January 20, 2016

U.S. Department of Transportation Docket Operations West Building Ground Floor, Rm W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

REQUEST FOR SUMMARY GRANT OF EXEMPTION

Dear Sir or Mada m,

I am applying for a Summary Grant of Exemption under Section 333 of the FAA Reform

Act and Part 11 of th e Federal Aviation R egulations from 14 CFR Part 21, Subpart H; 14 CFR 45.23 (b); 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2)

- (8), (e)(12), (e)(14), (g); 14 CFR 61.113 (a), (b); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.111; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203 (a), (b); 14 CFR 91.209; 14 CFR 91.4 05 (a), (b); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1)

- (2); and 14 CFR 91.417 (a), (b) ; to allow commercial operation of Small

Unmanned A i rcraft Systems (" sUAS " ) for aeria l data collection

. If t his e x emption request is granted, I plan to use the Yuneec Q500 Typhoon for aerial data collection including , but not limited to, remote sensing and measuring by instrument(s) aboard the

sUAS to include imagery (photography, video, infrared, etc.), electronic measu rement (precision surveying, RF analysis, e tc.), and chemical measurement (pa rticulate measurement, etc.). More specific mission and proposed operational use with Previous Grants of Exemption listed below.

APPLICANT: Perry Gilland 152 Reid St., Roopville, Ga 30170

Ph : 770

- 842

- 6648

Email: perrygilland@gmail.com

UAS CERTIFICATE NUMBER: FA3WR9NXFM

YUNEEC Q500 “TYPHOON” The UAS for the proposed use in the exemption is the YU NEEC Q500 “TYPHOON” which has been a part of multiple previous Grants of Exemption including: 13120

, 12890

, 13500

, 12933

, 13727 . The link to the manufacturer’s owners/operators manual including specs, maintenance, proper operation and recommended safety procedures is

include d for reference.
https://www.yuneec.com/download/manuals/Typhoon%20Q500%204k

- %20User%20Manual%20V12302015.pdfFLIGHT TIME: Up to 25 Minutes

DIM ENSIONS: 8.27 in (210mm) x 16.54 in (420mm) DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm) PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm) WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g) MAXIMUM TAKEOFF WEIGHT WITH CGO3: 60.0 oz (1700g)

BATTERY: 5400mA h 3S 11.1V LiPo CHARGER: 3S 11.1V LiPo DC Balancing Smart Ch arger with AC Adapter

TRANSMITTER: 10

- channel 2.4GHz with 5.8GHz video downlink

MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground Level

MAXIMUM ROTATION RATE: 65°/s

MAXIMUM ROLL ANGLE: 35°
RADIO CONTROL FREQUENCY BAND: 2.4GHz

MAXIMUM CLIMB RATE: 2m/s

MAXIMUM DESCENT RATE: 3m/s

THE COMMERCIA L (MISSION/OPERATION) USE

FAA Previous ly Approved Exemption Numbers

The FAA has previously issued grants of exemption for aerial data collection in circumstances similar in all material respects to those I am petitioning for. In Grants of Exemption Nos. 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), 11213 to Aeryon Labs, Inc. ( see Docket No. FAA−2014−0642), and 12645 to Allied Drones ( see Docket No. FAA

- 2014

- 0804). The FAA also has previous Grants of Exemption for the following forms of data collection which I am petitioning for: 1. Bridge Inspections: 11603, 11564, 11422, 11171 2. Flare stack inspection: 11251, 11581, 11241, 11156 3. Utility

- power generation system inspections and patrolling: 11581, 11512, 11238,

11467 4. Aerial inspection, photography and videography of residential and commercial real estate, weddings and wedding receptions: 11784, 11786, 11787, 11789 5. Aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind tur bines and cell towers: 11787, 11512, 11581,

