September 25

, 2015

Exemption No. 13023 Regulatory Docket No. FAA

− 20 15

− 2882

Mr. Thomas E. Dolan Founder & Operations Officer

Above It All

– UAS Services, LLC 30 Industrial Drive, Suite 1B Louisa, VA 23093

Dear Mr. Dolan :

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

By letter dated June 9, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Above It All

– UAS Services, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct precision aerial surveys that consist of still, video images and corresponding data taken by onboard cameras and/or sensors

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom, DJI Phant om 2 Vision +, and the

DJI S

- 1000

.2

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

— Airworthiness Certificates

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

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

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

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

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

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

− 2014

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

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

—

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

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by th e Administrator, Above It All

– UAS Services, LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

aerial data collection

. This exemption is subject to the conditions and limitations listed

below.

Conditions and Limitations

In this grant of exemption, Above It All

– UAS Services, LLC is hereafter referred to as

the operator.

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

1. Operations authorized by this grant of exemption are limited to the DJI Phantom, DJI Phantom 2 Vision +, and the DJI S

- 1000 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a pet ition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

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

aircraft manufacturer.

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

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

- issued airman medical certificate or

U.S. driver’s license.

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

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

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of4

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations an d made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised

d ocuments to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revis ions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting fur ther operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

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

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

- flight inspection and determine the

UAS is in a condition f

or safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from op erating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircr aft and

aircraft components.

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

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a
state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal5

government. The PIC must also meet the fligh t revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consis tent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a ma nner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

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

traini ng, proficiency, and experience

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

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

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the cur rent FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or other wise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

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

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

pre

- determined location within the pr ivate or controlled

- access pro perty.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the

i ntended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

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

- issued COA. The6

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

.

22. All aircraft operated in accordance with this exemption must be i dentified 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Adminis trator or any law enforcement official upon request.

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

activities at all times.

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

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

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensurin g the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

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

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

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

28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be7

reported to the National Transportation Safety Board (NTS B) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

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

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

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

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the f ollowing:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

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

- scene operation of the UAS;

d. Make, model, and ser ial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list o f those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

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

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

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

This exemption termin ates on October 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresREGARDING THE FAA 333 EXEMPTION PETITION REQUEST FR OM: Above It All – UAS Services, LLC

1 United States Department of Transportation Docket Management System West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

REGARDING THE PETITION FROM:

Above It All – UAS Services, LLC,

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS (14 CFR ) PART 21 SECTIONS 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409( a)(2), and 91.417(a) and (b).

CONCERNING OPERATION OF SMALL UNMANNED AIRCRAFT SYS TEMS (SUAS)

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Regulatory Docket Number _______________ Submitted Electronically June 9, 2015

Above It All – UAS Services, LLC

Thomas E. Dolan

Founder & Operations Officer

30 Industrial Drive, Suite 1B Louisa, Virginia 23093REGARDING THE FAA 333 EXEMPTION PETITION REQUEST FR OM: Above It All – UAS Services, LLC

2 June 9, 2015

United States Department of Transportation Docket Management System West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 and 14 CFR Part 11, Above It All – UAS Services, LLC the Appl icant of the DJI Phantom (PHANTOM), DJI Phantom 2 Vision + (PHANTOM 2) and D JI S-1000 (“S-1000”) Small Unmanned Aircraft Systems (“SUAS”) , seeks a n exemption from the Federal Aviation Regulations (“FARs”) discussed later in th is petition.

The requested exemption would allow commercial oper ation of Applicants PHANTOM, PHANTOM 2 and S-1000 SUAS’ of which all weigh under 25 lbs. (based on variable installed sensors) to perform precision aerial surv eys that consist of still, video images and corresponding data taken by onboard cameras and /or sensors. The PHANTOM, PHANTOM 2 and S-1000 SUAS’ takes a series of high q uality, still digital images, video images and or other data that are used to provide i nspection data for evaluation by a client. Applications for these SUAS devices and ass ociated data processing functions include inspection of; agriculture; building; trave l & power utility infrastructure; professional surveying; real estate; law enforcemen t; Electronic News Gathering (ENG); television; movie filming; radiological & consequen ce management and scientific research & development.

Use of the PHANTOM, PHANTOM 2 and S-1000 SUAS’ for the aerial missions aforementioned reduces the need to operate conventi onal airplanes or helicopters for the same purpose thus reducing risk to personnel and pr operty on the ground. High quality imagery/data can be provided at a fraction of the c ost of using conventional manned aircraft. The benefits from these savings will be e nhanced efficiency, productivity for the affected activities, as well as reduction in harmfu l environmental emissions and safety risks. Operations under the exemption will be subje ct to strict operating requirements and conditions to ensure at least an equivalent level o f safety to currently authorized operations using manned aircraft and under conditio ns as may be modified by the FAA as required by Section 333.REGARDING THE FAA 333 EXEMPTION PETITION REQUEST FR OM: Above It All – UAS Services, LLC

3 The PHANTOM, PHANTOM 2 and S-1000 SUAS’ will be ope rated under controlled conditions at low altitude in airspace that is limi ted in scope, as described more fully herein; it will have automated control features, as described below. The PHANTOM, PHANTOM 2 and S-1000 SUAS’ also will be operated an d observed by a individuals who posses an FAA commercial or private pilots lice nse that already understand the rigorous requirements of flying manned airplanes an d/or rotorcrafts in the National Airspace System (NAS). Any required manufacturer’s training, certification and/or exam programs for the SUAS if any will also be obtained by the applicant’s SUAS team

members.

Finally, the airspace in which the SUAS’ will opera te will be below 400 feet above ground level, over privately owned, owner authorize d land. Applicant respectfully submits that because these small, unmanned aerial v ehicles, the PHANTOM, PHANTOM 2 and S-1000 SUAS’, will be used in lieu of comparatively hazardous operations now conducted with fixed wing, and rotar y conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. Approval of this exemption would t hereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrato r’s) responsibilities under Section 333(c) of the Reform Act to establish requirements for the safe operation of such aircraft systems in the NAS.

