April 25 , 2015

U.S. Department of Transportation Docket Management System
1200 New Jersey Ave, SE Washington, DC 20590

Regarding Exemption Request of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Attachme nts: A) E384 Maintenance Manual

B) E384 Operations Manual C) E384 Training Syllabus

Dear Sir or Madam:

Ryan Nolin, an unmanned aircraft systems ( UAS ) consultant, and UAS operator, is requesting an exemption from the Federal Aviation Regulations listed below pursuant to
section 333 of the FAA Modernization and Reform Act of 2012.

The granted exemptions would allow Ryan N olin to safely and properly operate small Unmanned Aircraft Systems (sUAS) for the commercial purpose of precision imaging for agricultural, forestry, wildlife management and survey industries. By following the procedures outlined in this document and att ached appendices or established by the

FAA

, Ryan Nolin believes an equivalent level of safety can be achieved to current Federal Aviation Regulations (FARs).

Because the sUAS Ryan Nolin plans to operate (Event 38 E384) weighs less than 10lbs, is
made of fo am, and is electric powered, operations produce less noise, less air pollution and congestion in the National Airspace (NAS). These reasons are all in the well being of the general public.

Being a sUAS also has the added benefit of reducing risks to personnel and property in the air and on the ground. Because flight operations will require consent from landowners, operate below 500 feet and operate in a similar fashion to current manned
aircraft no new privacy issues will arise.

The requested exemption is in the public interest of our nation. By granting this exemption Ryan Nolin, the public and surrounding communities will all benefit from added economic, environmental and positive sUAS outlook impacts

.

Ryan Nolin
439 Lancelot Lane Lexington, KY 40517
Phone: 802

- 318

- 3456
Email: ryan@skyviewcustoms.comThe Specific sections of 14 CFR from which Ryan Nolin seeks exemption:

14 C.F.R Part 21 Subpart H 14 C.F.R 61.113 (a)&(b) 14 C.F.R 91.7 (a)

14 C.F.R 91.151 14 C.F.R 91.405 (a) 14 C.F.R. 91.407 (a)(1) 14 C.F.R. 91.409 (a)(1) & (a)(2) 14 C.F.R 91.417 (a) (b)

Appendix A discusses why each C.F.R is appropriate for exemption, how an equivalent
le vel of safety is achieved and how it is in the public’s interest.

Characteristics of the Aircraft:
Ryan Nolin will operate the E384 fixed wing sUAS, which is manufactured by Event38 of Akron, Ohio. The principle construction material for the E384 airframe is EPO foam,
carbon fiber tail boom with an all up weight ( AUW ) no greater than 10lbs. The E384 is powered by a single lithium polymer battery that drives a single brushless motor. The E384 has a maximum flight time of 100 minutes with operating s peed of 27 mph. The pilot in command (PIC) will communicate with the E384 with a 2.4 ghz remote control radio and a 915mhz data telemetry radio connected to a gro und control (GC) computer.

The E384 aircraft has several failsafe systems in place:

 In the event of the loss of remote control (unlikely due to visual line of sight ( VLOS ) operations under 400ft) the E384 will perform a “return to home”

command.

 In the event of the loss of ground control connection (unlikely due to VLOS operations under 4 00ft) the E384 will perform “return to home” command.

 In the event of a low battery (less than 20%) the E384 will perform a “return to
home” command

.

In addition to the above failsafes, a gps guided “Geofence” will prevent the E384 from flying beyond its intended flight path.

Ryan Nolin holds an Airframe and Powerplant certificate (#3474636) and will thus perform all E384 maintenance. Maintenance procedures will be followed in accordance
with Event38 maintenance manuals (attachment A) . All maintenance procedures will be logged.

Similar aircraft is already approved for operation. See exemption #11166Proposed procedural and operational standards

Pilot In Command (PIC) and Visual Observer

 As PIC, Ryan Nolin will have at minimum a Sport Pilot ’ s license

.