11238 6. Pipeline inspection and patrolling: 11467, 11422, 11554, 11561, 11564 7. Filmmaking, cinematography, and videography: 11581, 11251, 11256, 11659 8. Precision agriculture with on board sensors: 11759, 112 22, 11673, 11769 9. Wildlife and forestry monitoring and mosquito and insect control: 11684, 11648,
11790, 11551 10. Aerial surveying: 11593, 11600, 11567, 11581 11. Construction site inspection and monitoring: 11591, 11508, 11535, 11469 12. Public entity support operations: 11471, 11426, 11412, 1138913. Aerial imaging for safety, monitoring and comparing work efforts and completion

percentages, and security of co ntrolled environment of various sites: 11649, 11524, 11522, 11481

14. Aerial video and live video feed to assist with se arch and rescue operations under the authority and support of local authority: 11327, 11282, 11558, 11842 15. Aerial video and photography for public and pr ivate use including television, public events, and cinematography li ve f eed and live newsgathering: 11408, 11406, 11787,

11760 16. Training to persons individually or belon ging to both private and public organizations

to increase awareness and improve safety for current and future UAS operation s within the NAS: 11789, 11663, 1 1668 17. Special Events (including High Schools, Coll eges, Professional Sports, open air and fairs): 11787, 11792, 11777, 11757

18. Research: 11424, 11389, 11370, 11368

19. Risk Management and Assessment: 11293, 11494, 11481, 11293

20. D isaster and Catastr ophe events: 11309, 11487, 11370, 11327 11683

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that
have the characteristics of sUAS and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure as the proposed operations represent a safety

enhancement to the alrea dy safe aerial commercial photography and survey operations

conducted with conventional aircraft.

The Unmanned Aircraft ( “UA” ) planned to be operated is a rotorcraft, weighing 55 or fewer pounds including payload. It would op erate at a speed of no more th an 87 knots. Operations will b e performed by a qualified PIC, as outlined below, to insure that the UA will “not create a hazard to users of the national airspace system or the public.” The UA will also carry no passengers or crew. Given the small size of the UA involved

, and the

pre

- planned environment within which it will operate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemptio n, allow commercial operations of UASs to commence immediately. Also, the operation of the sUAS will have no credible threat to national security. The operation of the UA by k nowledgeable professionals with experience in the NAS will serve to enhance safety, a dd to the public benefit and reduce environmental impacts related to current methods of aerial photography and survey.

PUBLIC INTEREST This exemption application will also 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 NAS

before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress’s intent of allowing sUAS to operate with significant safety precautions in low risk environments.The use of s UASs on or wit hin a site or facility can significantly reduce the risk to

workers of falls while inspecting, surveying, or monitoring site progress, facilities, or structures. UASs can inspect, photograph, and collect data on hard to get to areas that

otherwise would re quire worker inspection or are inaccessible. Falls are the leading source of workplace fatality and injury on sites and reducing falls through s UAS use for site imaging could save workers lives. Additionally, sUASs could replace the use of helicopters and small aircraft to monitor

sites. The UA I propose to fly in this application is under 55 pounds , and carries no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to a sUAS from helicopters or other aircraft presents a marked safety increase for workers and the public. The UA does not carry a crew or passengers

that a conventional small aircraft does. The UAS, when compared to the operation of other small aircraft that are many hundreds of times heav ier, carry highly flammable fuels and highly hazardous liquids, is a much safer choice due to the possible catastrophic results of an accident. Lastly, sUASs reduce the environmental impact by dramatically decreasing the energy used for aerial imaging an d data collection over a site, facility, or structure. The proposed sUAS uses rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of other small aircraft which has a detrimental effect on the

environment . The petitioner feels that the UAS operation enabled by this exemption is in the public ’ s interest.

SAFETY FACTORS AND OPERATIONS PROPOSED

1. Prior to a sUAS flight, an area of operation wil l be established. This area of operation will include a defined lateral and vert ical area, where the sUAS will operate. Safety procedures will be establi shed for persons, property and applicable airspace within the area of operation.