Thomas E. Dolan

Founder & Operations Officer Above It All – UAS Services, LLC

30 Industrial Drive, Suite 1B Louisa, Virginia 23093

Cell Phone: 631-495-2947

Office: 434-374-1866

Email: Tom.Dolan@aboveitall-uas-services.com or thomasedolan@gmail.comi revised 6/9/2015 TABLE OF CONTENTS Page

I GLOSSARY OF ABBREVIATIONS & TERMS 1

II LIST OF ATTACHMENTS 1

III PETITIONERS CONTACT INFORMATION 2

IV REGULATIONS FROM WHICH EXEMTION IS REQUESTED 2

V THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 2

VI DESCRIPTION OF PROPOSED OPERATIONS & SUAS’ 3

VII REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 8

A. Airworthiness Certificates 8

B. Airworthiness Standards: Normal Category Rotorcraft 9

C. Aircraft Marking and Identification Requirements 9

D. Civil Aircraft Flight Manual in the Aircraft 10

E. Civil Aircraft Airworthiness 11

F. Preflight Action 11

G. Flight Instruction 11

H. Minimum Safe Altitudes 12

I. Altimeter Settings 13

J. Fuel Requirements for Flight in VFR Conditions 13

K. Carrying Civil Aircraft Certification and Registrat ion 14

L. Maintenance Inspections 15

VIII PUBLIC INTEREST 15

IX PRIVACY 16

X FEDERAL REGISTAR SUMMARY 17

XI BIOGRAPHICAL BACKGROUND TEAM OF PETITIONERS 18

XII CONCLUSION 25Above It All –UAS Services, LLC - FAA 333 Exemption Request

1 Revised 6/9/2015 I GLOSSARY OF ABBREVIATIONS & TERMS

AGL Above Ground Level CFR Code of Federal Regulation

COA Certificate of Authorization

FAA Federal Aviation Administration FAR Federal Aviation Regulation

GCS Ground Control Station NAS National Airspace System

NOT AM Notice to Airman

PIC Pilot in Command

PO Pilot Observer

Reform Act FAA Modernization and Reform Act of 201 2 SUAS Small Unmanned Aircraft Systems

UA Unmanned Aircraft UAS Unmanned Aircraft System VLOS Visual Line of Sight VFR Visual Flight Rules Class E Airspace Controlled airspace around some ai rports from surface that

extends to 700 or 1,200 feet AGL Class G Airspace Class G is completely uncontrolled airspace from surface to

below 60,000 feet

II LIST OF ATTACHMENTS

The following attachments are referenced in the req uest for exemption which follows. These documents provide additional evidence in supp ort of Petitioner’s petition to the

FAA.

Attachment A PHANTOM Operations Procedures Manual Attachment B PHANTOM 2 VISION + Operations Proced ures Manual Attachment C PHANTOM Pilot Training Manual Attachment D S 1000 Operations Procedures Manual

Attachment E PILOT OPERATION & SAFETY GUIDELINES

III PETITIONERS CONTACT INFORMATION

Petitioner: Above It All – UAS Services, LLC

Phone: 631-495-2947

Email: Tom.Dolan@aboveitall-uas-services.com or Thomasedolan@gmail.com Address: 30 Industrial Drive, Suite 1B Louisa, Virginia 23093Above It All –UAS Services, LLC - FAA 333 Exemption Request

2 Revised 6/9/2015 IV REGULATIONS FROM WHICH EXEMTION IS REQUESTED

14 CFR Part 21, Subpart H Airworthiness Certificate s & 14 CFR §

14 CFR Part 27: Airworthiness Standards: Normal Cat egory Rotorcraft.

14 CFR § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification R equirements 14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. 14 CFR § 91.7(a): Civil Aircraft Airworthiness. 14 CFR § 91.103(b): Preflight Action. 14 CFR § 91.109(a): Flight Instruction. 14 CFR § 91.119: Minimum Safe Altitudes. 14 CFR § 91.121: Altimeter Settings. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification & Registration 14 CFR § 91.405(a); 14 CFR § 91.407(a) (1); 14 CFR § 91.409(a) (2); 14 CFR § 91.417 (a) & (b): Maintenance Inspections

V THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Developer submits that grant of this exemption appl ication for use of the PHANTOM, PHANTOM 2 VISION + and S-1000 SUAS’ in a wide-range of various low level aerial missions & applications that will advance the Congr essional mandate in Section 333 of the

Reform Act to accelerate the introduction of UAS’s into the NAS if it can be accomplished safely. This law directs the Secretary of Transport ation to consider whether certain UAS’s may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination , the Secretary is required to determine which types of UAS’s do not create a hazard to user s of the NAS or the public or pose a threat to national security in light of the followi ng:

• The UAS’s size, weight, speed, and operational ca pability;

• Operation of the UAS in close proximity to airpor ts and populated areas; and

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

Reform Act § 333(a) (1) If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shal l establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c)

Petitioner submits that this provision places a dut y on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the UAS. Devel oper welcomes the opportunity to consult with FAA staff in order to address any issu es or concerns that this proposal may raise that they believe may require modification.Above It All –UAS Services, LLC - FAA 333 Exemption Request

3 Revised 6/9/2015 The Federal Aviation Act expressly grants the FAA t he authority to issue exemptions. This statutory authority, by its terms, includes exempti ng civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations req uiring commercial pilots to operate

aircraft in commercial service:

The Administrator may grant an exemption from a req uirement of a regulation prescribed under subsection (a) or (b) of this sect ion or any of sections 4-44702-

44716 of this title if the Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 U SC §44704; 14 CFR §91.203(a) (1)

The grant of the requested exemption is in the publ ic interest based on the clear direction in Section 333 of the Reform Act; the additional autho rity in the Federal Aviation Act, as amended; the strong equivalent level of safety surr ounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAS’s for aerial applications and use of its associated data processing functions to include inspection of; agriculture; bu ilding; travel & power utility infrastructure, professional surveying, real estate , law enforcement, Electronic News Gathering (ENG), television, movie filming, radiolo gical & consequence management and scientific research & development. Accordingly, the Petitioner respectfully requests that the FAA grant the requested exemption upon review o f request.

VI DESCRIPTION OF PROPOSED OPERATIONS & SUAS’

The current PHANTOM, PHANTOM 2 VISION + and S-1000 SUAS’ Manual describes, in detail, the policies and procedures for Petition ers proposed SUAS operations. To assist the FAA in its safety assessment of Petitioners pro posed SUAS operations, below is a summary of operational limitations and conditions w hich will ensure an equivalent or higher level of safety to operations conducted unde r current regulatory guidelines:

1. The SUAS’ will weigh less than 25 lbs. depending on sensor requirements.

2. Flights will be operated within line-of-sight of th e trained PIC and PO.

3. Flights will be terminated at 25% power reserve.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of the SUAS PIC and PO.

6. The SUAS PIC and PO will both be FAA licensed comme rcial or private pilot.Above It All –UAS Services, LLC - FAA 333 Exemption Request

4 Revised 6/9/2015 7. The SUAS pilot will be PIC. The PIC and PO, both be ing FAA pilot certificate holders have the ability to and may take over each others role for safety or any other reason due to both having the same and necessary PI C/PO qualifications & training, which adds to the overall safety of flight operatio ns.

8. The SUAS will only operate within a limited pre-det ermined area.

9. The SUAS onboard computer stabilization controller provides the PIC the ability to

hover the SUAS and move in vertical and horizontal planes independently and simultaneously that affords the PIC to alter predet ermined flight path if any safety issue in flight path arises.

10. The SUAS onboard telemetry affords the PIC to monit or in real time all pertinent SUAS airborne altitude, battery life, GPS system he alth data and parameters on laptop or tablet.

