2

Frank Taylor Community Safety Consulting Group (CSCG) 42

- 215 Washington St. suite A #386 Palm Desert, CA 92211 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Dear Sir or Madam: Attached, please find the request for an exemption, for Community Safety Consulting Group (also known as CSCG) owned by Frank Taylor, from certain stated Federal Aviation Regulations to allow commercial operation of its S mall Unmanned Aircraft S ystems (hereafter referred to as “SUAS”) for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, aerial inspections, data collection, security monitoring, public saf ety, first responder, search and rescue, emergency response support and other flight operations, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333 of the FAA Modernization and Reform Act of 2012. Please be advised that the FAA has previously issued grants of exemption in circumstances similar in all material aspects to those requested in this petition, notably in Exemption Nos. 11487 to HAZON Solutions, 11 552 to Sinclair Community College, and 11110 to Trimble Navigation Ltd. for fixed wing SUAS similar to the fixed wing SUAS proposed herein, in Exemption No. 11446 to Trumbull Unmanned LLC which includes the specific VTOL SUAS proposed herein, Exemption No. 11925 to James Michael Hourihan for VTOL SUAS based emergency response support operations. Therefore, CSCG respectfully requests this exemption be considered under the “summary grant” process. As detailed in this document, a granted exemption would permit the commercial operation of S UAS under controlled conditions in airspace that is limited and controlled via subsequent COA applications. Predominantly, C SCG seeks to operate under the “Blanket 200ft COA” guidance that was issued by the FAA in March 2015 and respectfully requests the “Blanket 200ft COA” be granted in concert with these exemptions. The requested exemptions and proposed limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure, specifically safety enhancements to personnel climbing vertical infrastructure and create a low

-risk alternative to certain manned aviation operations.3

As outlined in this request for exemption, the SUAS’s CSCG proposes to use are: Sentera Phoenix Lockheed Martin Procerus Technologies (LMPT) Indago DJIPhantom II, III DJIInspire

If Ican provide any

additional information in support of your review of this p etition, please do not hesitate to call me at 760

- 250

- 8358 or send an email to ftayl or@dc.rr.com

. Sincerely, Frank Taylor Owner Community Safety Consulting Group (CSCG)4

**Section 1: Introduction & Interest of Community Safety Consulting Group (CSCG)**  Community

Safety Consulting Group (CSCG) is headed b y Frank Taylor, a retired Captain from the Riverside County Sheriff’s Department of California, with almost 29 years of public safety experience. During his law enforcement career, retired Captain Taylor was involved in a multitude of regular law enforcement duties including, but not limited to, criminal and forensic investigations, Administrative Management, along with search and rescue operations. Additionally, his expertise was enhanced through his involvement in numerous technology related projects. These included Automated License Plate Readers, Body Worn Cameras, along with research and development of major databases used to help organize major criminal investigations. After retiring from his public safety career, he began to enhance his experience level by educating himself in the operations of Unmanned Aerial Systems (UAS). This was enhanced by becoming a member of the Association for Unmanned Vehicle Systems International (AUVSI), a member of the American Modelers Association (AMA), a member of the Airborne Law Enforcement Association (ALEA), along with attending a multitude of conferences and seminars related to UAS operations. In 2013, he founded and is the owner of CSCG located in Palm Desert California. Frank Taylor is currently involved in the Certificate of Authorization process for a public agency, slated to use the Sentera Phoenix UAS, under COA 2015

-WSA

- 157

- COA

. He has also been involved with Sentera LLC of Minnesota, the manufacturer of the Phoenix, for an extended period of time. CSCG also consults with law enforcement, public agencies, agricultural businesses and clients involved in Research and Development, by providing expertise during the complicated process of integrating Unmanned Aerial Systems (UAS) into the National Airspace. (NAS) Whether fo cusing upon domestic usage, ground

