both simulator and actual) and flight experience for those employees who will operate the Inspire 1, XBOW, Raptor, and Atlas for commercial services. A Chronicle UAS operator will not be able to fill the role of an operator of Inspire 1, XBOW, Raptor, or Atlas commercia l services until successfully completing a minimum of 15 hours of UAS training flights (45 twenty

- minute flights). Currency flights will also be required of operators who have exceeded a 90 day window with no logged flight hours, for a minimum of 1 hour a s either actual flight, or as a recorded and logged simulator flight.The above

- listed hours will be recorded in ASA

- SP

- 30 pilot logbooks subject to inspection by FAA personnel at any time.

By requiring extensive flight experience with the Inspire 1, XBOW, Raptor, and Atlas prior to conducting commercial operations, Chronicle UAS operators will have a better grasp of the handling of that aircraft and the EP's (emergency procedures) in the event of an emergency than they would by holding a commercial pilot c ertificate for an entirely different type of aircraft.

Chronicle UAS will conduct extensive simulator training and flight training for each of its Inspire 1, XBOW, Raptor, and Atlas operators. Simulator training is in addition to the hands

- on training

e xperience required of each Chronicle UAS operator prior to conducting commercial operations with the Inspire 1, XBOW, Raptor, and Atlas aircraft. The amount of training

– under simulator conditions and
hands

- on flight experience

– that Chronicle UAS oper ators must successfully complete before conducting commercial UAS services provides a level of experience specific to UAS flight operations that cannot be duplicated merely by holding a commercial pilot certificate. The Chronicle UAS operators of
the Insp ire 1, XBOW, Raptor, and Atlas will be better qualified to conduct UAS flights than a commercially

- licensed pilot, who has never operated a UAS aircraft, and is unfamiliar with its flight
characteristics.

In addition to UAS operational experience and si mulator flight training, Chronicle UAS operators will also be required that before becoming a UAS operator he / She must complete an FAA

- approved private pilot ground instruction course and have successfully passed the FAA Private Pilot written
examination or an FAA

- recognized equivalent. Operators of Chronicle UAS aircraft will therefore receive instruction in aeronautical navigation, meteorology and aviation regulations prior to conducting commercial UAS operations.

3. 14 C.F.R. § 91.7(a): Civil Aircra ft Airworthiness.

Chronicle UAS will follow the guidelines outlined in the NPRM 107.13 and NPRM 107.15 for the matters of Airworthiness unless otherwise guided by the FAA.

4. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking and Placard Req uirements.

This regulation requires that an approved flight manual, manual material, markings, placards or some combination thereof be placed onboard the aircraft. Neither Inspire 1, XBOW, Raptor, or Atlas have a configuration suitable for compliance w ith this requirement.Equivalent level of safety analysis . The Inspire 1, XBOW, Raptor, and Atlas are linked to a computer that serves as the ground control station. The instruction manual for the Inspire 1, XBOW, Raptor, and Atlas
will be on hand so a s to be referenced by the operator if needed, in much the same way that pilots of commercial airliners are able to access flight manuals on tablet devices. All manual material, markings and placards relevant to the operation of the Inspire 1, XBOW, Raptor , and Atlas can be displayed on the screen of the computer that serves as the ground control station, as required. The instruction manuals
for the Inspire 1, XBOW, Raptor, and Atlas will therefore be just as accessible as a flight manual carried
onboard a commercial aircraft.

5. 14 C.F.R. § 91.109(a) and 14 C.F.R. § 91.109(c): Flight Instruction: Simulated Instrument Flight and Certain Flight Tests.

Under this regulation, aircraft used for training purposes must have dual flight controls, subject

to ce rtain exceptions. FAA regulations also require that whenever training is provided in a simulator, the simulator must have a second control seat occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings a ppropriate to the aircraft being flown. Neither Chronicle UAS's aircraft nor the simulator used by Chronicle UAS for flight training purposes complies with these FAA requirements.

Equivalent level of safety analysis . Chronicle UAS has developed an extensive flight instruction training program for its Operators who will conduct commercial UAS operations. Flight instruction is provided through Chronicle UAS and consists of ground instruction and flight training. Further training will be
conducted wi th a computer flight simulator with a review of operator skills on a monthly basis. Pilots will be required to perform frequent training flights and currency flights, at either an FAA

- approved field or on Chronicle UAS property with suitable objects for p ilots to navigate to and around in a simulated commercial inspection environment.

All training operations of the Inspire 1, XBOW, Raptor, and Atlas will be observed by a UAS operator Supervisor, and will be able to observe all operator training by standing or sitting next to the computer that is used as the control station. Similarly, as flight simulations of the Inspire 1, XB OW, Raptor, and Atlas also are displayed on a computer screen, a Chronicle UAS operator with a high level of UAS flight experience is able to sit next to the operator and directly observe all phases of simulator training. In this manner, Chronicle UAS wil l be able to satisfy the FAA’s interest in having simulator training observed by a highly

- experienced operator.