11. If the SUAS loses communications or GPS signal the SUAS will automatically return to its pre-determined safe launching/landing site through its advanced onboard safety feature.

12. A mandatory preflight safety briefing for all SUAS team personnel will be conducted prior to each day's planned SUAS flight m issions.

13. PIC and PO will have the most current training in t he SUAS to be operated along with any pertinent information from the manufacture r, as required in the Manual.

14. PO and PIC will at all times be able to communicate by voice, visual signal, audible signal and/or text.

15. Permission, Written or oral, will be obtained from the necessary property owners or managers prior to any aerial activity.

16. Any and all required permissions and/or permits wil l be obtained from the appropriate state, county, city or jurisdiction age ncies prior to any aerial activity.

17. Petitioner will submit a Certificate of Authorizati on (COA) application for each SUAS as part of the exemption sought by this Petiti onAbove It All –UAS Services, LLC - FAA 333 Exemption Request

5 Revised 6/9/2015 Below is an overview of the Petitioners PHANTOM spe cifications. Additional operational information is available in the PHANTOM Operations Procedures Manual (Attachment A).

Operating Temperature

- 10°C ~ 50°C

Take

- off Weight <1000g

Hovering Accuracy Vertical : ± 0.8m ; Horizontal : ± 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 45°

Max Ascent / Descent Speed ±6m/s

Max Flight Velocity 10m/s

Diagonal distance (motor center to center) 350mm

Working Current /Voltage 52 mA@6VAbove It All –UAS Services, LLC - FAA 333 Exemption Request

6 Revised 6/9/2015 Below is an overview of the Petitioners PHANTOM 2 V ISION + specifications. Additional operational information is available in the PHANTOM 2 VISION + Operations Procedures Manual (Attachment B).

PHANTOM 2 Vision + +

Battery 5200mAh LiPo

PHANTOM 2 VISION + + Weight 1160g

Hover Accuracy (Ready to Fly) Vertical:± 0.8m;Horizontal:± 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed 6m/s

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Tilting Range of Gimbal 0°-60°Above It All –UAS Services, LLC - FAA 333 Exemption Request

7 Revised 6/9/2015 Below is an overview of the Petitioners S-1000 SUAS specifications. Additional operational information is available in the S-1000 Operations Procedures Manual (Attachment D).



### Frame Diagonal Wheelbase: 1045mm
Frame Arm Length: 386mm
Frame Arm Weight: (Including Motor, ESC, Propeller) 325g

Center Frame Diameter: 337.5mm
Center Frame Weight (With Landing Gear Mounting Base, Servo s)

1330g Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)



### Motor Stator Size: 41×14mm

KV: 400rpm/V

Max Power: 400W Weight (With Cooling Fan): 158g



### ESC Working Current: 40A
Working Voltage: 6S LiPo
Signal Frequency: 30Hz ~ 450Hz
Drive PWM Frequency: 8KHz Weight (With Radiators): 35g



### Foldable Propeller

(1552/1552R) Material: High strength performance engineered plastics

Size: 15×5.2inch Weight: 13g



### Flight Parameters Takeoff Weight: 6.0Kg ~ 11.0Kg
Total Weight: 4.2Kg
Power Battery: LiPo (6S

、 10000mAh~20000mAh

、 15C (Min))
Max Power Consumption: 4000W
Hover Power Consumption : 1400W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@14000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature: -10 °C ~ +40 °CAbove It All –UAS Services, LLC - FAA 333 Exemption Request

8 Revised 6/9/2015 VII REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA t he authority to issue exemptions. By its terms, this statutory authority includes exe mpting 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 requeste d exemption is in the public interest.

Petitioner seeks an exemption from several interrel ated provisions of 14 CFR Parts 21, 45 and 91 for purposes of conducting wide-range of various low level aerial missions & applications with associated data processing functi ons to include inspection of; agriculture; building; travel & power utility infrastructure; pr ofessional surveying; real estate; law enforcement; Electronic News Gathering (ENG); telev ision; movie filming; radiological & consequence management and scientific research & de velopment using SUAS which are

listed below are:

(1) the specific sections of 14 CFR for which exemp tion is sought; and (2) the operating procedures and safeguards that Pe titioner has established which will ensure a level of safety equal to or better th an the rules from which exemption is sought.

A. 14 CFR Part 21, Subpart H Airworthiness Certific ates & 14 CFR § 91.203(a) (1).

This petition seeks an exemption from 14 CFR Part 2 1, Subpart H, which establishes the procedural requirements for the issuance of airwort hiness certificates as required by 14 CFR §91.203(a)(1). Given the size and limited opera ting area associated with the SUAS to be utilized by the Petitioner, an exemption from Pa rt 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C. § 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requi rement for an airworthiness certificate, upon consideration of the size, weight, speed, oper ational capability, and proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonst rates that the SUAS operated without an airworthiness certificate, in the restricted enviro nment and under the conditions proposed will be at least as safe, or safer, than a conventi onal rotorcraft operating with an

airworthiness certificate without the restrictions and conditions of the proposed SUAS operations.

Equivalent Level of Safety

The SUAS to be operated hereunder is less than 25 l bs. fully loaded, carries no pilot, No passenger, no explosive materials, and operates exclusively within a secured predetermined area. Unlike other civil aircraft, the p roposed operations in this petition for exemption will be controlled and monitored by the P etitioner with advance notice to the FAA of all operations that will be conducted under this exemption.Above It All –UAS Services, LLC - FAA 333 Exemption Request

9 Revised 6/9/2015 These safety enhancements, which already apply to c ivil aircraft operated in connection with existing inspection operations, provide a grea ter degree of safety to the public and property owners than conventional operations conduc ted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, app lication of these same criteria

demonstrates that there is no credible threat to na tional security posed by the SUAS, due to its size, speed of operation, location of operation , lack of explosive materials, and inability to carry a substantial external load.

B. 14 CFR Part 27: Airworthiness Standards: Normal Category Rotorcraft.

14 CFR Part 27 sets forth the procedural requiremen ts for airworthiness certification of normal category rotorcraft. To the extent the Petit ioner's SUASs would otherwise require certification under Part 27, as a rotorcraft, Petit ioner requests an exemption from Part 27’s

airworthiness standards for the same reasons identi fied in the exemption request from 14 CFR Part 21, Subpart H.

C. Aircraft Marking and Identification Requirements : 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a).

This petition seeks an exemption from the aircraft marking and identification requirements of 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a).

14 CFR § 91.9(c), Civil aircraft flight manual, mar king, and placard requirements, provides that:

No person may operate a U.S.-registered civil aircr aft unless that aircraft is identified in accordance with part 45 of this chapter.