2. Flights will be operated under visibility an d cloud clearance requirements equivalent to Visual Flight Rules (VFR).

3. Flight planning will include flight completion with at least 20% battery power remaining as measured by the sUAS or appropriate timing.

4. The sUAS aircraft used will utilize GPS navigation, failsafe, return

- to

- home (RTH) and/or flight abort safety features.

5. All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

6. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the sUAS will not be operated until the necessary maintenance has been performed and the sUAS i s found to be in a condition for safe flight.

7. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8. Any sUAS that has undergone maintenance or alteratio ns that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component,will undergo a functional test flight. The operator who conducts the functional test

flight will make an entry in the aircraft records.

9. The operat or will follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

10. The sUAS operated under this exemption will comply with all manufacturer Safety Bulletins.

11. Operation near airports will be conducted according to t he "blanket" COA unless

another COA is obtained.

a. 5 nautical miles (NM) from an airport having an operational control tower;

or b. 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

c. 2 NM from an airport without a published instrument fli ght procedure or an operational tower; or
d. 2 NM from a heliport with a published instrument flight procedure 12.

Maximum speed 50 knots.

12. The UAS will weigh less than 55 lbs. including payload.

13. The UAS wi ll operate under normal conditions at a speed of no more than 87

knots . In no case will the UA be operated at airspeeds greater than the maximum

UA S operating airspeed recommended by the aircraft manufacturer.

14. The sUAS will operate only in the PIC’s visual line of sight (VLOS) at all times.

15. The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL).

Such operations will insure that the sUASs will “not create a hazard to users of the

natio nal airspace system or the public.” Reform Act Section 333 (b). Given the s mall
size of the sUAS listed in my application , the sUAS fall s squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allo w commercial operations of sUASs to commence immediately. Also due to the small size of the UASs and the low altitudes and restricted areas in which my sUAS 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 , the grant of the requested exemptions is in the public interest. Accordingly, I respectfully request that the FAA grant the Summary Grant of Exemption

, as the exemption would not set a precedent, and any delay in acting on this petition would be detrimen tal to the petitioner.

Exemptions Requested The Operator generally requests exemption from the following regulations for the purpose of conducting commercial UAS operations within controlled airsp ace. 14 CFR Part 21, Subpart H; 14 CFR 45.23 (b); 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2)

- (8), (e)(12), (e)(14), (g); 14 CFR 61.113 (a), (b); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14

CF R 91.103; 14 CFR 91.109; 14 CFR 91.111; 14 CFR 91.119; 14 CFR 91.121; 14 CFR91.151 ; 14 CFR 91. 203 (a), (b); 14 CFR 91.209; 14 CFR 91.405 (a), (b); 14 CFR 91.407

(a)(1); 14 CFR 91.409 (a)(1)

- (2); and 14 CFR 91.417 (a), (b). The Operator specifically requests relief from the following regulations and in such capacity as depicted below: 14 CFR part 21 Subpart H

- Certification procedures for products and parts, Subpart H

— Airworthiness Certificates. In accordance with the statutory criteria provided in Sect ion 333 of Public Law 112−95

in reference to 49 U.S.C. 44704, and in consideration of the s ize, w eight, speed, and

limited operating area associated with the UAS and its operation, the Operator requests exemption from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certifi cation and testing requirements of part 36. 14 CFR Part 21 Subpart H meets the requirements of an equivalent le vel of safety under Part 11 and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C .§ 44701(f)) and Section 333 of the FMRA both authoriz e the FAA to exempt aircraft from the r equirement for an airworthiness certificate upon consideration of the size, weight, speed, operation al capability, and proximity to airports and populated areas of the particular UAS. In all cases , an analysis of thes e criteria demonstrates that the UAS operated without an airworthiness certifica te, in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certifica te without the

restrictions and conditions proposed. 14 CFR 45.23 (b)