-truthing of crops, or R&D related to UAS applications, CSCG provides a service to help navigate the process to operate in the NAS. Educating governmental stakeholders and the public, working through the FAA application process, are all parts of how CSCG help’s our clients. CSCG’s staff includes current and retired aircraft pilots with hundreds of hours of flight experience, retired law enforcement personnel, along with several other personnel with extensive knowledge and expertise in the SUAS field and operations. CSCG proposes to commercially operate the Sentera Phoenix , the Lockheed Martin Procerus Technologies (LMPT) Indago , the DJI Phantom II & III , and the DJI Inspire SUAS platforms for the purposes of aerial inspections, crop and agricultural surveys, aerial photography, videography, data collection, security monitoring, public safety, search and rescue, first responder and emergency response support and other flight operations conforming to the proposed limitations and restrictions. CSCG holds that commercially operating an SUAS within the NAS under these same limitations and restrictions will not pose a hazard to manned aircraft, and that operation of its SUAS is in the public best interest by providing an inexpensiv e, low

-risk alternative to manned survey operations.5

**Section 2: Regarding the Unmanned Aircraft System**  The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This section intends to fulfill each requirement of this guidance.
1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners should describe the d esign and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft performance and performance limitations, operating procedures, and aircraft loading information in as much detail as possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document. NOTE: The FAA will consider all information and data submitted by the petitioner that describes the UAS developmental and operational history. This could include statistical data or other documentation for the specific design and performance characteristics of the UAS, including the operational history and operational failure modes, obtained through previous Research & Development (R&D) and/or flight test activities, e.g. operations conduct

ed under a COA, with a civil airworthiness certificate, or under other authorized operating conditions.
2. Petitioners should describe any procedures they would implement, such as pre- flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate documents or combined in a single document.
3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC requirements upon request. CSCG intends to commercially operate SUAS weighing less than 55 lbs, during daylight hours, within visual line of sight of the PIC, at altitudes less than 400ft AGL and at speeds less than 100 mph or 87 knots (depending on the system, see Section 2.1 below). As described later, CSCG’s PICs shall be fully qualified airmen, holding at least a sport pilot certificate and associated medical clearance. The proposed SUAS are equipped with GPS

enabled autopilots, capable of safe, steady autonomous flight and guided by the PIC. The proposed SUAS are commercially available, “off the shelf” products that have accumulated innumerable flight hours and they have proven themselves, low

-risk, safe aircraft. Given6

the small size and weight, low altitudes, slow speeds, a qualified PIC, a GPS

- enabled autopilot, data

- link and countless flight hours, CSCG holds that commercially operating these SUAS under the limitations and restrictions set forth is a safe alternative to the current regulatory

structure and minimizes risk to the NAS or to persons and property on the ground. **2.1 Proposed**  **SUAS** CSCG intends to operate the Sentera Phoenix family of SUAS , the Lockheed Martin Procerus Technologies (LMPT) Indago family of SUAS , along with the DJI Phantom and Inspire families of SUAS

. All of these types of systems have been proven to be reliable and effective SUAS with the ability to carry payloads such as cameras, sensors and other equipment necessary to complete CSCG’s aerial photography, cinematography, videography, mapping, crop surveying, inspection, search and rescue and public safety tasks. Each SUAS is described below. **Sentera Phoenix**  The Sentera Phoenix system is comprised of a fixed wing , hand

- launched, propeller driven unmanned aircraft and a laptop or tablet based ground control, responsible for both vehicle operation and camera functions, along with a communication s data

- link providing bi

- directional communications between the air vehicle and the ground control station. The Phoenix SUAS has the ability to conduct hand

- launched takeoffs, precision landings in varied terrain and execute standard horizontal flight maneuvers. The maximum gross weight of the Phoenix is 3.5 lb. (1588g), and it measures 8in (203mm) tall , 22

- 26in (559

- 660mm), long (depending on the model) and has a 38in (965mm) or 48 in (1219mm) wingspan (again, depending on the model). Its standard cruise speed is 29

