November 16, 2015 TO: U.S. Department of Transportation Docket Operations West Building, Ground Floor, Room w12

-140 1200 New Jersey Ave., SE Washington, DC 20590 FROM: LORBORN Energy Company, LLC 30487 Trace Lane Walker, LA 70785 Re: LORBORN Energy Company, LLC for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 Dear Gentlemen: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 C.F.R. Part 11, LORBORN Energy Company, LLC (“LORBORN Energy Co.”) hereby applies for an exemption from Federal Aviation Regulations (“FARs”) identifiedbelow, to allow commercial operations of small, unmanned aerial vehicles by and through small, unmanned aerial systems (“sUAS”) for Precision Aerial Surveying, Mapping, Utility Inspection, Pipeline Inspection, Wind Turbine Inspection and Property Damage Inspections

. This exemption is requested in subject to and in conformance with those operations and protocols outlined in this Petition, the enclosed UAS Professionals Flight Operations Manual (“Flight Operations Manual”), the sUAS Operator’s Handbook, which includes componentparts manufacturers’ operations and/or instructions manuals (“Operator’s Handbook”) and any other requirements establishedby the FAA pursuant to the FMRA. The Flight Operations Manual and Operator’s Handbook both contain confidential, trade secret and proprietaryinformation that the Petitionerhas not and will not share with others. Petitioner submits the Flight Operations Manual and Operator’s Handbook and all information contained therein as proprietary and confidential informationpursuant to 14 C.F.R. § 11.35(b). The Flight Operations Manual and Operator’s Handbook contain operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq. **I. Description**  **of Petitioner** LORBORN Energy

Company, LLC is a brokerage firm that specializes in providing support services, to include but not limited to, lease area checks, researching mineral title, figuring out working and royalty interests on oil and gas leases, acquisition of oil and gas leases, due diligence and acquisition of rights of way for utility

companies and oil and gas companies

. **II. Statutory**  **Authority** This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant toSection 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximityto airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator. If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the National Airspace System". Additionally, the FAA Administratorhas general authorityto grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702

– 44716, etseq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). **III. Qualifications**  **for Approval**  **Under Section**  **333 of the FM** **RA** The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The proposed operations would permit the use of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access; and that (4) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. Petitioner’s sUAS are rotorcraft, weighing 35 or fewer pounds including payload. They operate, under normal conditions, at low speed and have the capability to hover, and move in the vertical and horizontal plane. Petitioner’s sUASs will operate in line of sight and will only operate within those areas described in the enclosed Flight Operations Manual. Given the small size of the sUASs involved and the restricted environmentwithin which they will operate, this petition exemption falls within the zone of safety i.e., an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemptionpending completion of formal rulemaking. Also, due to the size of the sUASs and the restricted area in which the sUASs will operate, approval of the applicationpresents no national security issue. Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significantpublic benefit, the grant of the requested exemptions is also in the public interest.

Accordingly, Petitionerrespectfullyrequests the FAA grant the requested exemption without delay

.**IV. Proposed**  **Operations**

The enclosed Standard Operating Procedures describe, in detail, the policies and procedures for Petitioner's proposed sUAS operations. To assist the FAA in its safety assessment of Petitioner's proposed sUAS operations, below is a summary of operational limitations and conditions, which will ensure an equivalent or higher level of safety to operations conductedunder current regulatory guidelines: 1. The sUAS will weigh less than 35 pounds. 2. Flights will be operated within line of sight of the Operator. 3. Maximum total flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 25%. 4. Flights will be operated at an altitude of no more than 500 feet above ground level ("AGL"). 5. Flights will be operated at a safe lateral distance from, and not directly above, any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation. 6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot's certificate. 7. The sUAS Pilot with Pilot in Commandresponsibilities for the flight will be the designated Operator ("Operator"). 8. The sUAS will operate only within a confined area as described in the Flight Operations Manual. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's missions. It will be mandatorythat all personnel who will be performing duties within the boundaries of the safetyperimeterbe present for this briefing. 10. The Operator will have been trained in operations of sUAS generally and received up-to

-date information on the particular sUAS to be operated as required in the Flight Operation Manual. 11. Written and/or oral permission from the relevantpropertyholders will be obtained. 12. If the sUAS loses transmission signal, the sUAS will have the capabilityto return to a pre-determined location and land. 13. The sUAS will have the capabilityto abort a flight in case of unpredicted obstacles or emergencies.**V. Regulations**  **From Which**  **Exemption is**  **Requested**

The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including sUASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. Petitioner seeks an exemption from several interrelatedprovisions of 14 C.F.R. Parts 21, 45 and 91 for purposes of conducting Precision Aerial Surveying, Mapping and provind Inspections using sUASs. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas establishedwhich will ensure a level of safetybetter than or equal to the rules from which exemption is sought.

