### May 5, 2015

Exemption No. 11471 Regulatory Docket No. FAA

– 20 15

- 0140

Mr. Donald M. Roman Jr. TacticalMOA LLC, dba North East UAV 148 North Portage Street Doylestown, OH 44230

Dear Roman Jr. :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 9, 2015

, and additional information posted to the docket on April 22, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of North East
UAV ( hereinafter petitioner or operator ) for an exemption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to conduct aerial imagery ope rations for commercial, public, and private entities

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by t he petitioner are the DJI Phantom 2 Vision+, DJI Spreading Wings S900, and DJI Spreading Wing S1000.

### 2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the
aircraft and its operation, the Secretary of Transpo rtation has determined that this aircraft
meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from
14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection

. The FAA has issued grants of exemption in circumstances similar in all material respects t o those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly g reater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you pre sent; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, North East UAV is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, North East UAV is hereafter referred to as the operator.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision+, DJI Spreading Wings S900, and DJI Spreading Wing S1000 when weighing
less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are (not) permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vis ion unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permit ted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all docume nts needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS ope rations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the

### 4

operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any up date or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conduct ing further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the
UAS is in a co ndition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for th e aircraft and
aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a
state, the District of Col u mbia , Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The o perator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

### 5

qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be co nducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonpa rticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) ar e not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communic ations or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if gr eater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and fligh t of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforce ment official upon request.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure
tha t nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipat ing persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the prope rty owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertic al boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions
contained o n the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to t he local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for al l flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission m ust be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted an d the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Un less otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017 , unless so oner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight Standards Service

### 1 Donald M Roman Jr.

330.605.9580 droman556@att.net

January 9, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R.
45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.10 9;91.119; 91.121; 91.151(a);91.203(a) &
(b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

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, TacticalMOA L LC,

d ba North East UAV , operator s of Small Unmanned Aircraft Systems (“ UAS ”) equipped to conduct aerial imagery operations for
commercial, public, private entities , hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow

c ommercial operation of its UAS s , so long as such operations are conducted within and under the conditions outlined herein or as
may be established by the FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive

UAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide
safety enhancements to the already safe operations in the aerial imaging industry using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibiliti es to “...establish requirements for the safe operation of such aircra ft systems in the national airspace system.” Section 333(c) of the

Reform Act.
The name and address of the applicant is:
TacticalMOA LLC, dba North East UAV

Attn: Donald M Roman Jr.

Ph one : 330.605.9580

Email: droman556@att.net
Address: 148 North Portage St, Doylestown, Ohio 44230

Regulations from which the exemption is requested:

□ 14 CFR Part 21

□ 14 C.F.R. 45.23(b)

□ 14 CFR 61.113 (a) & (b)

□ 14 C.F.R. 91.7 (a)

□ 14 CFR 91.9 (b) (2)

□ 14 C.F.R. 91.103

□ 14 C.F.R. 91.109

□ 14 C.F. R . 91.119

□ 14 C.F.R. 91.121

□ 14 CFR 91.151 (a)

□ 14 CFR 91.203 (a) & (b)

□ 14 CFR 91.405 (a)

□ 14 CFR 407 (a) (1)

□ 14 CFR 409 (a) (2)

□ 14 CFR 417 (a) & (b)

### 2 This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act.
This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the
national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this
determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or
pose a threat to national security in light of the following:

□ The UAS size, weight, speed, and operational capability;

□ Operation of the UAS in close proximity to airports and populated areas; and

□ Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines t hat such vehicles “may operate safely in the national airspace system, the
Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis
added)2.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes
exempting civil aircraft, as the term is defined under §40101 of the Act, that includes UAS , from the requirement that all civil aircraft

must have a current a irworthiness certificate

.

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions
under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if i t should be determined
that the conditions set forth herein do not fulfill the statutory requirements for approval.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this se ction

or any s ections 44702

- 44716 of this title if the Administrator finds the exemption 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).

North East UAV ’s UAS are muti

- rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a
speed of no more than 45 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They
will operate only in line of sight and will operate only within the sterile area described in the North East UAV Operations Manual,
attached as Exhibit 1 ( heinafter: NE UAV Operations Manua l”)3. Such operations will insure that the UAS will “not create a hazard to
users of the national airspace system or the public.”

Given the small size of the UAS involved and the restricted sterile environment within which they will operate, the applican t falls
squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exempt ion, allow commercial operations of UAS to commence immediately. Also due to the size of the UAS and the restricted areas i n which the

relevant UAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of
the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding
the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts,
including reduced emissions associated with allowing UAS for movie and television operations, the grant of th e requested
exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemp tion
without delay.

### 3 AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant 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 op erations
under the current regulatory structure beca use the proposed operations represent a safety enhancement to the already safe aerial
imaging operations conducted with conventional aircraft.