 A visual observer (VO) will maintain contact with the PIC and be used to ensure the E384 remains in VLOS and will fully understand all operating limitations set forth in this petition.

 Flights will be conducted during day

- light hours and under Visual Flight Rules (VFR).

 Flights will be condu cted within VLOS of the PIC and VO

.

 As PIC

, Ryan Nolin will complete Event 38 training for the E384 aircraft in accordance with the Event38 training syllabus (attachment C).

 As PIC

, Ryan Nolin will be responsible f or all aircraft and preflight inspections.

Flight Operational Limits

 All required permissions/permits from governmental agencies will be obtained prior to each flight

.

 Permission from relevant property owners will be obtained prior to each operation.

 Preflight Safety briefings will be conducted before each flight to discuss potential safety hazards and operational boundaries

.

 Flight plans will not extend past the 100

- minute flight limit of the E384 aircraft.

 All flights will be conducted no more than 4 00 f ee t above ground level ( AGL ) and 5 miles from any airport.

 All flight operations will be conducted at least 500 f ee t from all nonparticipating persons, vessels, vehicles, and structures.

 Operations over congested areas will be avoided.

 The E384 will ta ke off and land next to the PIC and VO

.

 Alternate emergency landing zones will be established during the preflight safety briefing.

 The E384 will always give way to manned aircraft

.

 A ground control station will always be present in the are a of the PIC and VO to relay real

- time E384 information, s uch as battery level, altitudes, speeds,
location and glob al positioning system (GPS) health.

 Certificates of Approval (COA) will be secured before each flight as required by FAA regulations.

 The PI C will abort flights in the event of obstacles or emergencies.

 The E384 aircraft will be registered in accordance with 14CFR Part 47 and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as prac tical.

 All documents used by the operator to ensure safe operation and flight of the

E384 will be available to the PIC at the ground control s tation of the s UAS anytime the aircraft is operating.

Safety in the National Airspace and on the ground is the priority for operations. By following the above guidelines, in addition to Event 38 Operations Manual (attachment

B ), Ryan Nolin is confident an equal or greater level of safety to current manned aviation
is achieved.

See s imilar operations that have be en granted exemptions: #11062, #11109, #11166, #11213, #11379,

#11285Appendix A

Specific Sections of 14 CFR from which Ryan Nolin Seeks Exemption

Below are the sections from which Ryan Nolin seeks exemption, with specifics on the extent of relief sought, reason for relief, and why exemption would not adversely affect safety.

Part 21 Subpart H

– Airworthiness Certification

Part 21 Subpart H estab lishes the requirements for the issuance of an airworthiness certificate. Ryan Nolin seeks complete exemption from Part 21 Subpart H pursuant with Section 333, which authorizes the FAA to exempt a UAS from the requirements of an

airworthiness certificate b ased on consideration of the foll owing: size, weight, speed, operational capability, proximity to airports and populated areas , and operation within

VLOS.

An equal level of safety will be achieved with the operational limitations established in

t his document (refer to page 3 of the Event38 Operational limitations (attachment B) ) for all E384 flights conducted by Ryan Nolin. The E384 sUAS operates with an all up weight ( AUW ) of less than 10lbs and maximum airspeed of 30mph. All flights will occur

w ithin VLO S of the PIC and VO , at an altitude of 400 ft. AGL or less, and only ov er designated areas. Based on the required standards and limitations the E384 can safely operate without creating a hazard to any other aircraft, people, or structures on the

g round.

Similar aircraft is already approved for operation. See Exemption #11166

61.113 (a)

– Private Pilot Privileges and Limitations; Pilot In Command: Commercial Pilot Privileges and Limitations

Sections 61.113 (a) & (b) limit private pilots to non

- c ommercial operations. Due to its size, weight, and operational limitations the E384 sUAS will not c arry any persons on board. T he proposed operations will not adversely affect saf ety by requiring

the PIC of aircraft to have a commercial pilot certificate, as long as they

have passed, at minimum, a sport pilots certification. The safe operation of a sUAS benefits more from hands on experience and training in comparison to a commercial pilot ’ s license. Ryan Nolin respectfully states that, since there are no standards for either private or commercial UAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the UAS acquired from actual operation of

the aircraft willbe the most important factors in establishing an equi valent level of safety. By following

the Event38 training syllabus (attachment C) with the E384 sUAS the proper knowledge of airmanship can be achieved to maintain safe flight operations.