**A. 14 C.F.R.**  **Part 21, Subpart**  **H**

**– Airworthiness**  **Certificates and 14 C.F.R.**  **§ 91.203(a)(1)** Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural requirements for the issuance of airworthiness certificates as requiredby 14 C.F.R. § 91.203(a)(1). Given the size and limited operating area associatedwith the sUAS to be utilizedby

the Petitioner, an exemption from Part 21, Subpart H, meets the requirements of an equivalent level of safetyunder Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximityto airports and populated areas of the particularUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe as, or safer than, a conventional rotorcraft operating with an airworthiness certificate without restrictions and conditions of the proposed sUAS operations. **Equivalent Level**  **of Safety** The sUAS to be operated hereunder, DJI Phantom 3 Pro multi

-rotorrotorcraft, weighs less than 35 pounds with payload, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusivelywithin a securedand sterile area. Unlike other civil aircraft, the proposed operations will be controlled and

monitoredby

the Operatorpursuant to the Flight Operations Manual’s requirements. These safety enhancements, which already apply to civil aircraft operated in connection with existing inspection operations, provide a greater degree of safety to the Petitioner's employees, members of the public, and property owners than conventional operations conductedwith airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national securityposed by the sUAS, due to its size, speed of operation, lack of explosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. **B. 14 C.F.R.**  **Part 27 Airworthiness**  **Standards: Normal**  **Category Rotorcraft**  14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the Petitioner's sUAS would otherwise require certificationunder Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21, Subpart H. **C. 14 CFR**  **§ 61.113: Private Pilot**  **Privileges And Limitations**  Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also have the effect of requiring a second

-class medical certificate. **Equivalent Level**  **of Safety** In Grant of ExemptionNo. 11062 to Astraeus Aerial (Astraeus), the FAA determinedthat an Operator with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Additionally, as previously determinedby the Secretary of Transportation, the requirementto have an airman certificate ameliorates security concerns over civil UAS operations conducted in accordance with Section 333. The Precision Aerial Surveying, Mapping and Inspections conductedby LORBORN Energy Co. occur in areas where access to the public is strictly limited and controlled. Under most circumstances, all of the property or structures are owned and operated by separate entities

. As a result, the operation could have an impact on any third persons not involved in the inspection. However, LORBORN Energy Co. will ensure that permission is received, orally or in writing, from any and all landowners that the flight of the sUAS could impact. Because LORBORN Energy Co. will operate in a sterile area, the sUAS will be flown based on visual line

-of

-sight at altitudes below 500' AGL. Accordingly, LORBORN Energy

Co. request that this exemptionbe granted. **C. 14 C.F.R. §§ 91.9(c),**  **45.23(b) and 45.27(a): Aircraft Marking**  **and Identification**  **Requirements** Petitioner seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard

requirements, provides that: No person may operate a U.S.

-registered civil aircraftunless that aircraft is identified in accordance with Part 45 of this chapter.
**Equivalent Level**  **of Safety** The equivalent level of safety for exemptions to the aircraft marking and identificationrequirements of §§ 91.9(c), 45.23(b) and 45.27(a) will be providedby having the sUAS marked on its fuselage as requiredby § 45.29(f). The FAA has previously issued the following exemptions to the aircraft marking requirements of § 45.23(b): ExemptionNos. 10700, 10167 and 10167A. **D. 14 C.F.R. § 91.9(b)(2): Civil**  **Aircraft Flight**  **Manual in**  **the Aircraft**  Petitioner seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: (b) No person may operate a U.S.

