1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

February 2 5 , 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") , 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Gresco Utility Supply ("Gresco") hereby petitions for exemption to operate s mall Unmanned Aircraft Systems ("sUAS") in order to conduct aerial data collection as described in this petition. Gresco desires to operate sUAS in connection with the construction, operation, repair and maintenance of utility infrastructure and assets

. Gr esco specifically seeks an exemption from the Federal Aviation Regulatio ns ("FARs") listed in this petition

. This request is substantially similar to other data collection petitions previously approved, and should be considered under the expedited summary grant procedure.

I. Petitioner

Gresco was founded in 1960 and is headquartered in Forsyth, GA. Gresco currently provides goods and services to commercial and utility customers, and intends to provide goods and services related to
unmanned aerial system s.

All communications regarding Gresco's petition should be directed to:

Rusty Ortkiese with CC to: Chad Capps Gresco Utility Supply Gresco Utility Supply
1135 Rumble Road 1135 Rumble Road Forsyth, GA 31029 Forsyth, GA 31029 Rusty.Ortkiese@Gresco.com CCa pps@Gresco.com1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

II. Regulations F rom Which an Exemption is Sought

• 14 CFR Part 21, Subpart H

• 14 CFR 61.23(a) and (c)

• 14 CFR 61.101(e)(4) and (5)

• 14 CFR 61.113(a)

• 14 CFR 61.315(a)

• 14 CFR 91.7(a)

• 14 CFR 91.119(c)

• 14 CFR 91.121

• 14 CFR 91.151(a)(1)

• 14 CFR 91.405(a)

• 14 CFR 91.407(a)(1)

• 14 CFR 91.409(a)(1) and (2)

• 14 CFR 91.417(a) and (b)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited oper ating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 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 requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor passenger, carries n o explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the require ments and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with ai rworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pil ots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set forth in the FOM will equate to the safe operation o f the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exempti on be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or a ltitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, a n exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained

con sent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or
local officials. Because of the advance not ice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the max imum 55lbs. proposed herei n and the lack of flammable fuel, any risk associated with these operations i s far less than those presently presented with conventional aircraft operating at or below 500 AGL . In addition, the low

- altitude operations of the UAS will ensure separation betw een these UAS o perations and the operations of conventional aircraft that must comply with Section 91.119.1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cr uising altitude by reference to
an alt imeter that is set “...to the elevation of the departure airport or a n appropriate altimeter setting available before departure.” As the UAS may not have a barometr ic altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in a n airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During th e day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flig ht area and the location of its proposed operations within a predetermined area, a longer t ime frame for flight in daylight or twilight
VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where onl y people and propert y owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed
of the small UAS. Additio nally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power

— whichever h appens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in sub

- part E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed i n part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Main tenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

UAS is very limited in size and will carry a small payload and operate only in restricted areas fo r a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure
that the UAS is in working order prior to initiating flight and perform required maintenance needed.

III. Equivalent Level of Safety

Gresco sUAS operations will provide a level of safety that exceeds the level of safety required by the FAA for hobbyists and man ufacturers of model aircraft. The following operating procedures will apply during the sUAS operations under this exemption request.

1. Gresco operations will be conducted:

a. Within the visual line of sight of the Pilot in Command (PIC) and one or more V isual
O bservers (VO).
b. A t less than 400 feet AGL

.
c. Within class G airspace.
2. Gresco operations will be conducted in a confined area over isolated private property located at least 5 miles away from any airport, heliport, seaplane base, spaceport or other location with aviation activities, and any military or U.S. government installations or airfields. If we are within
th e 5 mile radius of any of the above installations Gresco will seek written approval from that installation's owner before sUAS operations take place. If said installation owner requires stricter guidelines for operation then Gresco will comply.
3. All sUAS op erations will remain within the lateral and vertical boundaries of the operating area, taking into account all factors, including wind, gross weight and glide distances, that may affect the capability of the sUAS to remain within the airspace boundary; mor eover, the ceiling height
will be no more than 400 feet AGL.
4. Gresco sUAS operations under this exemption will be conducted under the supervision of the designated PIC who ultimately has final responsibility for the operation

. 5. PIC will maintain the sUAS sys tem in a condition for safe operation, and conduct a pre

- flight inspection prior to each flight so as to ensure that the sUAS, control station, data link equipment, camera, and support equipment are in a condition for safe operation and in a configuration appropriate for the purpose of the intended flight.
6. The PIC and VO will maintain two

- way communications with each other during all operations ; if
unable to maintain two

- way communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the operator will immediately conclude the operation.

