## kbs + armoury

Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 1 of 19 30 JAN 2016

Chris Mozolewski Chief Financial Officer Bond Senecal & Partners , LLC 160 Varick St

. New York, NY 10013

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

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 4 5.23(b); 14 CFR 61.315(c ); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ Reform Act”) and 14 CFR Part 11, Kirshenbaum Bond Senecal & Partners, LLC , 160 Varick St, New York, NY 10013
, operator of a small Unmanned Aircraft System ( s UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Kirshenbaum Bond Senecal & Partners, LLC , 160 Varick St, New York, NY 10013
, intends to conduct commercial operati ons of a sUAS for compensation or hire as described in the exemption request. The sUAS are equipped with camera(s), sensors, and other avionics that would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including televisio n, public events, cinematography (closed set operations

- see Appendix A for CSFOM) and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

4. Aerial inspect ion/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 2 of 19 6. Search and Rescue sU AS training and services provided to the local municipal and state officials under agreements of community service in a time of need.

7

. Training to persons individually or belonging to both private and/or public organizations to increase awareness and im prove safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would per mit the safe and beneficial operation of the

s UAS as set forth in this document under controlled conditions in the NAS . Using th e Maintenance, Operations, Safety, and Training (MOST) manuals of Kirshenbaum Bond Senecal & Partners, LLC

, ensure that the sUAS flight operations would be conducted in a limited, controlled, and predetermined manner in compliance with the conditions of approval and other FARs as ap plicable

. Approval of this exemption would increase public education and awareness of sUAS operations, furthering aviation safety through Kirshenbaum Bond Senecal & Partners, LLC , participation in voluntary safety reporting activities and data collection, and aid others in fulfilli ng the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Sincerely,



## C

hris Mozolewski

Chris Mozolewski Chief Financial Officer Kirshenbaum Bond Senecal & Partners , LLC dba kbs+ armoury

The name and address of the applicant is:

Chris Mozolewski Chief Financial Officer Kirshenbaum Bond Senecal & Partners , LLC dba kbs+ armoury 160 Varick St

. New York, NY 10013

Point of Contact: o: 212 352 6558 mjolly@ armourynyc.com

Enclosure(s)

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 3 of 19 

## SUMMARY

**FAR EXEMPTION REQUEST LIST**

1. 14 CFR Part 21 subpart H
2. 14 CFR 45.23 (b)
3. 14 CFR 61.315 (c)

4. 14 CFR 91.7 (a)
5. 14 CFR 91.9 (b) (2)
6. 14 CFR 91.103
7. 14 CFR 91.109
8. 14 CFR 91.119 (c)
9. 14 CFR 91.121
10. 14 CFR 91.151 (a)

11. 14 CFR 91.203 (a) & (b)
12. 14 CFR 91.405 (a)
13. 14 CFR 91.407 (a) (1)

14. 14 CFR 91.409 (a) (2)
15. 14 CFR 91.417 (a) & (b)



### APPLICANT
Chris Mozolewski Chief Financial Officer Kirshenbaum Bond Senecal & Partners , LLC 160 Varick St

. New York, NY 10013

Point of Contact: o: 212 352 6558 mjolly@ armourynyc.com



### sUAS OPERATIONAL DETAILS Kirshenbaum Bond Senecal & Partners, LLC , will operate one or more of the following models of s UAS:

**Aircraft** DJI S900; DJI S1000; DJI Phantom 1, 2, 3; DJI Inspire; EOdrones HLH; EOdrones FTX; EOdrones HLQ;
EOdrones 250; EOdrones FTW ; Lockheed Martin Desert Hawk; Lockheed Martin Indago; Prioria Maverick; 3dr Iris; 3dr Solo; 3dr Aero.

**Primary Flight Control Systems** DJI aircraft use the DJI Autopilots; EOdrones a nd 3dr use the 3dr Autopilots; Lockheed Martin and Prioria use the Lockheed Martin Kestrel autopilots.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 4 of 19 **Operations Risk Assessment** Given the small size of the s UAS in sc ope and the controlled environment provided, the proposed operations will adhere to the Reform Act’s safety requirements.

The approval of this application presents no national security issues.

Regarding the level of safety surrounding the proposed operat ions and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest.

Accordingly, the applicant requests that the FAA grant the requested exemption.



### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limit ations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh less than 55 lbs.

2. The UAS, depend ing on the model in operation, will have a maximum operating speed of no more
than 55 knots.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight w ill be depending on the UAS model in operation,
but will not exceed 12 0 minutes. Flights will be terminated at 25% battery p ower reserve or 5 minutes of flig ht time whichever occurs first during the flight operation.

5. Flights will be operated at an alt itude of no more than 2 0 0 feet Above Ground Level (AGL) OR the height of the obstacle from which the PIC is operating, whichever is higher.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Sensor Operator (S O).

7. The UAS pilot in command will be a FAA certificated pilot with at least a sport pilot's l icense and a
FAA medical certificate OR a valid driver's license

.

8. A flight planning and safety briefing will be performed prior to each flight consisting of FAR required planning and notifications.

9. All f light activities related to the PIC and VO w ill be logged using industry best practices of digital audio/video via the use of the M obile O bservation B ased A fter A ction R eview S ystem (MOBAARS) tools required by Kirshenbaum Bond Senecal & Partners, LLC , flight operations policy.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 5 of 19 10. All flights will occur under Visual Flight Ru les Meteorological Conditions (VMC) only.

11. The flights will occur in Cla ss G airspace no closer than a 3 nautical mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport not classified as

restr icted, private, or closed.

