1

March 6,	2016

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

Re:				Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal Aviation	Regulations	from	14	C.F.R.45.23(b); 14	CFR	Part	21; 14	CFR 61.113(a)&(b);	91.7(a);	91.9(b)(2); 91.103(b);	91.109; 91.119;	91.121;	91.151(a); 91.203(a)	&	(b); 91.405	(a);	91.407(a)(1);	91.409(a)(2); 91.417(a)&(b).

Dear	Sir	or	Madam,
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform	Act”)	and	14	C.F.R.	Part	11,Tri

-State	Aerial	Solutions, (“Tri

-State	Aerial	Solutions”) Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to offer on-demand commercial UAS operations for a host of industries and applications and to perform the purposes listed below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C.	§44701(f)
As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous	structures,	and	working	adjacentto	treacherous	infrastructure. Approval	of	this exemption would thereby enhance safety and fulfill the Secretary ofTransportation’s (the FAA	Administrator’s)	responsibilities	to	“...	establish	requirements	for	the	safe	operation	of such	aircraft	systems	in	the	national	airspace	system.”	Section	333(c)	of	the	Reform	Act.2



### N**ame and address of** **applicant :**  Tri

-State	Aerial	Solutions Attn:	JasonT. Snyder (Private	Pilot) Email:jtsnyder85@gmail.com Address: 1236 12th Street,	Nitro,	WV		25143 

### Background

Tri

-State Aerial Solutions is under Jason T. Snyder’s direction. Jason T. Snyder is a private pilot (Private Pilot Certificate #2742561 issued 27DEC2002) and a highly accomplished,	capable,	experienced	andtrusted	professional.
Tri

-State Aerial Solutions is an aerial photography firm specializing in safe and efficientindustrial	inspection	applications

. Tri

-State Aerial Solutions employs professionals in the fields of photography, inspection and safety management. They have a combined 29 years of flight and safety management experience and are experienced with the systems, characteristics and safety features of the sUAV equipment they operate. Aerial photography has become an important element in their inspection process and safety management

. Tri

-State Aerial Solutions aimsto providethe highest qualityvisualswhile practicing safety measures such as pre-flight safety check lists, pre-flight site walkthroughs and tours, pre-flight photography shot list and planning, and adherence to the regulations and parameters set forth	by	the	FAA.


### Regulations from which the exemption is requested:

 14	CFR	Part	21  14	C.F.R.	45.23(b)  14	CFR	61.113	(a)	&	(b)  14	C.F.R.	91.7	(a)  14	CFR	91.9	(b)	(2)  14	C.F.R.	91.103  14	C.F.R.	91.109  14	C.F.	R.	91.119  14	C.F.R.	91.121  14	CFR	91.151	(a)  14	CFR	91.203	(a)	&	(b)  14	CFR	91.405	(a)  14	CFR	407	(a)	(1)  14	CFR	409	(a)	(2)  14	CFR	417	(a)	&	(b)3



### Introduction**:**
Tri

-State Aerial Solutions requests the agency issue a summary grant process for this application. Tri

-State Aerial Solutions has identified recently approved exemption numbers whereby the FAA has already granted a previous exemption similar to these requests forthe	following:  Commercialpurposes  Type	of	sUAVs	(UAS)  Title	14	Exemptions 

### Description of Type, Make and Models of sUAV/UAS Requested:

Tri

-State	Aerial	Solutionsis	seeking	an	exemption	to	commercially	operatesUAV’s makes	and	models	as	follows: Blade	Chroma; DJI Inspire	1; DJI		Phantom	3 EachsUAVweighs	55	lbs.	or	less,	with	payload. 

### Purposed Commercial Operation**:**

This exemption request, once granted would allow Tri

-State Aerial Solutions to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct structural inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use, public events, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, risk management	and	assessment,	mining,	disaster	and	catastrophe	events.4



### Public Benefit as a Whole**:**

Tri

-State Aerial Solutions proposes the use of its sUAV provided equivalent or augmented	levels	of	safety	for	each	of	the	uses	proposed	herein: The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys,wild life monitoring,
are now conducted by either a person climbing on the roofs and structures that are steep, tall,	slippery,	weakened	or	otherwise	hazardous	or	by	the	use	of	conventional	aircraft. The current procedures can result in significant injuries to the people who must climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude greater in	size than the sUAV. Either method, manual inspection or large conventional aircraft, results in increased	risk	of	injury dueto	personnel	falling	off	roofs	or	ladders,	carrying	heavy	ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly	more	expensive	than	those	undertaken	with	a	sUAV. The present system exposes those not only in the immediate area ofinspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site because the aircraft must be flown to and from the site. By contrast, the sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the sUAVs and emit pollutants associated with internal combustion engines. The sUAVs proposed herein are battery	powered	and	have	no	emissions. 