- 35 mph (25

- 30 ktas, 13

- 15 m/s), maximum horizontal speed of 52 mph (45 ktas, 23 m/s) and maximum ascent and descent speeds are 800 ft/min (4.1m/s) is 400 ft/min (2.0 m/s) respectively. The Phoenix is powered with a Lithium Ion battery and flies for approximately 60 minutes. Detailed specifications are available in the Sentera Phoenix UAS Pilot Operational Handbook attached as Appendix 1. The Sentera Phoenix system has been proven to be a reliable and effective system for operations such as those proposed herein and has previously been approved for similar uses by FAA. The Sentera Phoenix is an evolution of the Vireo UAS, originally produced by UTC Aerospace Systems by the team that now forms the core engineering team of Sentera. The Sentera Phoenix’s immediate predecessor, the Vireo is currently operating in numerous FAA
- approved Public COAs as identified below:

 2013

- E S A

- 4 6 CO A Hyd e (P roponent : N C State University)
 2013

- E S A

- 6 5 CO A Butner (P ropon ent : N C Stat e University)
 2013

- E S A

- 6 9 CO A C aratoke (P ropon ent : N C State University)
 2014

- E S A

- 9 3 CO A Verno n Jam e s (P ropon ent : N C State University)7  2014

- E S A

- 1 1 4 CO A L ake Whee l er (P ropon ent : N C State University)
 2015

- CSA

-24

- COA S pringfield Airpark (Proponent: Sinclair Community College)
 2013

- CSA

- 56 Wilmington Airpark (Proponent: Sinclair Community College) **Lockheed Martin Procerus Technologies (LMPT)**  **Indago** The Indago system is comprised of a four

-rotor Vertical Takeoff and Landing (VTOL) unmanned aircraft and ground control station

– either a handheld controller or a laptop/tablet based control station

– which is re sponsible for both vehicle operation and camera functions, along with a communications data

- link providing bi

- directional c ommunications between the air vehicle and the ground control station. The Indago SUAS has the ability to conduct vertical takeoffs and landings, hover and execute standard horizontal flight maneuvers. The maximum gross weight of the Indago is 4.85 lb (2200g), and it measures 32 x 32 x 9 in (813 x 813 x 229mm). The Indago’s maximum horizontal speed is 30mph (13.4 m/s), maximum ascent speed is 800 ft/min (4.1 m/s), and maximum descent speed is 400 ft/min (2.0 m/s). The Indago is powered by a Lithium Ion battery and flies for approximately 45 minutes. More detailed specifications are available in the Indago User Guide attached as Appendix 3

. The Indago system has been proven to be a reliable and effective system for operations such as those proposed herein and has previously been approved for similar uses by FAA in the form of numerous Section 333 Exemptions, such as those outlined on page 1 of the cover letter above. **DJI Phantom**  The Phantom system is comprised of a four

-rotor unmanned aircraft and handheld controller, which is responsible for both operation and camera functions. The maximum gross weight of the Phantom is 1250g, and it measures 350mm across rotor
-to
-rotor
. Its maximum horizontal, ascent and descent speeds are 15 m/s, 6m/s and 2m/s re spectively. The Phantom is powered with a Lithium Ion battery and flies for approximately 20 minutes. More detailed specifications are available in the DJI Phantom Operations Manual, which is attached as Appendix 5

. **DJI Inspire**  The Inspire system is comprised of a four

-rotor unmanned aircraft and handheld controller, which is responsible for both operation and camera functions. The maximum gross weight of the Inspire is 3000g, and it measures 438 x 451 x 301mm. The Inspire’s maximum horizontal, ascent and descent speeds are 22m/s, 5m/s and 4m/s respectively. The Inspire is powered by a Lithium Ion battery and flies for approximately 20 minutes.8 More detailed specifications are available in the DJI Inspire Operations Manual, which is attached as Appendix 6