-registered civil aircraft

–

... (2) For which an Airplane or Rotorcraft Flight Manual is not requiredby § 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 combinationthereof. Given its physical dimensions, configuration and load capacity, the sUAS has no abilityto carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simplyno room or capacityto carry such an item on the aircraft. **Equivalent Level**  **of Safety** The safety related purpose of this manual requirement can be equally satisfied by maintaining the sUAS flight manual at the ground control point where the Operator will have immediate access to it. Accordingly, Petitionerrequests an exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the sUAS flight manual be available at the control point during each operation. The FAA has issued the following exemptions to this regulation: ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **E. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft**  **Airworthiness** Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraftbe in airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the sUAS, should this exemptionbe granted, no FAA regulatory standard will exist for determining airworthiness.**Equivalent Level**  **of Safety** The DJI Phantom 3 Pro has a stellar safety record, demonstrating that the sUAS is airworthy. Further, given the size of the sUAS and the requirements contained in the Flight Operation Manual for maintenance and pre-flight safety check lists, an equivalent level ofsafety will be provided. The FAA has issued the following exemptions to this regulation: ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **F. 14 C.F.R.**  **§ 91.103: Preflight Action**  Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiarwith specific informationbefore each flight, including information contained in the FAA

-approved flight manual on board the aircraft. While the Operator will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA

-approved flight manual is required on board the aircraft. **Equivalent Level**  **of Safety** An equivalent level of safety will be providedby following the Operator’s Handbook. The Operator will take all requiredpreflight actions

- including reviewing weather, flight batteryrequirements, landing and takeoffdistance, and aircraft performance data

- before initiation of flight. The Operator’s Handbook will be kept at the ground station with the operator at all times. **G. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 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." sUASs and remotelypiloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplishedthrough the use of a box that communicates with the aircraft via radio communications. **Equivalent Level**  **of Safety** Given the size and speed of the sUAS, an equivalent level of safe training can still be performedwithout dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance away in the event that the sUAS experiences any difficulties during flight instruction. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. Exemptions include: Nos. 5778K and 9862A.**H. 14 C.F.R.**  **§ 91.119: Minimum Safe**  **Altitudes** Petitionerrequests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from anyperson, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopterto operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." To provide the intended inspections, the sUAS is normally operatedbelow 500 feet AGL. Additionally, due the nature of the proposed operations, the sUAS will maintain a safe lateral distance from inhabited structures, buildings, vehicles, and vessels, and from people not associatedwith the operation. **Equivalent Level**  **of Safety** Comparedto flight operations with rotorcraft weighing far more than the maximum 35 pounds proposed herein, and given the lack of flammable fuel, any risk associatedwith these operations is far less than those that presently exist with conventional aircraft. An 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. As set forth in the Flight Operation Manual, the sUAS will be operated in a restricted and sterile area, where buildings and people will not be exposed to operations without theirpre-obtained consent. Because of the advance notice to the property owners and participants, all affected individuals will be well aware of the planned flight operations as set forth in the Flight Operation Manual. Furthermore, by

operating at such lower altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI Phantom 3 Pro demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments. **I. 14 C.F.R. § 91.121: Altimeter**  **Settings** This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeterthat is set to the elevation of the departure airport or barometric pressure. An exemption is requiredbecause the sUAS does not have a barometric altimeter, but rather a GPS altitude read out. **Equivalent Level** **of Safety** An equivalent level of safety will be achievedby following the procedures set forth in the Flight Operation Manual. As prescribed in the Flight Operation Manual, the operator will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the Operator will use the GPS altitude indicatorto constantly monitorthe sUAS's height, thus ensuring operation at safe altitudes.**J. 14 C.F.R. § 91.151(a): Fuel**  **Requirements for**  **Flight in**  **VFR Conditions**  Petitionerrequests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (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; or (2) At night, to fly after that for at least 45 minutes. Here, the batterypowering the DJI Phantom Pro 3 provides approximately23 minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safetymarginbased on a reserve amount of battery life is needed. Petitionerwill not be conducting any sUAS flights at night. **Equivalent Level**  **of Safety** An equivalent level of safety will be achievedbecause the operations will be conducted on-site without significant transit time by the sUAS. All flights will be planned to be terminatedwith no less than 25% reserve batterypower still available. This restriction would be more than adequate to return the sUAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the ty