### Aircraft and Equivalent Level of Safety**to the Existing Rule :** 
Tri

-State Aerial Solutions proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These	limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Exemptions	11136,	11138,	11172,	11174	and	11177,	11062,	11109,	11112,	and	11213	and as	recent	as	11857. These limitations and conditions to which Tri

-State Aerial Solutions (referred to as “operator”) agrees to be bound when conducting commercial operations under an FAA issued exemption	include:5 1) Operations authorized by this grant of exemption are limited to the aircraft described in the Operator’s manual, which is a multi

-rotor weighing up to 55 pounds. Proposed operations of any other aircraft will	require	a	new	petition	or	a	petition	to	amend	this	grant. 2) The UA may not be flown at an indicated airspeed exceeding 30 mph (10	mph	during	inspections). 3) The UA must be operated at an altitude ofno more than 200 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s	manual.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL. 4) The UA must be operated within visual line of sight (VLOS) of the Aircraft Operator at all times. This requires the Aircraft Operator to be able to use human vision unaided by any device other than corrective lenses. 5) The Exemption Holder’s Manuals must be amended to include all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s	manual,	the	conditions	and	limitations	in	the	exemption	take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption	Holder	may	update	or	revise	its	Manuals.	It	is	the	Exemption Holder’s responsibilitytotrack such revisions and present updated and revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents ifit petitions for an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder	must	petition	for	amendment	to	its	exemption. 6) Prior to each flight, the Aircraft Operator must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, andthe	UAS	is	found	to	be	in	a	condition	for	safe	flight. The Ground Control	Station	must	be	included	in	the	preflight	inspection. All maintenance and alterations must be properly documented in the aircraft	records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight6 critical component, must undergo a functional test flight in accordance with the Exemption Holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption	Holder’s	Operator’s	manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components	that	may	not	be	addressed	in	the	manufacturer’s	manuals. 9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature ofthe authorized technician returning the	UAS	to	service. 10) The authorized technicians must receive and document training referenced	in	the	Exemption	Holder’s	Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer	System	and	Safety	Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action	taken	against	discrepancies	discovered	between	inspections. 13) Prior to commencing operations, the Aircraft Operator shall have logged	at	least	25	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	at	least ten hours logged as a UA pilotwith a similar UAtype and 5 hours inthe make	and	model. 14) If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled

access property and land or be recovered in accordance with the Exemption	Holder’s	Manuals. 15) The Aircraft Operator must abort the flight in the event ofunpredicted obstacles or emergencies, including unauthorized people entering the flight	area,	in	accordance	with	the	Exemption	Holder’s	Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough powerto	fly	to	the	first point	of	intended	landing	and,	assuming	normal cruising	speed,	to	fly	after	thatfor	at	least	10	minutes.7 17) All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14	CFR	part	45,	Subpart	C.	Markings	must	be	as	large	as	practicable. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight	agency	requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station ofthe UAS any time	the	aircraft	is	operating. These	documents	must	be	made	available to	the	Administrator	or	any	law	enforcement	official	upon	request. 20) The UA must remain clear and yield the right of way to all other manned operations and activities at alltimes (including, but not limited to, ultra

-light vehicles, parachute activities, parasailing activities, hang gliders,	etc.). 21) The UA may not be operated by the Aircraft Operator from any moving device	or	vehicle. 22) UAS operations may not be conducted during night, as defined in 14 CFR	1.1. 23) All operations must be conducted under visual meteorological conditions	(VMC).	The	UA	may	notbe	operated	less	than	500	feet	below or less than 2,000 feet horizontally from a cloud or when visibility is less	than	3	statute	miles	from	the	Operator. 24) During	operations	the	UA	may	not	operate	within	5	nautical	miles	of	the geographic center ofan airport as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required by the Operator’s COA. The letter of agreementwith the airport management must be made available to the Administrator	upon	request. 25) The	UA	may	not	be	operated	over	congested	or	densely	populated	areas unless	the	conditions	set	for	in	#26	are	satisfied. These	populated	areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119	(d)	(1).8 26) Flight operations must be conducted at least 500 feet from all nonparticipating	persons,	vessels,	vehicles,	and	structures	unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 30 feet	of	the	UA,	flight	operations	must	cease	immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of the risk of operating	closer	to	those	objects	and;

c. Operations near the Aircraft Operator do not present an undue hazard	to	the	Operator	per	§	91.119(a). 27) All operations shall be conducted over private or controlled

-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB	Web	site:www.ntsb.gov

. 

### Equivalent Level of Safety**: 14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and	Limitations;**  **Pilot	in	Command;**
Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Tri

-State Aerial Solution’s sUAV is remotely controlled with no passengers or property ofothers on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command	of	an	aircraft	for	compensation	or	hire.
Tri

-State Aerial Solution’s UAV respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Tri

-State Aerial Solution’s UAV has a high degree ofpre-programmed control andvarious built

-intechnical capabilities	that	strictly	limit	the	potential	for	operation	outside	of	the	operating	conditions set forth in the exemption application. Tri

-State Aerial Solution’s UAV has navigation and9

control system	comprised	of	a	Ground Control Station	(GCS)	and	auto

-pilot	system	that	can be pre-programmed to set operational boundaries. All flights are pre-programmed with precision GPS guidance. In the case of unplanned events, the operator may input preprogrammed evasive maneuvers fromthe control unit, andthe onboard autopilot executes those maneuvers. Pre