14 CFR § 45.23(b), Markings of the Aircraft, states :

When marks include only the Roman capital letter "N " and the registration number is displayed on limited, restricted or light-sport cat egory aircraft or experimental or provisionally certificated aircraft, the operator m ust also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, i n letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," " light-sport," "experimental," or "provisional," as applicable

14 CFR § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks requir ed by §45.23.

Exemption from § 45.23(b) is warranted because the SUAS has no entrance to the cabin,Above It All –UAS Services, LLC - FAA 333 Exemption Request

10 Revised 6/9/2015 cockpit or pilot station, on which the word "Experi mental" can be placed. Moreover, given the size of the SUAS, two-inch lettering would be i mpossible. The word "Experimental" will be placed on the fuselage in compliance with § 45.29(f).

Given the nature of the specific relief sought by t his exemption request, Petitioner requires relief from the associated marking and identificati on requirements of § 45.27(a) and § 91.9(c), which would require compliance with § 45.2 3(b).

Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and identification requirements of §§ 91.9(c), 45.23(b) and 45.27(a), will be provided by having the SUAS marked on its fuselage as required by §45.29(f) whe re the PIC, PO, and others working

with the SUAS will see the identification of the UA S as "Experimental." Additionally, Petitioner will ensure compliance with any requests of SUAS marking by the FAA.

The FAA has issued the following exemptions to the aircraft marking requirements of § 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10 167A.

D. 14 CFR § 91.9(b) (2): Civil Aircraft Flight Manu al in the Aircraft.

This petition seeks an exemption from the flight ma nual requirements of 14 CFR § 91.9(b) (2), which states:

(b) No person may operate a U.S.-registered civil a ircraft

(2) For which an Airplane or Rotorcraft Flight Manu al is not required by §21.5 of this chapter, unless there is available in the airc raft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Given its size, configuration, and load capacity, t he SUAS has no ability to carry such a manual on the craft. There is no need to carry this item on the SUAS, since there is no pilot on board, no room, no capacity or need.

Equivalent Level of Safety

The safety related purpose of this manual requireme nt can be equally satisfied by having the SUAS flight manual at the ground control point where the pilot flying the SUAS will have immediate access to it. Accordingly, Peti tioner requests an exemption from § 91.9(b) (2)'s flight manual requirements, on the co ndition that the SUAS flight manual be available at the control point during each operatio n.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A , 10602, 32827, and 10700Above It All –UAS Services, LLC - FAA 333 Exemption Request

11 Revised 6/9/2015 E. 14 CFR § 91.7(a): Civil Aircraft Airworthiness.

This petition seeks an exemption from 14 CFR § 91.7 (a), which requires that a civil aircraft be in an airworthy condition to be operated. Since there is currently no airworthiness certificate issued for the SUAS, no FAA regulatory standard will exist for determining

airworthiness.

Equivalent Level of Safety

Petitioner PICs have hundreds flight hours in SUAS flying operations with an excellent safety record. Furthermore, given the size of the S UAS and the requirements contained in the Manual for maintenance and use of safety checkl ists prior to each flight, an equivalent level of safety will be provided.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A , 10602, 32827, and 10700

F. 14 CFR § 91.103(b): Preflight Action

This petition seeks an exemption from m § 91.103, w hich requires a PIC to become familiar with specific information before each flig ht, including information contained in the FAA approved Flight Manual on board the aircraft. Inasmuch as an FAA approved flight manual will not be provided for the SUAS, an exempt ion will be needed.

Equivalent Level of Safety

An equivalent level of safety will be provided by f ollowing the SUAS Operations Manual comprehensive preflight checklist. The PIC will att ain all information and actions, including reviewing weather, flight battery require ments, landing and takeoff distances, and aircraft performance data, a briefing to the PO alo ng with all others involved in the aerial activities before beginning any flight operation.

G. 14 CFR § 91.109(a): Flight Instruction.

This petition seeks an exemption from 14 CFR § 91.1 09(a), which provides that “no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully function ing dual controls.” SUAS’ and remotely piloted aircraft, by their design do not have fully functional dual pilot controls. Instead, flight control is accomplished through the use of a control box or ground station that communicates with the SUAS via radio frequency comm unications.Above It All –UAS Services, LLC - FAA 333 Exemption Request

12 Revised 6/9/2015 Equivalent Level of Safety

Given the size and speed of the SUAS, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the SUAS, and all persons will be a safe distance away should the SUAS experience any difficulties during flight instruction.

The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption

Nos. 5778K & 9862A.

H. 14 CFR § 91.119: Minimum Safe Altitudes.

This petition seeks an exemption from the minimum s afe altitude requirements of 14 CFR § 91.119. Section 91.119 prescribes the minimum saf e altitudes under which aircraft may not operate, including 400 feet above the surface a nd away from any person, vessel, vehicle, or structure in non-congested areas. See 1 4 CFR § 91.119(c). Section § 91.119(d) (1) allows for a helicopter to 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 o r altitudes specifically prescribed for helicopters by the FAA

To provide the intended inspections, the SUAS will normally need to be operated within a range of approximately 100 feet from the structure or item to be inspected. Accordingly, due to the nature of the proposed operations, the P IC and the PO may at times be less than 400 feet away from structures during the operation, and an exemption is therefore required.

Equivalent Level of Safety

An equivalent level of safety will be achieved give n the size, weight, speed of the UAS as well as the location where it is operated. Operatio ns with rotorcraft weighting far more than the maximum 25 lbs. proposed SUAS, along with the l ack of flammable fuel, any risk associated with these operations are far less than those of conventional aircraft. As set forth in the Manual, the SUAS will be operated in a posit ively controlled area, where buildings and people will not be exposed to operations withou t their authorized consent. No flight will be taken without the permission of the propert y owner or manager and/or local officials. Because of the advance notice to the pro perty owner and participants, all affected individuals will be aware of the planned flight ope rations as set forth in the Manual. Furthermore, by operating at such lower altitudes, the SUAS will not interfere with other aircraft that are subject to the minimum safe altit ude regulations.Above It All –UAS Services, LLC - FAA 333 Exemption Request

13 Revised 6/9/2015 I. 14 CFR § 91.121 Altimeter Settings

This petition seeks an exemption from 14 CFR § 91.1 21, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airpo rt or barometric pressure. An exemption is required because the SUAS does not have a barometri c altimeter, but rather a GPS altitude

read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by f ollowing the procedures set forth in the PHANTOM, PHANTOM 2 VISION + and S-1000 SUAS’ Manual . As prescribed in the Manual, the operator will confirm the altitude of t he launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the SUAS’s height, thus ensuring operation at safe altitudes.

J. 14 CFR § 91.151(a): Fuel Requirements for Flight in V FR Conditions

This petition seeks an exemption from 14 CFR § 91.1 51(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane und er VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming norma l 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 min utes.

The battery supplying electric powering source for the SUAS provides approximately 20 to 30 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 CFR §91.151 is therefore required.

Equivalent Level of Safety

An equivalent level of safety can be achieved by li miting flights to 25% of battery power, whichever happens first. This restriction would be more than adequate to return the SUAS to its planned landing zone from anywhere within it s limited operating area. Operation of

the SUAS 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 t he size and speed of the small UAS. Additionally, we are not planning or proposing to f ly SUAS at night.