. **2.2 Maintenance &**  **Inspection** CSCG shall follow the manufacturer’s maintenance, overhaul, inspection and record

-keeping guidelines as specified in the relevant manufacturer user manuals, attached as Appendices 1 , 3, 5 & 7

. CSCG will conduct inspections and maintenance, which shall be noted in the aircraft’s logbook including total flight hours and the nature of maintenance performed. Comprehensive maintenance will be performed in conformance with the manufacturer’s guidelines. In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect the SUAS to ensure it is safe to fly as described in the relevant manufacturer user manuals and checklists, attached as Appendices 2 (Sentera Phoenix) , 4 (LMPT Indago) , 5 & 9 (DJI Phantom) and 7 & 8 (DJI Inspire)

. Furthermore, the PIC will conduct a pre - flight checklist as described in the Operations Manual ’s and Safety Guidelines

. With both inspections completed and passed, the SUAS shall be deemed safe to fly. All SUAS proposed under this request for exemption will be in compliance with all manufacturer maintenance, system and safety bulletins.
**2.3 Radio**  **Communications** All radio systems used in the proposed SUAS comply with FCC regulations and have earned FCC approval. CSCG shall operate the SUAS in compliance with those approvals. Certificates of compliance may be found in Operations manuals in Appendices 1 , 3, 5 and 6

. Both the Phantom and Inspire SUAS operate in two different FCC

- approved bands. The remote control operates between 5.728 and 5.85GHz, and the video/data

- link operates between 2412MHz and 2462MHz. **Section 3: Regarding the Unmanned Aircraft**  **PIC** The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This section intends to fulfill each requirement of this guidance. Regarding the Unmanned Aircraft PIC 4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including information such as: the level of airman certificate held; any applicable training related to the operation; and any minimum hours of flight experience required by the PIC(s), both totalflight time and the time with the particular UAS. If the operation would use visual observers, petitioners9

should describe their roles and qualifications. 5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for the operation of the UAS. CSCG PICs shall possess a “current airline transport, commercial, private, recreational or sport pilot certificate. ” The PIC shall also hold a current FAA airman medical certificate or a valid U.S. Driver’s License. The PIC shall also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. Prior to commercial operations, CSCG PICs shall have accumulated and logged a minimum of 25 hours total time as an SUAS pilot. Flights for the purposes of training CSCG PICs and VOs (training, 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 requested under the terms of this exemption. Training operations shall only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all p ersons not essential for flight operations shall be considered nonparticipants, and the PIC shall operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. **Section 4:**  **Regarding the**  **Operation of**  **the Unmanned**  **Aircraft** The FAA’s public guidance on filing an exemption under Section 333 is reprinted below, along with CSCG’s proposal. This section intends to fulfill each requirement of this guidance. Regarding the Operation of the UnmannedAircraft 6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure public safety, which includes persons and property both in the air and on the ground. This can be described in the petition, in an Operations Manual, or similar document. NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of fligh t, NAS safety considerations, and the safety of the non participating persons and property during the operational period and within the operational area. 7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an Operations Manual, or similar document. The SUAS will be operated during daylight hours, in compliance with visual flight rules, and10

flown within direct visual line of sight of the PIC at all times and never over congested or densely populated areas unless specifically authorized by the Air Traffic Organization

issued COA. The PIC shall 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. The SUAS shall be operated at an altitude of no more than 400ft AGL, unless specifically authorized and operating under the terms of the COA, at speeds less than 23m/s (52mph). The SUAS will not be operated less than 500ft below or less than 2000ft horizontally from a cloud, or when visibility is less than 3 statute miles. Prior to beginning a flight, the PIC shall clearly establish the limits in latitude, longitude and altitude AGL to ensure compliance with the COA under which the SUAS is flown and establish the “sterile area” for operations. If at any time, this area is breached by unpredicted obstacles (manned aircraft or otherwise), the PIC shall abort the flight. Manned aircraft shall have right of way at all times. Incase of a reduced or diminished control link, the SUAS will automatically return to a predetermined point within the private or controlled

