Name and Address of Petitioner: 

Brad Darrow 

1331 Grant St 

Ashdown, AR 71822 

903-826-8776 (Cell) 

87Q-898-8591 (Home) 

brad.darrow@domtar .com 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act'') and 14 

C.F.R. Part 11, Brad Darrow, the Petitioner, request exemption from the following Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System. 

Regulations from which the exemption is requested: 

14CFR21 H 

14 CFR 45.23 (b) 

14 CFR 61.113 {A) 7 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b) 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) & (b) 

14 CFR 91.417 (a) & (b) 

14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67 - 61.1 to 61.429 
• Environmental Assessment • Location of Utilities 

• Aerial Photography- Real time 

Forest Inventory Analysis 

• Mapping Forest Stands and Volumes • Estimating log and Chip Inventories on Manufacturing Sites 

Equipment Inspections 

• Visual Monitoring of Equipment 

The Petitioner believes the use of the UAS's is more economical and safer to use for the aforementioned 

purposes. Use of the UAS rather than a manned aircraft is more economical to the consumer, and 

beneficial to the general public due to its small size, low noise and minimal potential for accident. 

Characteristics of the Aircraft: 

The UAS to be used is the 3DR IRIS+ which has a small 20 inch wingspan and ultra-light (payload capacity 

of .8 pounds) making this platform perfect for precision aerial mapping missions thanks to the on-board 

GPS and the related flight management software (Mission Planner) that allows the operator to plan 

safely and efficiently a mission in 30, and then monitor it in real-time. The onboard camera takes and 

collects high definition still images that are later used to generate maps and contour lines of the 

surveyed area. 

The four main characteristics of the IRIS+ are: 

1. Very Light Weight 

The IRIS+ is so light the operator can launch it by hand and let it land on almost any surface without 

requiring a parachute or landing net. Its low impact energy (in the case of a controlled emergency 

landing) also significantly reduces the risk of hazardous situations. 

2. Electric-powered 

The IRIS+ is electric powered. A brushless engine technology makes it silent and reliable. 

3. Semi-automatic flight 

The artificial intelligence incorporated within the IRIS+ autopilot system continuously analyzes data from 

the onboard GPS and takes care of all aspects of the flight under the supervision of the operator. 

4. Option for Manual control 

Additionally, the IRIS+ provides an override capacity that allows the operator to take manual actions 

during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspends automated 

operations and take manual control of the aircraft should it become necessary to respond to emergent 

circumstances, thanks to the remote controller provided with the system. 
14 CFR 45.23 (b): Marking of the Aircraft 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. 

Reason for Exception 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have not entrance to the cabin, cockpit or pilot station on which the work "EXPERIMENTAL" can be 

placed. Given the size of the UAS, two-inch lettering will be impossible. The word "EXPERIMENTAL" will 

be placed on the fuselage in compliance with 45.29 (f). 

The FM has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A. 

14 CFR 61.113 (A) 7 (b): Private Pilot Privileges and Umitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft 

of the United States, unless that person: (1) has a pilot certificate or special purpose authorization 

issued under this part in that person's physical possession or readily accessible. (2) The flight is only 

incidental to that business or employment. (3) The aircraft does not carry passengers or property for 

compensation or hire. 

Reason for Exception 

The Petitioner will follow all manufacturers' training program and safety manual. I also believe these 

requirements are unnecessary for pilot controlled drone flight. Additionally, current FM proposals have 

omitted this as a future requirement for small UAS's. 

14 CFR 91.7 (a): Ovil Aircraft Airworthiness 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition. 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate, however the 

petitioner will ensure airworthiness through the combined use of the manufacture's Operations Manual 

and preflight checks. 
exemptions to this regulation: Exemption #8607, 8737, 8738, 9299, 9299A to list a few. 

14 CFR 91.103 (b): Preflight Instruction 

This regulation requires each pilot in commend to take certain actions before flight to insure the safety 

of flight. AS FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The petitioner will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 CFR 91.109: Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.n 

Reason for Exception 

UAS's and remotely piloted aircraft, by their design so not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See exemption Nos. 