Operation of SUAS will be limited to predetermined and controlled areas where only people and property owners, or official representat ives who have signed waivers will be

allowed.Above It All –UAS Services, LLC - FAA 333 Exemption Request

14 Revised 6/9/2015 This request for exemption falls within the scope o f prior exemptions. See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to oper ate without compliance with § 91.151 (a)); see also Exemptions 2689F, 5745, 10673 , and 10808.

K. 14 CFR § 91.203 (a) & (b): Carrying Civil Aircra ft Certification and Registration

This petition seeks an exemption from civil aircraf t certification and registration requirements of 14 CFR § 91.203 (a) and (b). The re gulation provides in pertinent part:

(a) Except as provided in §91.715, no person may op erate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certif icate

(b) No person may operate a civil aircraft unless t he airworthiness certificate required by paragraph (a) of this section or a spec ial flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to the passengers or crew.

Petitioner is seeking an exemption from the airwort hiness certificate requirements, an exemption to this regulation is necessary because:

1 No such certificate is available to be issued for a irworthiness of a SUAS:

2 SUAS load capacity and size does not allow it to ca rry certification and registration documents and it is impractical to display such doc umentation on the SUAS;

3 SUAS does not have a cabin or cockpit entrance at w hich the documents could be displayed; and

4 There are no passengers or crew for whom the certif icates need be displayed.

Equivalent Level of Safety

To the extent these regulations are applicable to t he proposed SUAS operations, an equivalent level of safety will be achieved by keep ing these documents at the ground control point or station where the pilot flying the SUAS will have immediate access to

them.

The FAA has issued numerous exemptions to this regu lation. A representative sample of other exceptions which includes Exemption Nos. 9565 , 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700Above It All –UAS Services, LLC - FAA 333 Exemption Request

15 Revised 6/9/2015 L. 14 CFR §§ 91.405(a); 91.407(a) (1); 91.409(a) (2 ); 91.417 (a) & (b): Maintenance Inspections

Petitioner seeks an exemption from the maintenance inspection requirements of 14 CFR §§ 91.405(a); 91.407(a) (1); 91.409(a) (2); 91. 417 (a) & (b). These regulations specify maintenance and inspection standards in reference t o 14 CFR Part 43. See, e.g., 14 CFR § 91.405(a) (stating that each owner or operator of a n aircraft “shall have that aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections . . . have discrepancies repaired as prescribed in part 4 3 of this chapter”). An exemption of these regulations is needed because Part 43 and the se sections apply only to aircraft with an airworthiness certificate, as such the SUAS does no t have or is required to have at this

time.

Equivalent Level of Safety

An equivalent level of safety will be achieved sinc e maintenance and inspections will be performed in accordance with the PHANTOM, PHANTO M 2 VISION + and S-1000 SUAS’ Manuals. As provided in the Manual, the PIC w ill ensure that the SUAS is in proper working order prior to initiating flight, pe rform routine or required maintenance, and maintain a log of any maintenance performed. Th e PIC is the most familiar with the

craft and best suited to maintain the SUAS in an ai rworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the SUAS can land immed iately no higher than 400 feet AGL at the most. The SUAS’ small size, carrying capacity, and the fact that flight operations will only take place in restricted areas for periods of time not to exceed 25 minutes or until 25% battery power remains, create less risk than the sa me factors associated with conventional fixed-wing airplane and rotorcraft performing the s ame operation.

VIII PUBLIC INTEREST

Consistent with the requirements of 14 CFR §11.81(d ), Petitioner offers the following reasons why granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole.

Approval of exemptions allowing commercial operatio ns of small and lightweight SUAS’ in aerial services industry benefits the public as a whole in the following ways:

• It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, the FAA Administrator's assessment of whether certain UAS may operate safely in the National Airspace System befo re completion of the rulemaking required under Section 332 of the Reform Act.

• The operation significantly improves safety and red uces risk by alleviating human exposure to danger associated with current aerial m ission methods, namely, full size helicopters. Manned helicopters performing various low level inspections andAbove It All –UAS Services, LLC - FAA 333 Exemption Request

16 Revised 6/9/2015 patrols have experienced an exceedingly high number of accidents and fatalities. The public's interest is furthered by reducing huma n exposure to death or serious injury associated with manned aircraft performing v arious low level inspections and patrols.

• Petitioner's SUAS’ are battery powered and create n o emissions and are quite quiet. If Petitioner's SUAS crashes, there is no fuel to i gnite and explode. Any impact of Petitioner's lightweight SUAS’ is obviously, far le ss than a full size helicopter. The public's interest is furthered by minimizing human exposure to death or serious injury from an accident and ecological impact of by reducing to potentially harmful emissions and noise pollution associated with manne d aircraft.

• Problems with safety, cost, statistical integrity, and logistics continue to impede low

level aerial missions conducted from conventional m anned aircraft. The uses of SUAS’ address these problems, thus proving to be a powerful tool for performing a wide-range of various low level aerial missions & a pplications with associated data processing functions to include inspection of; agri culture; building; travel & power utility infrastructure; professional surveying; rea l estate; law enforcement; Electronic News Gathering (ENG); television; movie filming; radiological & consequence management and scientific research & de velopment are valuable and safe tools for these low level missions. The public as a whole will benefit from the safer and more cost-effective utility aerial servic es that SUAS operations provide.

• There is also a financial benefit to the public. Cu rrent methods of capturing aerial imagery are expensive, which proves to be cost-proh ibitive for many individuals and organizations. Granting exemptions such as the one proposed by Petitioner will make such services affordable to a wider group of p rospective customers.

IX PRIVACY

All flights will occur over Petitioner's property o r the Utility Customer's property with the customer's prior consent and knowledge.Above It All –UAS Services, LLC - FAA 333 Exemption Request

17 Revised 6/9/2015 X FEDERAL REGISTAR SUMMARY

Pursuant to 14 CFR Part 11, the following summary i s provided for publication in the FEDERAL REGISTER, should it be determined that publ ication is needed:

Petitioner seeks an exemption from the following ru les:

14 CFR Part 21, Subpart H;
14 CFR Part 27; 14 CFR 45.23(b); 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 exemptions will allow commercial operat ions of small and lightweight SUAS in the wide-range of various low level aerial missions & applications industry will enhance safety by reducing risk. Conventional opera tions in this industry using manned operations, rotorcraft or fixed-wing aircraft prese nt the risks associated with vehicles that weigh in the neighborhood of several thousand pound s and carrying large amounts of fuel. Such aircraft must fly to and from the locati on and operate at low altitudes.

In contrast, a SUAS weighing fewer than 25 lbs. and powered by batteries eliminates virtually all of that risk, given the reduced mass and lack of combustible fuel carried on board. The SUAS is transported, not flown, to the d esignated area and set up. The SUAS carries no passengers or crew and, therefore, does not expose them to the risks associated with manned aircraft flights.