- access property. The PIC shall not begin a flight unless there is sufficient available power for the SUAS to complete the intended mission and to operate for at least five minutes after that. By operating within the limitations and guidelines set forth herein, CSCG shall provide an equivalent level of safety to operations under the existing regulatory structure. 8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory mandate under Section 333 regarding proximity to populated areas. These issues can be addressed in the petition, an Operations Manual, or similar document. 9. Petitioners should describe if they intend to operate in the proximity ofany airports, in accordance with the statutory mandate under Section 333 regarding proximity to airports. All flight operations will be conducted at least 500ft from all nonparticipating persons, vessels, vehicles and structures on private or controlled access property with permission from the property owner/controller or authorized representative. In some cases due to mission requirements, the SUAS will be operated closer than 500ft to commercial and industrial infrastructure and facilities. In these instances, CSCG shall have the authorization of the property owner/controller or from an authorized representative, and the PIC shall have conducted a safety assessment and determined that it does not present an undue hazard. Permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted. In accordance with the “Blanket 200ft COA” guidance that was issued by the FAA in March 2015, flight operations will not take place within,11  5 nm from an airport having an operational control tower; or
 3 nm from an airport with a published instrument flight procedure, but not an operational tower; or
 2 nm from an airport without a published instrument flight procedure or an operational tower; or
 2 nm from a heliport with a published instrument flight procedure unless a letter of agreement with that airport’s management is obtained and/or otherwise permitted by

an Air Traffic Organization

- issued COA. Foreseen hazards include encroachment of manned aviation operations and nonparticipants on the ground. Both of these hazards are mitigated by choice of location (non

congested areas) and strict limits on range (visual line of sight) and altitude established herein. Operation under these limits effectively mitigates these risks.
10. The UAS must be operated within visual

- line

- of

-sight (VLOS), in accordance with the statutory mandate under Section 333(b ) ( 1) . Petitioners should describe how they intend to comply with this m andate. 11. Petitioners should describe any procedures they would implementfor conducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be completed safely. These procedures can be addressed in the petition, an Aircraft Flight Manual, Operations Manual, or similar document. As described above, the SUAS will be operated during daylight hours, in compliance with visual flight rules, and flown within direct visual line of sight of the PIC at all times. The PIC shall 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. In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect the SUAS to ensure it is safe to fly as described in Appendices 1

- 4

. Furthermore, the PIC will conduct a pre - flight checklist as described in Appendix 5 (Sentera Phoenix) , Appendix 6 (LMPT Indago), Appendix 7 (DJI Phantom) and Appendix 8 (DJI Inspire) and ensure the planned operation can b e completed safely with sufficient battery reserves (including wind and terrain limitations). With both inspections completed and passed, the SUAS shall be deemed safe to fly.
12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture and television filming, or pipeline and powerline patrol

– petitioners should describe their intended coordination in this regardfor their proposed operation(s). CSCG’s aerial infrastructure inspections, cinematography/videography, agricultural12

operations, security monitoring, public safety, search and rescue, first responder and emergency response support operations do not require notification to FSDOs. 13. The FAA intends to require entities who obtain an exemption under this process to also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS. The COA application is available here. As stated previously, CSCG shall obtain an Air Traffic Organization

- issued COA p rior to conducting any operations under this requested grant of exemption. CSCG s eeks primarily to operate under the “Blanket 200ft COA” guidance offered by the FAA in March, 2015 and respectfully requests that COA be issued concurrently with these exemptions. For operations not conforming to the “Blanket 200ft COA” guidance, CSCG will seek separate and additional COAs to operate its SUAS. **Section	5:	Requested Exemptions**  **14	C.F.R Part**  **Summary	of Regulation**  **Proposed Action**  21, Subpart H Airworthiness