The requirement for dual flight controls on an aircraft used for training purposes will be followed during actual flight training at a FAA appr oved Field or Chronicle UAS property.

6. 14 C.F.R. 91.119: Minimum Safe Altitudes: General

This regulation specifies the minimum altitude in various flight environments below which aircraft are not allowed to operate. Chronicle UAS will conduct the co mmercial services it proposes
below the FAA

- specified maximum of 500 feet AGL and not any closer to vessels and structures than the minimum separation of 500 feet mandated by the FAA.Equivalent level of safety analysis . The operation of the Inspire 1, XBOW, Raptor, and Atlas exclusively in Class G airspace (i.e., below 500 feet) is intended as a safety measure to provide a level of separation between commercial UAS operations and the operation of manned aircraft at altitudes above 500 feet
AGL. Therefo re, limiting the Inspire 1, XBOW, Raptor, and Atlas to flights below the 500 foot AGL maximum will enhance safety rather than compromise it. Chronicle UAS will need to operate the Inspire 1, XBOW, Raptor, and Atlas closer than 500 feet to structures in or der to conduct the inspections that will comprise the majority of Chronicle UAS's commercial UAS services. However, Chronicle UAS has flight procedures that include the company’s own requirements regarding the minimum level of separation between the Inspi re 1, XBOW, Raptor, and Atlas and any nearby structures or facilities. In addition, the risk of damage to any nearby structures or facilities is reduced by the Inspire 1, XBOW, Raptor, and Atlas's small dimensions and the use of lightweight materials in t heir construction.

7. 14 C.F.R. § 91.121: Altimeter Settings

Pursuant to this regulation, an aircraft that is operating below 18,000 feet above Mean Sea Level must contain an altimeter that is set to one of several designated altimeter settings prior to departure.
Neither the Inspire 1, XBOW, Raptor, or Atlas includes an altimeter.

Equivalent level of safety analysis : The operation of the Inspire 1, XBOW, Raptor, and Atlas aircraft exclusively in Class G airspace (i.e., below 500 feet) away from commerc ial traffic and ATC

- controlled airspace reduces the need for an altimeter onboard the Inspire 1, XBOW, Raptor, and Atlas aircraft. The
altitude of the Inspire 1, XBOW, Raptor, and Atlas aircraft above Mean Sea Level and its GPS coordinates will be display ed on the screen of the remote ground control station used by the Chronicle UAS operator to perform any commercial services. The operator will have continuous situational awareness of the UAS altitude and position, as flight operations will be conducted u nder line

- of

- sight flight procedures.

8. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions.

FAA regulations require that a rotorcraft operating under VFR conditions have sufficient fuel to fly to the first point of intended landing a nd, assuming normal cruising speed, to fly for at least an
additional 20 minutes.

Equivalent level of safety analysis . Chronicle UAS will follow the guidelines set forth in the NPRM 107. 49(a)(4) requiring a small UAS to have a minimum of 5 minutes of r eserve left after completion of the
mission.

9. 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Aircraft Maintenance and Inspections; Maintenance Records.

FAA regulations impose various requirements regarding the maintenance of civil aircraft,
includi ng periodic inspections, approval for return to service by a qualified mechanic following maintenance or repair, an airworthiness inspection and certain rules concerning maintenance recordkeeping. Chronicle UAS's maintenance of its Inspire 1, XBOW, Rapto r, and Atlas aircraft will not satisfy these requirements.

Equivalent level of safety analysis . Chronicle UAS will maintain the Inspire 1, XBOW, Raptor, and Atlas in accordance with the manuals and operating handbook provided by the manufacturer. Because of the Inspire 1, XBOW, Raptor, and Atlas's small size and lightweight construction, Chronicle UAS will be ableto subject it to an extensive examination after every flight. All pre and post

- flight maintenance, equipment failures, charge cycle logs, faul t/repair logs, inspections and general maintenance records will be kept on file for a minimum of five years. Chronicle UAS has developed a lengthy pre/post

- flight checklist; any aircraft which is unable to meet all the requirements for safe operation will be removed from service immediately and will not return to service until any defects have been repaired. Moreover, if mechanical issues arise, the Inspire 1, XBOW, Raptor, and Atlas can land immediately as they will be operating at an altitude no higher than 500 feet.

The manufacturers periodically update parts and firmware and software for these UAS aircraft. Each time a UAS is tested in the office, checks for the most recent stable software issued by the manufacturer will be performed. If any parts have been updated by the manufacturer, Chronicle UAS will immediately place them on order to ensure its UAS aircraft have the most updated equipment and
software.

The number of hours that a UAS is in operation will be logged by Chronicle UAS to ensure proper
life of com ponents as well as the flight packs that provide power. Once a Chronicle UAS aircraft has been removed from service its unique ID and serial number will not be re

- issued.