The operation of small SUAS’ weighting less than 25 lbs. provides an equivalent level of safety and thus supports the grant of the exemption s requested herein, including exempting the Petitioner from the requirements of P art 21 and allowing commercial operations. These lightweight SUAS’ operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far sa fer than conventional aerial mission operations conducted with fixed-wing aircraft or he licopters.Above It All –UAS Services, LLC - FAA 333 Exemption Request

18 Revised 6/9/2015

Biographical Background of the Above It All - UAS T eam

Above It All - UAS Services, LLC (AIA-UAS) a small veteran & minority-owned company incorporated in the State of Virginia. The company’s mission is to provide innovative myriad of aerial mission solutions that inspire and advance the efforts of its

clients and affiliates.

Mr. Dolan - Founder & Operations Officer, Charles C iuzio – Chief Executive & Flight Officer and Steve Curtis – Chief Technical Officer, have assembled a team of experienced aviation, business and scientific profe ssionals deeply rooted in aviation industry committed to positively advancing the UAS industry on multiple platforms to meet emerging market needs.

We have and continue to strive with our expertise i n cutting edge aviation and science to integrate UAS use across our country and the world in compliance with all government laws and regulations, thus assuring the highest sta ndards of safety and quality. The team will be collaborating with the Mid-Atlantic Aviatio n Partnership at Blacksburg, Virginia, and the University of Las Vegas FAA UAS Test Sites to best meet these goals.

Team Members Bios:

Tom Dolan – Founder & Operations, Mr. Dolan is a commercial instrument rated pilot in helicopters, single and multi-engine airplanes w ith 2,000 hours of flight, a Safety Officer for a local flying club and flying service. He was a pilot for a scheduled helicopter airline around Manhattan New York after graduating from Embry-Riddle Aeronautical University in 1982.

In 1988 he began his career as a Police Officer for the Nassau County Police Department (NCPD) on Long Island, New York being assigned to t he Marine-Aviation Bureau where he either piloted Bell Jet Ranger helicopters or po lice boats on patrol missions, on, over or around Nassau County its waterways, the gateway to the port of New York. During police career he was assigned to rescue operations at Ground Zero on 9-11-2001 World Trade Center Terrorist Attack, the downing of TWA's 747 Flight 800 disaster in March 1997, and the downing of the Avianca B-707 Flight 0 52 Disaster in January 1991. He received the 5th Precincts "Top Cop Award" also the “Department of Transportations

9-11 Medal”.

While still working as a Police Officer soon after the World Trade Center and Pentagon Terrorist attacks, Mr. Dolan realized there was a l arge void in maritime security, so he assembled a team to solve this dilemma, founding Ho meland Security Aviation & Maritime Services, Inc. (HSA), a technical support company dedicated to providing expert system support solutions to measure radiatio n signatures to government customers

in the area of aerial & vessel-borne radiation dete ction systems and field operations.

HAS’ team was compromised of members from the Penta gon, Nuclear Emergency Search Team (NEST), Nuclear Physicists and a variet y of scientist and technical experts,Above It All –UAS Services, LLC - FAA 333 Exemption Request

19 Revised 6/9/2015 that had a vast understanding of both the Federal a nd local levels of emergency response, devised solutions to the response community of how best to detect and measure radiation sources, along with on how to best shield and prote ct financial markets, utilities and computer systems from effects of Electro Magnetic P ulse Weapons.

Mr. Dolan’s HSA gained support and assistance for c ollaborative purposes from Brookhaven National Laboratory, Domestic Nuclear De tection Office, New York State Foundation for Science & Technology (NYSTAR) and Ho meland Security Chairman Congressman – Peter King. The program was being pic ked up by the National Nuclear Security Agency (NNSA) Administrator - Thomas Dagas tino to perform a study with Department of Homeland Security (DHS) and Departmen t of Energy (DoE) only to come to an abrupt halt when new administration cut fundi ng for all new NNSA projects.

With over 26 years with NCPD Mr. Dolan retired in 2 012 and moved with his family to central Virginia where he has worked closely with s everal law enforcement agencies on the use of UAS’s. Invited by Chief Sellers of Albem arle County Police Department (ACPD), Tom demonstrated the usefulness of UAS’ bef ore citizen members of the County’s Crime Prevention Council. Sellers was inst rumental in developing Virginia’s “Model Policy” on the use of UAS in law enforcement agencies for the Legislature, Department of Criminal Justice Services & the Offic e of the Attorney General it the state of Virginia. Those leery of the technology soon acc epted the technology finding pros outweighed the cons as long as the “Model” guidelin es” were adhered to.

October 2 nd 2013, Mr. Dolan successfully orchestrated the use of a high technology UAS from Virginia Tech’s Mid-Atlantic Aviation Partners hip (MAAP) in assisting in the close to month long exhaustive search effort, led by Chie f Sellers, for a missing University of Virginia student, Hannah Graham. The use of this te chnology was welcomed by the Charlottesville community which marked the first ti me in Virginia history that a UAS was used by law enforcement, with the Federal Aviat ion Administrations approval.

Tom is a member of the Airborne Law Enforcement Ass ociation’s Manned/Unmanned Aircraft Integration Safety Committee, Safety Offic er for both VDW Flight Services and the Monticello Flying Club.

Charles Cuzio – Chief Flight & Operations Officer Charles Ciuzio has extensive military and civilian manned and unmanned aviation experience. He is a 21 year retired U.S. Air Force Lieutenant Colonel with over 6400 flight hours in transport category aircraft includi ng the C-141, C-17 and C-21 aircraft.

Chuck served as Instructor and Evaluator pilot in t he C-17 performing worldwide missions in support of national objectives. He als o held positions in squadron training and standardization departments and as Squadron Ope rations officer.

He is a graduate of the U.S. Air Force, Air Comman d and Staff College; U.S. Army, Command and General Staff College and the U.S. Air Force, Air War College.Above It All –UAS Services, LLC - FAA 333 Exemption Request

20 Revised 6/9/2015 After retiring from the Air Force he spent 5 years working with the ScanEagle UAS system built by Insitu, Inc. (A Boeing Company). T he ScanEagle is a 45lb. small UAS with line of sight range of 60 miles and endurance of 18-24 hours. The ScanEagle has the ability to carry different payloads including a variety of cameras and sensors. Chuck’s ScanEagle experience includes 3 years deplo yed to Iraq and Afghanistan as an operator, maintainer and site lead in support of Do D customers.

Chuck has an extensive educational background. He is a 1987 graduate of the U.S. Air Force Academy and holds a master’s degree in Aviati on Science and Technology from Embry-Riddle Aeronautical University. He is curren tly enrolled in an MBA program at Washington State University. Chuck is also a certi fied Program Management

Professional and has taken all of the coursework fo r a Villanova University Six Sigma Black Belt. Chuck is currently a pilot for Netjets Aviation, Inc where he is a First Officer

on the Dassault Falcon 2000.