Certification In consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the FAA has previously held that this aircraft meets the conditions of Section 333, therefore, requested relief from 14 CF R part 21, and any associated noise certification and testing requirements of part 36, is not 45.23(b) Display of Marks CSCG SUAS shall be identified by serial number and N

-number, in markings as large as practical given the small size of the aircraft. However, the 2 inch minimum set forth in this rule is impractical, therefore relief is requested. 61.23(a) 61.101(e)(4&5) 61 113(a) & (b) 61.133(b) 61.315(a) Certification:

Pilots, Light Instructors and Ground Instructors In previous petitions for exemption, the FAA has held that a PIC of an SUAS holding at least a Sport Pilot certificate and a U.S. Driver’s License, or greater medical certification, would not adversely affect safe operations within the NAS or present a hazard to people or structures on the ground. Relief, subject to the limitations provided in this document, is requested. 91.7(a) Civil Aircraft

Airworthiness PICs operating on behalf of CSCG shall perform preflight inspections and ensure airworthiness prior to flight as described in this document, manuals and appropriate appendices. Relief from this requirement is not necessary.13

91.9(b)(2) & (c) Civil aircraft flight manual, marking, and placard requirements CSCG shall provide a current SUAS Flight Manual, and operational instruction material at the location of the PIC and/or Ground Station. The FAA has previously determined that, given this, relief from this requirement is not necessary. 91.103 Preflight Action CSCG will perform. Relief is not necessary. 91.105 Flight Crewmembers at Stations No human will be aboard the SUAS operated by CSCG , however, the FAA has held in previous petitions that relief is not necessary. 91.109(a) Flight Instruction CSCG will conduct flight training in accordance with the guidance and limitations offered in this document, as well as the Operations & Flight Manuals attached as appendices to this document. The FAA has held in previous petitions that relief is 91.119 Minimum Safe Altitudes Request relief within limitations and restrictions proposed herein, specifically in Section 4. 91.121 Altimeter Settings Each of the SUAS CSCG proposes to operate measure altitude with both barometric pressure sensors and GPS. Prior to each flight, the barometric altimeter will be set to 0ft AGL instead of the setting of the nearest reporting station. CSCG holds that by counting altitude in AGL, zeroed at the point of departure, will ensure conformance to the COA restrictions under which the SUAS is operating. Given the low operating altitudes of system and operating within the proposed restrictions, relief is requested.14

91.151 Fuel Requirements in VFR Conditions As described in this document, the SUAS CSCG proposes to operate have total endurance of between 20 and 30 minutes. CSCG will ensure missions are conducted with sufficient reserve to operate for at least five minutes after the intended mission is complete. The short flight time makes 91.203 Certifications Required CSCG LLC will place these documents at the location of the ground station and/or with the PIC. The FAA has previously held that this is sufficient to provide an equivalent level of safety, and 91.405 Maintenance Required Relief is requested within the limitations and conditions set forth in Section 2.2 of this document. 91.407 Operation After Maintenance Relief is requested within the limitations and conditions set forth in Section 2.2 of this document. 91.409 Inspections Relief is requested within the limitations and conditions set forth in Section 2.2 of this document. 91.417 Maintenance Records Relief is requested within the limitations and conditions set forth in Section 2.2 of this document. **Section 6: Public Interest & Equivalent Level of Safety**  Though this is addressed in pieces of this petition, a more complete answer is provided in this section. CSCG proposes certain 14 CFR exemptions to allow commercial operation of its small unmanned aircraft systems for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, inspections, data collection, security monitoring, search and rescue, public safety, search and rescue, first responder and emergency response support and other flight operations, so long as such operations are conducted within and under the conditions outlined herein. Traditional agricultural operations such as crop inspections and data collections under the current regulatory structure include the use of manned aircraft, which are expensive, inefficient and cannot be safely operated in close proximity to the ground. By using SUAS to complete these missions the public interest is served by increasing safety to pilots, passengers and non-participants on the ground.15