91. 121

– Altimeter Settings 91.121 requires aircraft to ma intain a cruising level or flight level in reference to a current reported altimeter setting. The altitude information on E384 is provided to the PIC via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a

radio communication tel emetry data link, which downlinks from the E384 sUAS to the GCS for active monitoring of the flight path. Also since the E384 will be operating at or below 400 ft. AGL, there is no need to maintain hemispherical cruising altitudes for de

- confliction with manned aircraft. For these reasons Ryan Nolin seeks exemption from this regulation. During arming sequence the E384 sets a reference AGL altitude at home location s using

GPS and barometric pressure sensors. An equal level of safety will be achieved through the E384’s GPS and flight control, which provides altitude and location data during flight to the PIC via the ground control station. The previous safety protocols are outlined in the Preflight checklist within the Event 38 Operations Manua l. Check ing the GPS read

out ensure s that it’s within tolerance prior to commencing flight operations. This, combined with the fact that the aircraft’s altitude will be visually monitored by the PIC and Safety Observer, ensures an equal level of safety is achieved without referencing an altimeter setting. Furthermore

, by operating at or below 400 ft. AGL the E384 sUAS will not create a hazard to any manned aircraft.

91.151

- Fuel Requirements for Flight in VFR Conditions

91.151 provides that no person may begin a f li ght in an airplane under day visual flight reference (VFR) conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Because the E384 sUAS is
electric

- powered, this requirement is inapplicable. Safety features on E384 prevent arming and take

- off in “Low battery” conditions as well as “return to launch” during “low battery” conditions. These features, teamed with the small size and weight of the UAV should more than achieve an equiv alent level of safety.

14 CFR Subpart E (91.401

- 91.417): Maintenance, Preventive Maintenance, and

Alterations

91.405 (a)

- States that the an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter.

91.407 (a) (1)

- Specifies that no person may operate any aircraft that has undergone

maintena nce, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under § 43.7 of this chapter.

91.409 (a) (1) (2)

- Specifies, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 and has been approved for return to service by a person authorized by Sec. 43.7(2) An inspection for the issuance of an airworthiness certificate in a ccordance with part

21.

91.417 (a) (b)

- requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for retu rn to service

.

Ryan Nolin seeks full exemption from sections (91.405 (a), 91.407 (a), 91.409 (a(1,2)), 91.417 (a,b) due to the fact that these sections apply to an aircraft with an airworthiness certificate for which Ryan Nolin is already seeking exemptio n. An equal level of safety will be achieved by using the E384 Operations Manual (Reference Attachment B ) and E384 Maintenanc e Manual (Reference Attachment A ) which provide instructions for preventive and corrective aircraft maintenance. The PIC

will be responsible for conducting maintenance in accordance with these procedures. Ryan Nolin, with the knowledge learned as a licensed Airframe and Powerplant mechanic (License # 3474636 ), will ensure that all preventive and corrective maintenance performed on the E384 sUAS will be documented.

Summary for Federal Register

Pursuant with section 333 of the FAA Modernization and Reform Act of 2012, Ryan Nolin seeks exemption from the follo wing Federal Aviation Regulations that are found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 61.113 (a)&(b), 91.151, 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), 91.417 (a)(b). Granted exemptions from these regulations would allow Ryan Nolin to safely and properly operate the E384 sUAS for the commercial purpose of precision imaging for agricultural, forestry, wildlife management and survey industries.

Ryan Nolin is prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Ryan Nolin can be contacted at any time (see contact information below) if you require additional information or clarification.

Respectfully,

Ryan Nolin Phone: (802)

- 318

- 3456 Email: ryan@skyviewcusto ms.com