7. Each sUAS that Gresco will employ under this exemption will safely return automatically to a
home location designated by the PIC if the communications link is lost.1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

8. The aircraft documenta tion required by 14 C.F.R. §§ 91.9 and 91.203(b), as applicable, will be available to the PIC referred to above at any time Gresco sUAS are operating.

Gresco will effectively operate under our own standard operating procedures that will provide
additional safeguards that go beyond the level of safety for public model airplane fields.

IV. Public Interest

This exemption application is expressly submitted to fulfill Congress' goal in passing section 333(a) through (c) of the FMRA . This law directs the Secretar y of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress's intent of
all owing UAS to operate with significant safety precautions i n low risk environments.

The use of sUAS on various site conditions can significantly reduce the risk to workers of falls wh i le inspecting, surveying, or monitoring a site. sUAS can inspect, photogr aph, and collect data on hard to

access areas that otherwise would require worker access

. R educing falls through sUAS use for site imaging could save workers lives.

Additionally, sUAS could replace the use of helicopters and small aircraft to perform these intended tasks. The sUAS propose d in this petition are under 55 pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. A move to sUAS from helicopters and airplanes presents a marked safety increase for workers and the public.

Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection. sUAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operatio n of small aircraft that are several hundreds times heavier.

V. Proposed Operations

Commercial operation of sUAS, as described herein, would operate in the following manner:

1. Aerial inspection/photography of utility infrastructure including but not limited to electrical power lines, solar generation, wind turbines and communication towers.
2. Aerial photography and/or video including engineering, mapping, land surveying, and other related professional activities.
3. Aerial video/photography to assist with storm an d disaster assessment and restoration.

4. Training to persons and organizations that have use and application of a sUAS.1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

Appendix A: Make and Model of Aircraft for Proposed Operations



### 3DRobotics Solo 3DRobotics X8+ 3DRobotics Iris Aeryon Scout Aeryon SkyRanger Altura Zenith Blade 350QX3 Blade Chroma DJI Inspire DJI Inspire 1 DJI Inspire 2 DJI Phantom DJI Phantom 2 DJI Phantom 2 Vision+ DJI Phantom 3 DJI Phantom 4
DJI S800
DJI S900
DJI S1000+ DJI Agras MG

- 1
DJI Matrice 100 Draganflyer Guardian Draganflyer X4

- P Draganflyer X4

- ES Draganflyer Commander Gryphon Dynamics X8 PrecisionHawk Lancaster
Prioria Hex
Prioria Maveric SenseFly eBee SenseFly eXom SkyCatch Yuneec Tornado Yuneec Typhoon1135 Rumble Road Forsyth, GA 31029 Tel: 478.315.0850 Rusty.Ortkiese@Gresco.com

Appendix B: Summary Statement for Federal Register

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

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 operate commercially a small unmanned vehicle (55lbs or less) for the purposes of aerial data co llection in connection with the construction, operation, repair and maintenance of utility infrastructure and assets.

Approval of exemptions allowing these particular commercial operations of sUASs will enhance safety by reducing risk. Conventional aerial data collection require fixed wing aircraft, rotary winged aircraft or qualified climbers to work on or around electrical and other hazards. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk give n the reduced mass and lack of combustible fuel carried on board as well as limiting risk to personnel. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of s mall UASs, weighting less than 55 lbs., conducted in the conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and a llowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with manned aircraft operating in close proximity to the ground and people.