– Display of marks; General. This regulation requires that aircraft display proper registration m arkings as required by

aviation authority. When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft o r experimental or provisionally certificated aircraft, the operator must also display on that

air craft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2

inches n or more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “p rovisional,” as applicable. The Operator’s UAS has no entrance to the cabin, cockpit, or pilot st ation on which the markings can be placed, two inch lettering would not be pos sible. Op erator to mark the UAS with UAS Certificate Number registration markings as large as practical to be displaye d on the top of the UA

. 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2)

- (8), (e)(12), (e ) (14), (g)

- Recreational pilot privileges and limitations. The Operator specifically request exemption from the aforementioned regulations of 14

CFR 61.101. This regulation prohibits recreational pilots from p erforming duties as a pilot for compensation or hire or aircraft with more than one power p lant, retractable landing

gear, carrying persons or property, in furtherance of a business or within class A, B, C or D airspace. The Ope rator proposes to utilize a pilot in command (PIC ) w ith a minimum of a spo rt pilot cer tificate . The proposed opera tions can achieve an equivalent level of safety of current operations by requiring the PIC operating the UAS to have a

minimum of a sport pilot’s certificate rather than a commercial pilot’s certificate to operate th e UAS proposed to be utilized in this operation. Flights which are proposed to be conducted by the Operator within controlled airspace will be conducted only having received prior approval from the local FSDO and/or the local airspace controllinga gency , (ATC) in which operations are proposed to be conducted and if applicable the

appropriat e airport manager or owner. The Operator will also publish NOTAM advisories a minimum of 24 hours prior to conducting operations within controlled airspace or as requested by FSDO. All PIC sha ll meet the requirements of 14 CFR 61.97 prior to conducting operations for the Operator as PIC. 14 CFR 61.113 (a) & (b)

- Private pilot privileges and limitations: Pilot in command. This regulation prohibits a person which holds a private pilot certificat e from operating

any aircraft as pilot in command (PIC) for compensation or for hire. This regulation also prohibit s a private pilot from conducting operations which involves carriage o f persons or property for hire. The UAS platform is not capable of carrying a pilot or pe rsons onboard the aircraft. The proposed operations can achieve an equivalent level of safety

of current operations by requiring the PIC operating the UAS to have a minimum of a sport pi lot’s certificate rather than a commercial pilot’s certificate to operate this UAS. Operator speci fically requests exemption from this regulation so that the Operator may conduct operation s using UAS for hire and in the carriage of property or equipment. 14 C.F.R. 91.7 (a), (b): Civil aircraft airworthiness This regulation requires that no person may operate a civil air craft unless it is in airworthy condition. As the U AS has no airworthiness certificate issue d for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist fo r determining

airworthiness. An equivalent level of safety will be provided by the small size of the UAV and the requirem ents contained in the manufacturer instructions for maintenance and

use of safety check lists prior to each flight. The Operator will ensure that the UAS is in an airworthy condition prior to each flight based on compliance with the specifications in

the m anufacturer instructions. 14 CFR 91.9 (b) (2)

- Civil aircraft flight manual, marking, and placard requirements. This regulation requires that an aircraft flight manual be carried upon the aircraft while in flight. With the operational limitations of the U AS and the unmanned nat ure of its operation, it is not practical to carry a flight manual onboard the aircraft while it is i n operation. The Operator shall familiarize him/herself with the operational manual of the UAS pr ior to performing operations as the PIC. Additionally, the PIC shall have access

to the manufac turer’s operational manual (OM) while operating the UAS. The UAS operated by the Operator will be identified by serial number, registered in accordance with 14 CFR part 47, and have identi fication markings in accordance with 14 CFR p art 45, Subpart C. Markings will be as large as practicable.
14 CFR 91.103

- Preflight action. The Operator only seeks to obtain exclusion from this r egulation as to an FAA approved operational or flight manual for the UAS. UAS equipment is no t approved as an airframe

under 14 CFR Parts 23 or 25 certification and as such no FAA approv ed flight operations manual is published. The Operator will utilize the UAS manufacturer

o perators ’ manuals (OM), policies and procedures d eveloped by the manufacturer for operatio n of the UAS. Additionally, the Operator will conduct preflight activity to include

but not necessa rily limited to determine among other items, current and forecast weather conditions, wind, temperature, performance calculations for take

- off and landing, runway distances, power sou rce requirements, facilities at intended airports and/or areas of operation.14 C.F.R. 91.109: Flight instruction.