Traditional industrial infrastructure inspection operations under the current regulatory structure are often performed 1) from the ground, where high detail is impossible 2) by a climber at great risk to his or her personal safety, or 3) by a manned aircraft where flying close to elevated infrastructure is extremely dangerous, and not permitted by 14 CFR 91.119. Traditional public safety, security (such as facility perimeter monitoring), first responder, natural resource management , search and rescue, and emergency response/emergency management flight operations under the current regulatory structure include the use of manned aircraft, which are expensive, inefficient and can pose significant risks to the aircrew, property and structures and persons on the ground when being operated in close proximity to the ground. By using SUAS to complete these missions the public interest is served by increasing safety to pilots, passengers and non-participants on the ground while increasing availability and responsiveness due to the lower cost of equipment and operations. Grant of exemption, with the conditions and limitations set forth herein, to CSCG , will provide for at least an equivalent or better level of safety, reduce risk to life and property, thereby serving the public interest. **Section 7:**  **Summary of**  **Exemption Request**  **for the**  **Federal Register**  In accordance with 14 CFR 11.81 and Section 333 of the FAA Modernization and Reform Act of 2012, P.L

. 112

- 95, Community Safety Consulting Group (CSCG) seeks exemption from the requirements of 14 C.F.R **§§** Part 21, Subpart H, 45.23(b), 61.23(a), 61.101(e)(4& 5), 61 113(a) & (b), 61.133(b), 61.315(a), 91.7(a), 91.9(b)(2) & (c ), 91.103, 91.105, 91.109(a), 91.119, 91.121, 91.151, 91.203, 91.405, 91.407, 91.409 and 91.417 to operate small unmanned vehicles weighing 55lbs or less for commercial purposes. **Section 8: Compliance with 14 CFR**  **11.81** 14 CFR 11.81a

– Published on Cover Page. 14 CFR 11.81b

– Please see Section 5. 14 CFR 11.81c

– Please see Sections 2, 3, 4 and 5. 14 CFR 11.81d

– Please see Section 6. 14 CFR 11.81e

– Please see Section 6. 14 CFR 11.81f

– Please see Section 7. 14 CFR 11.81g

– Please see Appendices 1

- --4. 14 CFR 11.81h

– Not applicable. Approval of these exemptions will allow CSCG to conduct safe, commercial operation of small unmanned aircraft for the purposes of aerial photography, cinematography, videography, mapping, crop surveying, inspections, data collection, security monitoring, public safety assistance , search and rescue, first responder and emergency response support and other flight operations.16

**Appendix 1: Sentera Phoenix UAS Pilot Operational Handbook Appendix**  **2: Sentera**  **Phoenix A1,**  **Phoenix M1, Vireo Pre** **- Flight**  **C hecklist**  **Appendix 3: Lockheed Martin Procerus Technologies Indago User Guide v1.1** Lockheed Martin considers these documents to be proprietary information and prefers to keep this confidential. To make it available for review, it has been sent to 333exemptions@faa.gov with the comment tracking number included in the email. Please contact ftaylor@dc.rr.comwith questions or concerns. **Appendix 4: Lockheed Martin Procerus Technologies Indago Flight Checklist** Lockheed Martin considers these documents to be proprietary information and prefers to keep this confidential. To make it available for review, it has been sent to 333exemptions@faa.gov with the comment tracking number. Please contact ftaylor@dc.rr.com with questions or concerns. **Appendix	5 :	DJI	Phantom	Operations**  **Manual Appendix	6**  **:	DJI	Insp ire	Operations	Manual**  **Appendix	7 :	DJI	Inspire	Maintenance**  **Manual Appendix	8**  **:	DJI	Insp ire	Safety	Guidelines**  **Appendix	9 :	DJI	Phantom	Safety**  **Guidelines Appendix	10**  **:	DJI	Intelligent	Flight	Battery	Safety Guidelines**  **Appendix	11 :	DJI	Phantom	Pilot	Training**  **Guide**