pe of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. This request for exemption falls within the scope of prior exemptions, including ExemptionNos. 10673, 2689F, 5745, 10673, and 10808. **K. 14 C.F.R.**  **§ 91.203(a) and (b): Carrying**  **Civil Aircraft**  **Certification and**  **Registration** Petitioner seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. § 91.203(a) and (b). The regulation states in pertinentpart: (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 aircraftunless the airworthiness certificate requiredby 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 topassengers or crew. In addition to the fact that Petitioner is seeking an exemption from the airworthiness certificate requirements, an exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacity and size does not allow it to carry certification and registration documents; (2) the sUAS does not have a cabin or cockpit entrance at which documents could be displayed; and (3) there are no passengers or crew for whom the certificates need to be displayed. **Equivalent Level**  **of Safety** To the extent these regulations are applicable to the proposed sUAS operations, an equivalent level of safety will be achievedby keeping these documents at the ground control point where the Operator will have immediate access to them. The FAA has issued numerous exemptions to this regulation, including: Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **L. 14 C.F.R.**  **§ 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance**  **Inspections** Petitioner also seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemptionto these regulations is neededbecause Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have. **Equivalent Level**  **of Safety** An equivalent level of safety will be achievedbecause maintenance and inspections will be performed in accordance with the Operator’s Handbook as referenced in the Flight Operation Manual. As provided in the Flight Operation Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenanceperformed. The operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restricted areas for limitedperiods of time during daylight hours, creates less risk than that associatedwith conventional rotorcraft performing the same operation.**VI. Public**  **Interest**

Granting LORBORN Energy Co.’s exemption request furthers the public interest. National policy

set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. Inaddition, maintaining industrial safety has been a priority of state and local governments for decades. By their nature, structural inspection sites presentunique difficulties for persons attempting to inspect and maintain the structure. The components can be tall and have limited access. Sending a human observer or using helicopters to inspect such elevated structures carry certain risks. These risks can be avoidedby using a small UAS under controlled conditions to photograph and documentthe state of the equipment. This helps to facilitate repairs and identify issues before they become problems. Current options for inspecting structures and conducting aerial site surveys and mapping is limited to using human personnel. Inspectors will eitheruse a normal rotor wing manned

-aircraft or crane baskets to raise a human observers to an elevatedposition. The use of an sUAS reduces the risk to human life by

removing them from dangerous aspects of the inspection process. In addition, granting the exception will help advance the knowledge base for conducting commercial UAS operations. This additional data will help the FAA set future rules regarding UAS flight operations, maintenance, and crew qualifications. The public also has an interest in reducing the hazards and emissions associated with alternate use of helicopters to conduct similar inspection operations. The UAS in question is very light weight and does not carry any flammable fuel, further reducing the risk from any potential accident. **VII. Privacy**  All flights will occur over propertywith the property owner's prior consent and knowledge. **VIII. Federal**  **Registry Summary**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determinedthat publication is needed: LORBORN Energy

Company, LLC seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 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)(2); 14 CFR 91.417 (a) & (b). Approval of these exemptions allowing commercial operations of small and lightweight unmanned aircraft ("sUAS") to conduct structural inspections will enhance safety by reducing risk to LORBORN Energy Co’s contractors, the general public and property owners. The DJI Phantom 3 Pro sUAS, weighing less than 35 pounds, with payload, and powered by

batteries, eliminates virtually all of that risk given the reduced mass and lack of combustible f

uel carried on board. The sUAS is transported to the designated survey area set up. It is not flown from an external location to the work

-site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associatedwith mannedaircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the exemptions requestedherein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, and in a controlled environment. As a result, they are far safer than conventional aerial survey and inspection operations conductedwith fixed wing aircraft or helicopters. **IX. Conclusion**  Satisfaction of the criteriaprovided in Section 333 of the Reform Act of 2012

—size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line of sight and national security

— provides more than adequatejustification for the grant of the requested exemptions to permit LORBORN Energy Company, LLC to operate sUASs in support of its Precision Aerial Surveying, Mapping and Inspections in accordance with the Flight Operation and Operator’s Handbook appendedhereto. Granting the requested exemptionwill benefit the public interest as a whole in many ways, including (1) significantlyimproving safety and reducing risk by alleviating human exposure to danger, (2) improving the inspection process and decreasing operating costs, and (3) providing an environmentallyconscientious way of conducting site surveys and structural inspections.

Sincerely, Adam J. Raborn Owner, LORBORN Energy Company, LLC

Encls: - Flight Operations Standard Operating Procedures (confidential)

- DJI Phantom 3 Pro Start Guide