22-Sept-2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the EM Reform Act and Part 

11 of the Federal AviQtion Regulations from 14 C.P.R. 45.23(b);14 

CFR Pf!rt 21:14 CFR 91,7 fa);QLQ (h) f2);Ql.l03(b); 91.1QQ;Ql.ll9: 

91.121:9l.l51(a):9l.203(A) & (b):91.405 (a); 91.407(8) (l): 91.409 

(3) (2):91.417 (a) & (b). 

Dear Sir or Madam: 

,-,·;, 

; '··· 

Pursuant to Section 333 of the FM Modernization and Reform Act of2012 (tlve Reform 

Act) and 14 C.F.R. Part 11, Emergent Technologies LLC .. hereinafter refereed t•o as 

Emergent, builder and operator of Small Unmanned Aircraft Systems ("sUASs'~), 

hereinafter refereed to as UAS equippe-d to conduct aerial photography/cinemat,ography/ 

aerial data collection and UAS pilot training, hereby applies for an exemption Jliropt the 

listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, 

so long as such operations are conducted within and under the conditions outlin•ed herein 

or as may be established by the FM as required by Section 333. 

As described more fully below, the requested exemption would permit the 

operation of small, unmanned UAS under controlled conditions in airspace that is: 

1. Limited 

2. Predetermined 

3. Controlled as to access and.!' 

4. Would provide safety enhancements to the already safe operations in the aerial 

photography/cinematography/aerial data collection and UAS pilot trainimg 

industry present1y using conventionai aircraft. Approvai of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation's (the FM 

Administrator's) responsibilities to" ... establish requirements for the safe 
• 

operation of such aircraft systems in the national airspace system." Secti«>n 333(c) 

of the Reform Act. 

The name and address of the applicant is: 

Emergent Technologies LLC. 

Attn: Ryan D. Bohling 

Email: ryan@f-3films.com 

Address: 299 Woodland Brook Dr., Madison, MS. 39110 

Regulations from which the exemption is requested: 

14 CPR Part 21 

14 C.P.R 45.23(b) 

14 C.P.R. 91.7 (a) 

14 CPR 91.9 (b) (2) 

14 C.P.R 91.103 

14 C.P.R. 91.109 

14 C.P.R. 91.119 

14 C.P.R. 91.121 

14 CPR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CPR 91.405 (a) 

14 CPR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CPR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress' g01alin 

passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to co.ns:ider whether certain unmanned aircraft .sy.stems may oper-ate safely 

in the national airspace system (NAS) before completion of the rule-making required 

under Section 332 of the Reform Act. In making this determination, the Secretaary is 

required to determine which types ofUAS do not create a hazard to users of the: NAS or 

the public or pose a threat to national security in light of the following: 

• The UAS size, weight, speed, and operational capability; 
• 

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

and 

• Operation of the UAS wjthin yjguaJ Jine of sjgbt of the operator_ 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "Ill8Ly operate 

safely in the national airspace system, the Secretary shall establish requirements: for the 

.safe oper.atinn .of .such aircr.aft .in the ..natinnaJ.air~e .sy.stem.. '' Jd §3.3.3{ c){~~.s 

added). 

1:\\e fed~t:~~\ A"4\~~ Ad e"%.rne~\".f %t'mt'b ~fAA k ?.v.~V} t~ ~ 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

term is defined under §40 101 of the Act, that includes UAS, from the requirememt that all 

civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) 

See also49 USC §447ll(a); 49 USC §44704; 14 CFR§91.203 (a) (1). 

Emergent plans to operate the Inspire 1 UAS, a quad-copter aircraft, conatructed 

\)"jon with fOO& (4) t~~%~ fOO& (4) ~fb m a~ ~ft...~\~ (}{4), with 

a max gross weight of seven (7) or fewer lbs. including payload and with serialt#AXOOl. 

The UAS will operate, under normal conditions at a speed of no more than 30 knots and 

have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. PIC will operate only in line of sight ofUAS and will follow prccedures 

described in the confidential Emergent Aerial Operations Handbook (AOH) whi.ch can be 

provided upon request. Such operations will insure that the U AS will .. not create a hazard 

to users of the national airspace system or the public. 