These limitations and conditions to which North East UAV agrees to be bound when conducting commercial operations under an
FAA issued exemption include:

Reform Act Section 333 (b). ADD TO THIS 1) The UAS will weigh less than 55 lbs.
2) Flights will be operated within line of sight of a pilot and/or observer.
3) Maximum total flight time for each operational flight will be 3 0 minutes. Flights will be terminated at 25% battery power
reserve should that occur prior to the 3 0 minute limit.
4) Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform

from which aerial imaging is planned.
5) Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer, and the Camera Operator.
6) UAS pilot will be an FAA licensed airman with at least a priv ate pilot’s certificate and third class medical. The observer will

hold at least a third class medical.
7) UAS Pilot will be Pilot in Command ( PIC ) . If a pilot certificate holder other than the UAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC

. 8) The UAS will only operate within a confined “Sterile Area” as defined in the NEUAV Operations Manual Section I I of the
NEUAV Operations Manual requires the establishment of a “Security Perimeter” for the flight operations area.
9) A briefing will be conducted in regard to the planned UAS operations prior to each aerial activit y . It will be mandatory that
all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.
10) The operator will obtain the consent of all persons involved in the aerial imaging activities and ensure that only consenting
persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an
equivalent level of sa fety determination, as required by Section II of the NEUAV Operations Manual . With the advanced
permission of the relevant DFO , operations at closer range can be approved.
11) The DFO will prepare a written Plan of Activities three days before the proposed op erations as required in Section I of the

Manual.
12) Pilot and observer will have been trained in operation of UAS generally and received up

- to

- date information on the
particular UAS to be operated as required Sections II through V of the NEUAV Operations Man ual

. 13) Observer and pilot will at all times be able to communicate by voice and/or text.
14) Written and/or oral permission from the relevant property holders will be obtained.
15) All required permissions and permits will be obtained from territorial, state, cou nty or city jurisdictions, including local law
enforcement, fire, or other appropriate governmental agencies.
16) If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location
within the Security Perimeter and land.
17) The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, es tablishes the procedural requirements for the issuance of airworthiness certificates
as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the
Applicant, an exemption from Part 21 Subpa rt H meets the requirements of an equivalent level of safety under Part 11 and Section
333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FA A to exempt aircraft from the requirement fo r an airworthiness certificate, upon consideration of the size, weight, speed, operational
capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria
demonstrates that the UAS operated witho ut an airworthiness certificate, in the restricted environment and under the conditions

### 4 proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airwor thiness

certificate without the restriction s and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive
materials or flammable liquid fuels, and operates exclusively within a secured area as set out in th e Manual. Unlike other civil
aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the NE UAV
Operations Manua l requirements, and under the requirements and in compliance with local public safety requirements, to provide
security for the area of operation as is now done with conventional a erial imaging operations . The FAA will have advance notice of
all operations. These safety enhancements, which already apply to civil aircraft operated in connection with aerial imaging
operations , provide a greater degree of safety to the public and property owners than conventional operations conducted with
airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria de monstrates that
there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation , lack of
explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C .F.R. § 45.23 (b). Marking of the Aircraft
The regulation requires:
When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft ne ar each
entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "l imited,"
"restricted," "light

- sport," "experimental," or "provisional," as applicable.
Even though the UAS will have no ai rworthiness certificate, an exemption may be needed as the UAS will have no entrance to the
cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS , two

- inch lettering will be
imposs ible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot,
observer and others working wi th the UAS will see the identification of the UAS as “Experimental.” The FAA has issued the following
exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.
Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations

. Because the UAS will not carry a pilot or passengers, the
proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC (PILOT IN COMMAND)
operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a
conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area of
operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. Th e level of
safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial
pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the UAS are so diminished from the
level of risk associated with commercial operations contemplated by Part 61 when d rafted, that allowing operations of the UAS as requested with a private pilot as the PIC (PILOT IN COMMAND) exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a)
& (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.
The regulation req uires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no
airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist fo r determining airworthin ess. Given the size of the aircraft and the requirements contained in the NE UAV Operations Manua l for
maintenance and use of safety check lists prior to each flight, as set forth in Sections II,III & V , an equivalent level of safety will be
provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.
Section 91.9 (b) (2) provides:
No person may operate a U.S.

- registered civil aircraft ...

### 5 (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is a vailable in the aircraft
a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination

thereof.

The UAS , given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is
no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.
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 FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737,
8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight a ction
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA a pproved
rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be
provided as set forth in Sections I through V of the NEUAV Operations Manual . The PIC (PILOT IN COMMAND) will take all actions
including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before
initiation of flight.