Steven Curtis

– Chief Technical Officer/UAS Systems Integration - Steven Curtis worked on NEST and radiation consequence management missions for DOE/NNSA for 13 years. He has held every field position within t he National radiological emergency response arena. One of the premier assets of the DO E/NNSA's Remote Sensing Laboratory is the Aerial Measuring System (AMS). Th is is the nation's primary response tool for initial assessment of a radiation depositi on on United States soil. He was the program manager for this asset for two years and hi s focus has been radiation detectors in the field-deployed systems.

Mr. Curtis held Battalion staff and Company Command er Positions as an officer in the Army and Nevada National Guard. For the last two ye ars, he had been a consultant, mostly working with National Security Technologies, LLC, in support for the Nevada

Test Site. He has worked with SAIC on several DHS D NDO architecture projects.

Mr. Curtis was the proposal manager for the success ful Screening Information Request proposal that secured the UAS FAA Test Site for the State of Nevada. He has been involved with technical integration for UAS with th e Nevada System of Higher Education for the last three years.

Steven Curtis has more than 30 years of experience in emergency response team leadership, program management, and academic collab oration for the Department of Energy (DoE), Federal Emergency Management Administ ration (FEMA) Environmental Protection Agency (EPA), University of Las Vegas (U NLV), and the Desert Research Institute. He holds a masters degree in Health Phys ics and a BSEE, both from UNLV.

Alan Saville – UAS Pilot/Air Traffic Control Liaison - Mr. Saville served in U.S. Army. Upon separation he became an FAA Air Traffic Control Specialist. He has over 14 years experience in Control Towers, Ground Controll ed Approach, Approach Control and

Air Route Traffic Control Center in 6 facilities ac ross the nation and the US VirginAbove It All –UAS Services, LLC - FAA 333 Exemption Request

21 Revised 6/9/2015 Islands. Alan is also a Commercial and Air Transpor t Pilot with Flight Instructor, Multiengine and Instrument ratings.

Alan has been involved and has extensive expertise in remote controlled platforms predominately with gliders, powered & float aircraf t for over 25 years and multi-rotor UAS’s in the last 5 years.

Scott Leiffer – Survey Officer - Sensor, Payload & Mapping - Scott Leiffer has been working in the Land Surveying field since 1994. His first surveying job was the Boundary Re-trace and Line Marking of several miles of U.S. Forest Service Boundary in Alleghany County, Virginia. Scott began work at Bel l Surveys, Inc. in 2000, where he worked his way up from Party Chief of a field crew to Project Manager to Licensed Land Surveyor in 2007. Scott left Bell Surveys, Inc. in 2010 due to Bell Surveys, Inc. financial difficulties. After working other jobs to get back in the black personally, Scott started Alpha Land Surveys LLC in 2011. In the summer of 20 13, Scott purchased the assets of Gregory D. Hosaflook, P.C. when Mr. Hosaflook retir ed after 30 years in business. In April of 2014, Scott purchased the assets of Bell S urveys, Inc. when his previous employers decided to retire. In July of 2014, Scott purchased the assets of Louisa Aerial Surveys from James H. Bell, Jr., the original owner of Bell Surveys, Inc. Mr. Bell at 84 years of age is can still be seen at the office as a mentor.

With the conglomeration of companies, Scott changed the company name to Bell Land Surveys LLC in honor of the founder, James H. Bell, Jr., who started his journey in 1963. Bell Land Surveys LLC is a privately owned company with over 50 years of surveying experience. We are able to provide clients a wide r ange of specialty services including but not limited to: Land Planning and Design, Site Surveys, Construction Staking, Aerial Mapping, Topographic Maps, Orthophotos, Volumetric Calculations and Project Management. Mr. Leiffer has since partnered with Ab ove It All – UAS Services, LLC to bring the company into the 21 st Century by utilizing cost effective Unmanned Aeria l Systems to pass along the cost savings of these UAS ’ to his clients.

Our clientele range from private land owners to cor porate developers to Engineers & Landscape Architects. We provide services for clien ts involved in state, county and federal projects as well as development companies, investment groups, and non-profit organizations. Bell Land Surveys is currently worki ng on a Siteplan for Virginia Vermiculite, a mine based in Louisa, to open a new pit. We have also mapped the Nestle/Purina Cat Litter Plant in Ashland, VA 3 tim es per year for many years. We also map several landfills in Virginia for Santek Enviro nmental 2-3 times per year.

Dr. Jens Hovgaard – Radiological Detection UAS Payl oads - Dr. Jens Hovgaard - Nuclear Physicist- President of Radiation Solutions , Inc. has over 25 years experience with nuclear detection techniques, including radiat ion monitoring from airborne platforms and aerial sensors. Jens was one of the l ead specialists in the aerial mapping & Tracking radiation fallout from the Chernobyl React or disaster. Jens was lead scientist atAbove It All –UAS Services, LLC - FAA 333 Exemption Request

22 Revised 6/9/2015 SAIC Exploranium in developing and producing radiat ion sensors for airborne applications. One of his sensor systems at Exploran ium was used by the military in a Blackhawk helicopter searching for Weapons of Mass Destruction in Iraq.

Dr. Jens Hovgaard founded Radiation Solutions Inc. (RSI) in 1999. Upon inception, RSI's primary function was to act as a consulting c ompany to the nuclear industry. While working with his customers and their supplied radia tion detection systems, Dr. Hovgaard identified there was a need for a new supplier of t hese systems that many on the market did not actually deliver the state-of-the-art techn ology they promised. In 2006, accompanied by a world-renowned nucleus of speciali sts, he began to design and manufacture a "new generation" of radiation detecti on systems. The RSI team have a vast amount of experience not only in the design of fiel d-use radiation detection systems but also in their applications. A vast majority of his sensors can be used on airborne applications. He continues to decrease the detector s size and is collaborating with Mr. Dolan to use UAS platforms to carry his detector/se nsor payloads.

Dr. Hovgaard’s focus is the design and manufacture of state-of-the art radiation detection systems using advanced DSP (Digital Signal Processi ng) technology. This technology provides a level of radiation detection previously only attainable in laboratory equipment. He holds a Ph.D. from Technical University of Denma rk specializing in airborne gamma ray surveying.

Dr. Michael Holroyd

– UAS 3D Modeling/ Search & Rescue (SAR) Projects Manager - Dr. Holroyd is a researcher in computer security, c omputer vision, and computer graphics as well as an instrument rated pr ivate pilot in single-engine aircraft. He received his Ph.D. in Computer Science from the University of Virginia in 2011. Dr. Holroyd has multiple publications and patents in th e areas of 3D scanning and computational photography, and is the founder of Ar qball (http://arqball.com), a small research and product development startup in Charlot tesville VA, where he has been Principal Investigator for over $1.1 million in res earch funded by the NSF (National Science Foundation).