12. For the purposes of sUAS operations, Kirshenbaum Bond Senecal & Partners, LLC , periodically
conducts "closed set fl ight operations" (see Appendix A for the applicable CSFOM). When required, t he operator will file FAA Form 7711

- 1 ( or its equivalent) with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned sUAS operation s

.

13

. The operator will obtain verbal/written consent of all persons involved with the planned operation
and e nsure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

14. The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated.

15

. The PIC and VO will be able t o communicate by voice and/or radio at all times.

16

. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appro priate to flight operations.

17

. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre determined location within a designated location and land autonomously.

18

. The UAS will have the capability to abort a flight in case of emergencies with an automated “Return
Home and Land” function.

19

. The UAS will have the capability to abort a flight (forced landing) in case of unpredicted obstacles, weather, or emergencies such as low battery.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 6 of 19 

## FARS FROM WHICH **APPLICANT IS REQUESTING EXEMPT**  **ION** 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. § 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes 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 Subpart H meets the requirements of an equivalent l evel 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 FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consider ation 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 without an airworthiness
certificate in the restr icted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be oper ated 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 and designated area.

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements 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.

A pplication of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, spe ed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 7 of 19 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 near each entrance to the cabin,

c ockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable 14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requir es: 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 aircra ft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness 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 impossible.

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 with the UAS will s ee the identification of the UAS as “Experimental.”

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 8 of 19 14 C.F.R. § 61.315 (c): Sport Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.315 (c ) (1), (2), (3), no person who holds a sport pilot certificate may act as a pilot
in comma nd of an aircraft that is carrying passengers or property for compensation or hire , operated for compensation or hire, or used in furtherance of a business

. The proposed UAS operations will achieve an equiva lent level of safety as stipulated by current r egulations because the applicant’s UAS do not carry any pilo ts or passengers for hire, and any property carried would be so insignificant as to not be measureable in terms of aeronautical/operational risk . The risk associated with the proposed operation

o f UAS is far less than the risk levels inherent in the piloting of manned aircraft for commercial ac tivities
outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct supe rvision of, a FAA
certificated s port pilot with current third c lass or higher medical certificate OR a valid driver’s license

. It is believed that the operation and limitations set forth in the operators training program and flight operations manuals will equate to the safe operation of the aircraft (sUAS) as intended by FAR and approved in preceding petitions

.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 9 of 19 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The regulation requires 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 for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be

pr ovided.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 10 of 19 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 ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available 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 plac e 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.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 11 of 19 14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved aircraft flight manuals will not be provided for the aircraft an exemption will
be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requi rements, landing and takeoff distances and aircraft performance data before initiation of flight

.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 12 of 19 14 C.F.R. § 91.109: Flight Instruction.

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design may not have fully f unctional 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. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

## kbs + armoury

Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 13 of 19 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 operated at less than the minimums prescribed, provided the person operating the helicopter complies with any ro ute or altitudes prescribed for helicopters by the FAA. As this exemption
i ncludes a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to
2 00 AGL, or not more than 200 above a structure involved in the flight operati on is planned, an exemption may be n eeded to allow such operations. For the purposes of waiver of the minimum safe altitudes, Kirshenbaum Bond Senecal & Partners, LLC further constrains its flight operations to comply with the UASA Closed Set Flight Operations Manual (see Appendix A).

As set forth herein, the UAS wil l never operate at higher than 2 00 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exc eeds 2 00 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where 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, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or
local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations wi th aircraft or rotorcraft weigh ing far more than the maximum 55l bs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL.

In addition, the low altitude operations of the UAS will en sure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 14 of 19 14 C.F.R. § 91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitu de 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 U.S. exemptio n may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 15 of 19 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 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; or (2) At night, to fly after that for at least 45 minutes.” The applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed 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. The applicant believes that an equivalent level of safety can be ac hieved by limiting flights to 5 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.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 16 of 19 14 C.F.R. § 91.203 (a) and (b): Carryi ng 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 civil 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 or crew. The UAS fully loaded weighs well under the proposed 55 lb limit and is operat ed 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.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 17 of 19 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 o wner “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...,” and
othe rs shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections 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 op erator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If
mechani cal issues arise the UAS can land immediately and will be operating from no higher than 2 00 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance perf ormed. 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. An equivalent level of safety will be achieved because
maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 18 of 19 

## ADDITIONAL INFORM **ATION** The applicant, Kirshenbaum Bond Senecal & Partners, LLC , believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficient justification for the granting of commercial opera tions of the applicant’s UAS.

The applicant, Kirshenbaum Bond Senecal & Partners, LLC , requests your respective approval of this Section 333 exemption petition request.

Please notify Kirshenbaum Bond Senecal & Partners, LLC , of your actions, and or approvals.

Thank You for your interest in this request.

Si ncerely,



## C

hris Mozolewski

Chris Mozolewski Chief Financial Officer Kirshenbaum Bond Senecal & Partners , LLC dba kbs+ armoury

Mailing Address:

Chris Mozolewski Chief Financial Officer Kirshenbaum Bond Senecal & Partners , LLC dba kbs+ armoury 160 Varick St

. New York, NY 10013

Point of Contact: o: 212 352 6558 mjolly@ armourynyc.com

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Kirshenbaum Bond Senecal & Partners, LLC PL112

- 95 Sec 333 Letter DEC 2015

- Summary Approval Process Filing 160123v3.docx 19 of 19 APPENDIX A

- UASA Closed Set Flight Operations Manual (CSFOM)

– Submitted Under Proprietary Terms