5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passenger 

will be carried in the aircraft and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 

400 feet AGL, we cannot comply with this requirement. 

Reason for Exception 

The use of UAS will be flown no higher than 400 feet AGL in LOS over developed and developing 

residential areas that may be considered congested areas. That will not always be the case when 

providing a 'Property Survey' flight because they could be conducted over empty lots or acreages with 

no structures. In the case of flying over or near existing private property while providing aerial imagery, 

property inspections, and property assessments, landowners will be notified in person by the Petitioner, 

or by a card left behind by the Petitioner if requested. The Petitioner will review with the landowners of 

associated risks to people and property. Due to the small size of the UAS the associated risk to persons, 

vessels, vehicles and structures is not comparable to manned aircraft and should be taken into 

consideration. 
14 CFR 90.151 (a) Fuel Requirements for Flight in VFR Conditions 

Fuel requirements for flight in VFR conditions: (a) No person may begin 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 normal cruising speed. (1) During the day, to fly after that 

for at least 30 minutes. 

Reason for Exception 

The UAS provides a low battery warning to indicate when you should return the UAS to the launch point. 

In addition, a "low" and "critical" battery level warnings and implemented a "return to Home" (or "Go 

Land") action in these situations. The Petitioner will not initiate a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and all flights will be conducted during daylight hours and at times not to be a nuisance to 

others. 

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) ofthis section or a special flight authorization issued under 19.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

Reason for Exception 

To obtain an equivalent level of safety and meet the intent of 91.203, documentation will be housed at a 

ground control point where the pilot is flying the UAS for immediate access to the extent they are 

applicable to the UAS's. In doing some research the FAA has issued numerous exemptions to this 

regulation. 

14 CFR 91.405 (a): Maintenance Inspections 

Each owner or operator of an aircraft- (a) shall have that aircraft inspected as prescribed in Subpart E of 

this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter. 

Reason for Exception 

The Petitioner shall inspect the aircraft prior to every flight. The Petitioner also will follow the 

manufacturer's recommended preflight checklist and make any repair necessary before flights occur. 

The Petitioner will also maintain a log of any maintenance or repairs performed. 
14 FR 91.409 (a)(l) & (2): Inspections 

Inspections: (a) Except as provided in paragraph (c) of this section, 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 of this chapter and has been approved for return to service by a person authorized by 43.7 of 

this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for 

any inspection required by this paragraph unless it is performed by a person authorized to perform 

annual inspections and is entered as an "annual" inspection in the required maintenance records. 

Reason for Exception 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in a condition for safe 

flight at all times. 

14 CFR 91.417 (a) & (b): Maintenance Records 

Except for work performed in accordance with 91.411 and 91.413 each registered owner or operator 

shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v){vi) for the periods specified in paragraph (b) 

of this section: (1) (2) (3) 

Reason for Exception 

The Petitioner will keep a record of all repairs and modifications. The Petitioner also proclaims to use 

approved manufactured parts for all repairs and modifications. 

14CFR Title 14 Chapter 1 Subchapter 0 Parts 60 thru 67- 61.1 to 61.429: Pilot Certification 

This section pertains to flight rules, pilot certificate requirements, manuals, etc. 

Reason for Exception 

The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and 

current FSS proposals have omitted this as a future requirement for small UAS's. 

In Conclusion: 

I, Brad Darrow, the Petitioner request for exemption from the above mentioned Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System in order to perform the Applications and Operations pertaining to my Forestry work in a safe and 

controlled environment. The Petitioner hopes for a timely consideration as I have made a considerable 

investment in time and finances on this project. 

Sincerely, '/ /1 ,/} 

Brad Darrow 

1331 Grant St 

Ashdown, AR 71822 

903-826-8776 (Cell) 

870-898-8591 (Home) 

brad.darrow@domtar.com