Dr. Holroyd has also served multiple roles in the B lue Ridge Mountain Rescue Group and Appalachian SAR Conference, and currently holds certifications as a Field Team Leader and Field Team Signcutter through VDEM (Virg inia Department of Emergency Management), and Technical Rescue 3 through the VAV RS (Virginia Association of Volunteer Rescue Squads).

Dr. Holroyd will consult with Mr. Dolan and his Abo ve It All Team on technology, photography and SAR issues, as well as assist with web-based technologies for making UAS aerial imaging more accessible and useful for p otential customers. He has significant experience with image-based interactive media, including creating Arqspin (http://arqspin.com), a platform for interactive 36 0 product photography with direct applications to UAV-based aerial imaging in the rea l-estate and security markets.Above It All –UAS Services, LLC - FAA 333 Exemption Request

23 Revised 6/9/2015 Luke Macfarlan – UAS EMS Analysis/Operations & Ag/V ineyard Lead Mr. Macfarlan has 12 years of military operations e xperience as an officer in the Virginia National Guard. This experience includes two deplo yments for security operations in support of the war on terror. Operations were prim arily focused on fixed site security of the major Seaport of Debarkation (SPOD) in Kuwait, and fourteen Special Forces facilities throughout Iraq. After a decade of serv ice in the Infantry, Mr. Macfarlan transitioned to the Army’s new Cyber Electromagneti c Activities branch where he has excelled. He recently planned a major training ope rating, and was directly responsible for the planning and integration of aviation operat ions and airspace management for three Army rotary wing units, fourteen UAS systems (Shado w and RAVEN), one Army artillery Battalion, and mortar sections from four maneuver Battalions.

Mr. Macfarlan's civilian experience spans a series of research and development (R&D) activities related to security and military operati ons at the Departments of Homeland Security and Defense. These activities included an evaluation of technologies to counter

shoulder-fired missiles directed at civilian airlin ers, development of an RFID tag capable of detecting security breaches in ISO90 shipping co ntainers, and various evaluations directed at mitigating roadside bombs in Iraq using jammers, electro-apical detection systems, and big data analytics.

Mr. Macfarlan is currently the co-founder of an Ele ctronic Warfare consulting firm and of a small wine marketing firm, both of which are l ocated in Central Virginia. He is also completing an Executive MBA at one of the nation’s top academic institutions - the University of Washington in Seattle. Mr. Macfarlan will support Above It All’s team in providing EMS (Electromagnetic Spectrum) analysis f or safe operation of UAS systems in our operations and assist in consulting work wit h other agencies or companies along with vineyard related marketing or agricultural UAS use. Luke holds an FAA Private Pilot Certificate with multi-engine and instrument ratings. He also has over 100 hours of logged flight operating time with a DJI PHANTOM 2 V ision + UAS.

Kurt Frisz – Airborne Law Enforcement UAS Liaison – Captain Kurt Frisz has been with the St. Louis County Missouri Police Departmen t for 29 years. He served over 17 years assigned to the departments Tactical Operatio ns Unit, 7 years as the units’ commander. During this time, he has commanded over 100 hostage/barricade situations, numerous dignitary protection events as well as coo rdinated response to numerous civil

disorder events. In addition to his duties with th e Tactical Unit, Capt. Frisz also serves as one of the departments’ pilots, possessing both rot orcraft and fixed wing ratings, as well as being a Certified Flight Instructor in helicopte rs.

Captain Frisz is currently the President of the Air borne Law Enforcement Association (ALEA) and has served on the board of directors sin ce 2008. Kurt has worked with groups, including the FAA and IACP advance the inte gration of UAS into law enforcement, and has participated in discussion pan els relative to UAS and the future use for first responders along with being a member of t he ALEA’s sUAS Committee.Above It All –UAS Services, LLC - FAA 333 Exemption Request

24 Revised 6/9/2015 Captain Frisz is currently assigned as the Commande r of the Bureau of Drug Enforcement. During the civil unrest in Ferguson, he served as the commander of special operations, overseeing the tactical response and th e aviation assets.

Brady Genz – UAS GEO Spatial & UAS Cybersecurity Te am Lead - Mr. Genz has over 13 years of all-source military intelligence e xperience at the strategic level of Army operations, 19 years of enlisted & commissioned Arm y Reserve experience focusing on military intelligence and Army communications syste ms with extensive training and certification in cybersecurity vulnerabilities of S CADA, industrial control systems, and IT networks, also strategic experience in productio n of all-source and geospatial intelligence supporting conventional and special op erations forces.

Mr. Genz is knowledgeable in Intelligence Community organization, disciplines, and missions with active Top Secret / SCI security clea rance. Brady is a volunteer with the Civil Air Patrol in the Monticello Composite squadr on in Charlottesville, VA, he holds a FAA Certificated Flight Instructor - Instrument rat ing also FAA Airframe & Powerplant

Mechanic certificate and served as an instructor an d check pilot for the Virginia Wing participating in ground and air search & rescue mis sions and training activities. He served as squadron finance officer and deputy commander fo r cadet activities, volunteering as coach with squadron team to participate in the nati onal 2010, 2011, and 2012 high school Cyber Patriot competition.

Mr. Genz is currently attending classes part-time t oward PhD in Systems Engineering at the University of Virginia and has a Master of Scie nce in General Engineering, Bachelor of Science in Computer Science & Mathematics and Pr ofessional Pilot/Aviation Maintenance Program all from University of Illinois at Urbana-Champaign.

Bio Summary:

The Petitioner’s team is committed to positively ad vancing the UAS industry on multiple platforms and ones emerging in the future. We are e xperienced business and scientific professionals deeply rooted in aviation looking to meet an emerging market needs. We have and continue to strive with our expertise in c utting edge aviation and science to integrate UAS use across our country in compliance with all government laws and regulations, thus assuring the highest standards of safety and quality.Above It All –UAS Services, LLC - FAA 333 Exemption Request

25 Revised 6/9/2015 XII CONCLUSION

Satisfaction of the criteria provided in Section 33 3 of the Reform Act of 2012 - size, weight, speed, operating capabilities, proximity to airports and populated areas, use of FAA Certified Pilots for both PIC & PO along with o peration within visual line of sight and national security provides more than adequate j ustification for the grant of the requested exemptions allowing commercial operation of Petitioner SUAS in the utilitypower transmission inspection and patrol industry i n accordance with the available

Manual

If additional information is required, or if you ha ve any questions regarding this Petition for Exemption, please contact the undersigned at:

Sincerely,

Thomas E. Dolan –

Founder & COO - Above It All – UAS Services, LLC

30 Industrial Drive, Suite 1B Louisa, Virginia 23093

Office: 434-374-1866

Cell Phone: 631-495-2947

Email: Tom.Dolan@aboveitall-uas-services.com or

thomasedolan@gmail.com