This regulation provides that no person may operate a civil aircraft (exce pt a manned

free balloon) that is being used for flight instruction unless that airc raft has fully functioning dual controls. By their design, UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished thro ugh the us e of an

electronic control that communicates with the aircraft via radio telemetry

communications. The FAA h as approved exemptions for flight training without fully

functional dual controls f or a number of aircraft and for flight instruction in e xperimental aircraft. See Exemption Nos. 5778K and 9862A. The equivalent level of safety provided by the fact that neither a pilot nor pa ssengers will be carried in the aircraft and by the size and speed of the aircraft. As such, the Ope rator requests reli ef from this regulation as described in this request for exemption and IAW its proposed order of operations.
14 CFR 91.111

- Operating near other aircraft. Operator specifically requests exemption from this regulation s o that the Operator may

conduct contr olled formation flight operations with multiple UAS and o r manned aircraft.

From time to time the Operator may utilize more than one UAS or manned ai rcraft designated as a chase or visual observer aircraft in effort to conduct its operations. The Operator will only conduct such operations within controlled airspace after having

received written approval from the local FSDO, local controlling airspace agency in which operations a re proposed to be conducted and if applicable the appropriate airport

manager or owner. The O perator will also publish NOTAM advisories a minimum of 24 hours prior to conducting operations within co ntrolled airspace or as requested by
FSDO.

14 C.F.R. 91.119: Minimum safe altitudes. This regulation establishes safe altitudes for operat ion of civil air craft. Section 91.119(d)

allows helicopters to be operated at less than the minimums prescribed, provi ded the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for UAS that are similar to helicopters, and

the exemption requests authority to operate at altitudes up to and including 400 AGL, an exemption may be needed to allow such operations. The UAS platform will not be operated higher tha n 400 AGL w ithout prior written authorization on a case

- by

- case basis from the local FSDO or ATC airspace controlling agency r esponsible for the

a irspace in which operations are proposed to be conducted. Additionally, the Operator will also publish NOTAM advisories a minimum of 24 hours prior to conducting operations within controlled airspace or as requested by FSDO. An equivale nt level of safety will be achieved given the size, weight, speed of the UAS platform as well as the

locations where they are operated. The l ow

- altitude operations of the UAS platform will ensure separation between the UAS operations and the operations of convent ional

manned aircraft that must comply with Section 91.119. 14 C.F.R. 91.121: Altimeter Settings. This regulation requires each person operating an aircraft t o maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the depa rture airport or an appropriate altimeter setting available before departure.” As the UAS pla tform may not

have a barometric altim eter, but instead a GPS altitude read out, an exemption may be required. An equivalent level of safety will be achieved by the operator, pursu ant to the
SOP and manufacturer instructions, the PIC shall confirm the altitude of the launch siteshown on the G PS altitude indicator before flight with topographical maps, sectional

charting or published airport elevation designations. 14 C.F.R. 91.151: Fuel Requirements for Flight in VFR Conditions. This regulation 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 leas t 30 minutes; or (2) At night, to fly after that

for at least 45 minutes.” Given the limitations on the proposed operations are as, a longer time frame for VFR conditions is reasonable. Applicant believes that an exempt ion 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 14 C.F.R. 91.151 (a)). Operating the

UAS platform in controlled operations does not engender the type of r isks that Section 91.151( a) was intended to alleviate given the size and speed of the UAS plat form. The UAS platform does not utilize fuel either liquid or solid format

