January 20, 2016 U

. S . Department

of Transportation Docket Management System 1200 New Jersey Ave., SE Washing ton, DC 20590 Re

: Request for Exemption under Section 333 of the FAA Modernization
and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations. Name and Address
of Petitioner: Brad Darrow 1331 Grant St Ashdown

, AR 71822 903-826-8776 (Cell) 87Q-898-8591 (Home) brad

. da
r row@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

. 429ThePetitionerwishestobegrantedtheexemptionforuseoftheUASofcommercialoperationslistbelow.ApplicationsandOperations:LandSurveyingandMapping•ForestHealthMonitoring•HarvestingMonitoring•ForestInventory•Topography•EnvironmentalAssessment•LocationofUtilities•AerialPhotography-RealtimeForestInventoryAnalysis•MappingForestStandsandVolumes•EstimatinglogandChipInventoriesonManufacturingSitesEquipmentInspections•VisualMonitoringofEquipmentThePetitionerbelievestheuseoftheUAS'sismoreeconomicalandsafertousefortheaforementionedpurposes.UseoftheUASratherthanamannedaircraftismoreeconomicaltotheconsumer,andbeneficialtothegeneralpublicduetoitssmallsize,lownoiseandminimalpotentialforaccident.CharacteristicsoftheAircraft:TheUAStobeusedisthe3DRIRIS+whichhasasmall20inchwingspanandultra-light(payloadcapacityof.8pounds)makingthisplatformperfectforprecisionaerialmappingmissionsthankstotheon-boardGPSandtherelatedflightmanagementsoftware(MissionPlanner)thatallowstheoperatortoplansafelyandefficientlyamissionin30,andthenmonitoritinreal-time.Theonboardcameratakesandcollectshighdefinitionstillimagesthatarelaterusedtogeneratemapsandcontourlinesofthesurveyedarea.ThefourmaincharacteristicsoftheIRIS+are:1.VeryLightWeightTheIRIS+issolighttheoperatorcanlaunchitbyhandandletitlandonalmostanysurfacewithoutrequiringaparachuteorlandingnet.Itslowimpactenergy(inthecaseofacontrolledemergencylanding)alsosignificantlyreducestheriskofhazardoussituations.2.Electric-poweredTheIRIS+iselectricpowered.Abrushlessenginetechnologymakesitsilentandreliable.3.Semi-automaticflightTheartificialintelligenceincorporatedwithintheIRIS+autopilotsystemcontinuouslyanalyzesdatafromtheonboardGPSandtakescareofallaspectsoftheflightunderthesupervisionoftheoperator.4.OptionforManualcontrolAdditionally,theIRIS+providesanoverridecapacitythatallowstheoperatortotakemanualactionsduringtheflight(GotoHome,GoLand,HoldandResumethemission)andalsosuspendsautomatedoperationsandtakemanualcontroloftheaircraftshoulditbecomenecessarytorespondtoemergentcircumstances,thankstotheremotecontrollerprovidedwiththesystem.Request for Exemption, Section 333 of the FAA Reform Act pertaining
to Federal Aviation Regulations: The Petitioner requests
an exemption from the following regulations

as well as any additional regulations that may technically apply to the operation

of UAS's. 14 CFR 21 H: Airworthiness Certificates Certification Procedures
for Products and Parts Reason for Exception It has been determined that similar UAS's do not require an airworthiness certificate

as granted

in Exemption No.11623, 11650, 11664 and 11734. 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

.14 CFR 91.9 (b) (2)

: Civil Aircraft Flight Manual
in the Aircraft This regulation provides that no person may operate
an aircraft unless

a current, approved flight manual is in the aircraft

. We assume that the intent of this requirement

is to ensure that flight manual information

is available
to the aircrew while operating the aircraft. We request
an exemption

to this requirement since the aircraft

is not only too small to carry documentation

; the documentation would not be available
to the crew

. Reason for Exception The equivalent level of safety will be maintained

by keeping the flight manual
at the ground control point where the pilot flying the UAS will have immediate access to it. The FSS has issued the following 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 Petit

i oner

, 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 91.121: Altimeter Settings This section requires that each person operating
an aircraft shall maintain the cruising altitude or flight level of that aircraft,
as the case may be, by reference

to an altimeter that
is set, when operating below 18,000 feet MSL. Reason for Exception Most UAS do not have

a barometric altimeter

. If does have

a GPS that will calculate altitude

. The Petitioner will limit flights to a maximum altitude of 400 feet AGL as granted

in Exemption
No

. 11623, 11664, and 11734. 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 CFR 91.407 (a) (1): Maintenance Operation after maintenance, preventative maintenance, rebuilding
or alteration

: (a) No person may operate any aircraft that has under gone maintenance, preventative maintenance, rebuilding,

or alteration unless (1) it has been approved for return to service by a person authorized under 43

. 7 of this chapter. Reason for Exception The Petitioner who has the responsibility
for the operation and safety of the UAS will follow the manufactures suggested replacement parts

. 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