-programmed operator interventions include initiation ofholding at present position; suspension of mission; fly back to launch point; abort mission and land immediately;	and	emergency	power	cut	off	and	land	(Flight	Termination	System).
Additional automated safety functions and safety enhancing features ofthe Tri

-StateAerial Solution’ssUAVs may	include	the	following: 1.1. Auto

-pilot detection of lost GPS or of insufficient satellites initiates an immediate	landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.	Low	power	below	10%	triggers	an	immediate	landing. 1.3. Ifthe auto
-pilot detects a lost

-link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute	a	return	to	home	and	land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un-commanded deviation from the flight	path. 1.5.	The	aircraft,	weighs	less	than	55	lbs.,fully	loaded. 1.6.	The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging)	nor	above	200	feet	above	AGL

. In addition to these safety features, operators of the Tri

-State Aerial Solution’s sUAV are required	to	hold	a	private	pilot	certification.
The risks associated with the operation of the Tri

-State Aerial Solution’s sUAV (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with conventional aircraft operations contemplated by Part 61 with conventional	aircraft	(fixed	wing	or	rotorcraft),	that	allowing	operations	of	the	UAS	as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a)	&	(b). 

### 14 C.F.R. § 91.7(a): Civil aircr**aft airworthiness.**
This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the	UAS	without	an	airworthiness	certificate,	no	standard	will exist	for	airworthiness	of	the UA. Giventhe size ofthe aircraft andthe requirementsthatthe operator has agreedto as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080	and	11110.10



### 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 route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 200AGL, an exemption may	be	needed	to	allow	such	operations.
The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flightwill be taken without the permission ofthe property owner, facility owner, and/or local officials. Because ofthe advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operations

. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated	with	these	operations	is	far	less	than	those	presently	presented	by	conventional aircraft operating at orbelow 500AGL in the aerial photography industry. In addition, the low

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

-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062	through	11067,	11080	and	11110.



### 14 C.F.R. §**91.121 Altimeter Settings**
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure.” As the Tri

-State Aerial Solution’s sUAV, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The operator will achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar operations	in	Exemptions	11062	through	11067,	11080	and	11110.


### 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.”11

Tri

-State Aerial Solutions believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation	to	operatewithout compliance	with	FAR 91.151 (a)). Operating	the	small	UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate	given	the	size	and	speed	of	the	small	UAS.
Tri

-State Aerial Solutions believes that an equivalent level ofsafety can be achieved by limiting flights to 15 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions	11062,	through11067,	11080	and	11110.


### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(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	as	prescribed	in	part	43	ofthis	chapter...,”	and	others	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 Tri

-State Aerial Solutions

. Maintenance will be accomplished	by	the	operator or manufacturer pursuant	to	the	flight	manual	and	operating handbook as referenced in the Manuals attached as an equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and	operate	only	in	defined	areas	for	limited	periods	of	time. If	mechanical	issues	arise,	the UAS can land immediately and will be operating from no higher than 200 feet AGL. As provided in the Aircraf

t Flight Operations Manual the operator will ensure that the UAS is inworking order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Additionally, the operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations	in	Exemptions	11062	through	11067,	11080	and	11110.12



## Federal Regis**ter Publication :** 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal	Register,	should	it	be	determined	that	publication	is	needed:
Tri

-State	Aerial	Solutions seeks	an	exemption	from	the	following	rules: 14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision	agriculture	with	on	board	sensors,	wildlife	and	forestry	monitoring	and	mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operationswithin the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment,	motion	picture	production,	surface	mining,	closed	set	filming,	disaster	and catastrophe	events.


## Summary**:** Approval of exemptions allowing commercial operations of sUAVs for Tri

-State Aerial Solutions to operate an unmanned aircraft system (UAS) to conduct structural inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support oflocal authority officials, aerial video and photography for public and private use, public events, training to persons individually or belonging to both private and public organizations to increase awareness and improve13

safety for current and future UAS operations within the NAS, risk management and assessment,	mining,	disaster	and	catastrophe	events.
Conventional operations, using jet or piston powered aircraft, ladders or placing people on roofs or tall, hazardous or weakened structures, exposes them to higher risks than those created by use ofa sUAVs. Conventional aircraft that operate at extremely low altitudesjust feet fromthe subjectbeing inspected and in extreme proximityto people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts ofjetA or other fuel (140 gallons forjet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the	risks	associated	with	manned	aircraft	flights.
The operation of small UASs, weighing less than 55 lbs., conducted under the strict conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of the exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional operations conducted with helicopters operating	in	close	proximity	to	the	ground	and people	or	the	use	of	individuals	to	climbthe structures	to	conduct	the	operations.
Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012

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

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Tri

-State Aerial Solution’s UAS for the purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11171 through 11174, 11176, 11177,	11062,	11109,	11112,and	11213	and	as	recent	as	15151

.

Sincerely, Jason T. Snyder (Private	Pilot	Certificate	#2742561	issued	27DEC2002) Tri

-State	Aerial	Solutions 1236 12th Street Nitro,	WV 25143