. Similar exemptions have

be en granted to other operations, including Exemptions 2689F, 5745, 10673, and

10808. T he Operator proposes to terminate flight operations when indication form the UAS controller is received showing 20% battery life is remaining. 14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The FAA has previously dete rmined that no airworthiness cer tification is necessary for
UAS platforms. See, e.g., Exemption No. 11110. The Operator there fore believes that no exemption is necessary from 91.203. However, to the extent that the F AA finds that

section 91.203 is applicable to the Operator’s operations, the Operator r equests an exemption therefrom. The regulat ion provides in pertinent part: (a ) e xcept as provided in 14 CFR 91.715, no person may operate a civil aircraft unless it has within it the following: (1) A n appropriate and current a irworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certifi cate required by paragraph (a) of this section or a special flight authorizatio n issued under 14 CFR 91.715 is displayed at

t he cabin or cockpit entrance so that it is legible to passengers or crew. The UAS platform weighs no more than 55 pounds fully load ed, and are 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 poin t where the Operator will have immediate access to them, to the extent they are applicable to the
UAS. The FAA has issued numerous e xemptions to this regulation. A representative sample of other exceptions includes Exemptio n Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. Based on the limited size, weigh t, operating conditions, design safety features, and the imposed conditions and limitations, O perator has

determined that its operations would not adversely affect safety compared to si milar operations conducted with aircraft that have been issued an airworthiness certificate

u nder 14 CFR part 21, Subpart H. Therefore, as the FAA found for similar exemptions (See Exemption 11110), the Operator believes that the requested relief from 14 CFR Part 21, and 14 CFR 91.203 (a), (b) and any associated noise certification and testing requirements of part 36, should be granted. 14 CFR 91.209 Aircraft lights.This regulation states that no person may, during the period fr om sunset to sunrise

operate an aircraft unless it has lighted position lights. Additionally, no pers on may operate an aircraft that is equipped with an anti

- collision light system, unless it has lighted anti

- collision lights. However, the anti

- collision lights need not be operated when the pi lot

- in

- command determines that, because of operating conditions, it would be in the interest of safety to turn the lights off. The Operator specifically requests exemption from this regulation on a case

- by

- case basis , as approved by the local FSDO, in order to perform covert investigations in concert with a licensed private investigation agency a
United States law enf orceme nt agency and/or as directed by United States governmental directive. The Operator will not cond uct operations without prior written consent from the local FSDO or ATC airspace control ling agency responsible for the airspace in which operations are p roposed to be conducted. Addit ionally, the Operator

will also publish NOTAM advisories a minimum of 24 hours prior to conducting operations within controlled airspace or as requested by FSDO. An equivalent l evel of safety will be achieved given the size, w eight, speed of the UAS platform as well as the locations where they are operated. The low

- altitude operations of the UAS platform wil l ensure separation between the UAS operations and the operations of conventional

manned aircraft that must comply with Se ction 91.119 and 14 CFR 91.209. 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 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 a s prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircr aft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft

wit h an airworthiness certificate, these sections will not apply to the Operator.

Maintenance will be accomplished by the Operator pursuant to the manufacturer instructions. An equivalent level of safety wil l be achieved because the UAS are limited in size, carry a small payload, and will ope rate only in defined operations areas for limited periods of time. If mechanical issues arise the UAS platform can land immediately and will be operating from no greater than 4 00 feet AGL. As provided in the manufacturer instructions, the Operator will ensure that the U AS is in working order prior to initiating flight, perform required maintenance, and wil l keep a log of any

maintenance performed. Moreover, the Operator is the person most familiar wi th the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

SUMMARY OF PETITION Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, I plan on using the afore mentioned sUASs for capturing

data. I hereby respectfully request an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of the sUASs for aerial imaging for data capture, 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. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirementsfor the safe operation of such aircraft systems in the national airspace system.” Section

333(c) of the Reform Act.

Sincerely,

Perry Gilland