14 C.F.R. §91.109: Flight instruction : Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for fli ght

instruction unless that aircraft has fu lly functioning dual controls. UAS and remotely piloted aircraft, by their design do not have
fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the ai rcraft 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 n either a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operat ed at less
than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescrib ed for
helicopters by the FAA. As this exemption is for a UAS that is a muti

- rotorcraft and the exemption requests authority to operate at
altitudes up to 400 AGL, or not more than 200 above an elevated platform from which activities may be planned, an exe mption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never
operate at higher than 400 AGL . It will however be operated in a pre

- designated area with a defined perimeter, wh ere buildings and
people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated.
No flight will be taken w ithout the permission of the property owner or local officials. Because of the advance notice to the property
owner and participants in the aerial activity, all affected individuals will be aware of the planned flight operations as set forth in

Section II of the NEUAV Operations Manual . Compared to flight operations with aircraft or rotorcraft weighting far more than the
maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than tho se presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

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

- UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter Settings
This regulation requires each person operating an aircraft to maintain crui sing 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 UAS may not have a
barometric altimeter, but instead a GPS altitude read out, an exem ption may be needed. An equivalent level of safety will be
achieved by the operator, pursuant to the NEUAV Operations Manual Section III and Safety Check list, confirming the altitude of the
launch site shown on the GPS altitude indicator before flight.

### 6 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering w ind and
forecast weather conditions) there is enough fuel t o 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; or (2) At night, to fly after that for at least 45 minutes.”
The battery powering the UAS provides approxima tely 4 0 minutes of powered flight. To meet the 30 minute reserve requirement in
14 CFR §91.151, UAS flights would be limited to approximately 1 0 minutes in length. Given the limitations on the UAS proposed
flight area (s) and the location of its proposed op erations within a predetermined area, a longer time frame for flight in daylight or
night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly
controlled area where only people and property owners or official representatives who have signed waivers will be allowed, wi th

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the
size and speed of the small UAS. Additionally, limiting UAS flights to 1 0 minutes would negate the utility for which the exemption wi ll
be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 3 0 minutes or 25% of battery power
whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere
in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinent part:
(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:
(1) An appropriate and current airworthiness certificate. . . .
(b) No person may operate a civi l aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special
flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers o r crew.

The UAS fully load ed weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to
carry certification and registration documents or to display them on the UAS

. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS . The FAA has issued numerous exemptions to this
regulation. A representative sample of other exceptions in cludes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and

10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections
These regulations require that an aircraft operator or owner “shall have that aircraft i nspected 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the
applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenc ed

in the NEUAV Operations Manual .(See Sections V ) An equivalent level of safety will be achieved because these small UAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanic al issues
arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the ope rator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a l og of any

### 7 maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the
aircraft in an airworthy condition to provide the equivalent level of safety.
Pursuant to 14 C.F.R. Part 11, the followin g summary is provided for publication in the Federal Register, should it be determined that
publication is needed:

Applicant seeks an exemption from the following rules:
14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121;
91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate comme rcially a
small unmanned vehicle (55lbs or less) in aerial imaging operations.

Ap proval of exemptions allowing commercial operations of UAS for North East UAV will enhance safety by reducing risk.

Conventional aerial operations, using jet or piston power aircraft operate at extremely low altitudes just feet from the subject (s)
being vi ewed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the
neighborhood of 2 ,000lbs. to 4,000lbs. , carrying large amounts of jet A or other fuel s . Such aircraft must fly to and from the
designat ed location. In contrast, a UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given

the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the designated location and not flown. The

UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.
The operation of small UAS , weighting less than 55 lbs., conducted in the strict conditions outlined abov e, will provide an equivalent
level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requireme nts of
Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile
environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in clos e proximity to the ground and people.

Privacy
All flights will occur over private or cont rolled access property with the property owner’s prior consent and knowledge. Aerial
imaging will be of people who have also consented to being filmed or otherwise having agreed to be in the area where aerial
imaging will take place.

Set forth below are PIC (Pilot In Command) Pic tures of aerial imaging/operations conducted in both day and night environment, as flown today in highly populated and/or urban areas, with turbine /piston po wered aircraft . The grant of this exemption request will
provide improved safety in both day and night operations.

### 8 Night operations will also be conducted by UAS and such operations will be fully lighted so that visibility is as though imaging was conducted during daylight hours.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

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

– provide more than adequ ate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in the aerial imaging
industry pursuant to the NEUAV Operation Manual appended hereto.

Sincerely,

Donald M

. Roman Jr. 

### Donald M

. Roman Jr.

TacticalMOA LLC, dba North East UAV

Attachments:
PIC (PILOT IN COMMAND) Credential

North East UAV Operations Manual

### 9 

# Appendix

– A PIC (PILOT IN COMMAND) Credentials

 20+ Years as a Private Pilot with Current Class III Medical

 Owner Operator of Experimental and Certified Airc raft.

 30 Years’ experience building & flying Remote Control Aircraft (Fixed Wing, Rotary and Multi

- Rotor)