Given the small size of the UAS involved and the restricted nature in wh:ich it will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA mustf by exemption, allow 

commercial operations ofUAS to commence immediately. Also due to the size of the 

UAS and the nature in which the relevant UAS will operate, approval of the app•lication 

presents no national security issue. Given the clear direction in Section 333 of the Reform 

Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the signific~t.nt public 

benefit, including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing UAS for aerial photography/cinematography/ 

aerial data collection and U AS pilot training operations, the granting of the reqthested 
exemptions is in the public interest. Accordingly, the applicant respectfully requests that 

the FAA grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETIY 

The applicant proposes that the exemption requested herein apply to civiJ aircraft 

that have the characteristics and that operate with the limitations listed herein. Tlhese 

limitations provide for at least an equivalent or even higher level of safety to operations 

under tbe current regufatory structure. ·me proposed operations represent a sarety 

enhancement to the already safe photography/cinematography and data collectio·n 

industry operations, conducted with conventional aircraft. 

The limitations and conditions, Standard Operating Procedures (SOP), to which 

Emergent agrees to be bound when conducting commercial operations under .an FAA 

issued exemption include: 

2. The UAS will be operated at an altitude of no more than 200 feet above ground 

level (AGL ). All altitudes reported to ATC will be in AGL. 

3. The UAS will not be flown at an airspeed exceeding 30 knots. 

4. The UAS will 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. 

5. All operations will utilize a Visual Observer (VO). The UAS will be oper·ated 

within VLOS of the 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 will be able to communicate verbally at all times. The PIC will be dt~:signated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. ihe PlC will ensure that the VO can perform the functions prescribed in the 

AOH. 

6. The AOH and the grant of exemption will be accessible during UAS operations 

and made available to the Administrator upon request. 

7. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). 
• 

8. A Notice to Airman (NOTAM) will be issued not less than 24 hours in advance, 

prior to flight operations unless: 

(a) request has been made to Emergent by law enforcement, first responder or 

exigent circumstances exist that would preclude data collection if tprompt 

action is not taken and a wavier to the 24 hour NOT AM requirement has 

been given to Emergent by the controlling Air Traffic Organization (ATO). 

9. Non-ContoUedAirport;.The UAS will not operate within two (2) nautical mites of 

an airport reference point as denoted on a current FAA-published aeronautical 

chart unless: 

(a) radio calls are made on the airport unicorn frequency prior to and during 

flight operations stating PIC's intentions and location. During oper..--ations 

altitudes are limited to 100 ft AGL and PIC wi11 maintain visual separation 

from all aircraft. 

l (), Controlled Airport-The UAS will not operate within five ( S) nautical miles ·of an 

airport reference point as denoted on a current FAA-published aeronautical chart 

unless: 

(a) Prior approval has been given by the controllingATO and two wa~il radio 

communication has been established with that controlling ATO prior to/and 

maintained during, the flight. A deviation request (if re{\uired)._ to o•perate an 

aircraft that is not equipped with a transponder in Class B Airspace has 

been approved. 

(b) Altitudes are limited to 100 ft AGL, PIC will maintain visual sepa:uration 

from all aircraft, and not operate off the extended center line of the active 

runway unless 1l,iven. clearance from the control.ling ATO~ 

11. The UAS will not be operated less than 500 feet below or less than 2,000 :feet 

horizontally from a cloud or when visibility is less than 3 statute miles frcm the 

PIC. 

12. UAS will be flown in the GPS Attitude mode during all operational flights. 

13. If the UAS loses communications or loses its GPS signa~ it will return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the AOH. 
14. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at nonnal cruising speed to the imtended 

landing po.int and land the UAS witll25% battery power remainjng. 

15. All aircraft operated in accordance with this exemption will be identified lby serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markhgs will 

be as large as practicable. 

16. Before conducting operations, the radio frequency spectrum used for operation and 

tiontrol of the UAS will comply with the Federal Communications Coonnission 

(FCC) or other appropriate government oversight agency requirements. 

17. The documents required under 14 CFR 91.9 and 91.203 will be available to the 

PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents will be made available to the Administrator or aay Jaw 

enforcement official upon request. 

r 8. The UAS will remain clear and yield the right of way to ail manned aviatti.on 

operations and activities at all times. 

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

unless: 

(a)The PIC has made a safety assessment of the risk of operating and 

determined that it does not present an undue hazard. 

20. Flight operations will be conducted at least 150 feet from all nonparticipa1ting 

persons, vessels, vehicles, and structures unless: 

(a) Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. The 

operator will ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 150 feet of the UAS, flight operations will cease 

immediately and/or; 

(b) The aircraft is operated near vessels, vehicles or structures where the owner/ 

controller of such vessels, vehicles or structures has granted pennission or 
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, and; 

(c) Operations nearer to the PIC, YO, operator trainees or essential per:sons do 

not present an undue hazard to those persons per§ 91.119(a). 

21. All operations will be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. 

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 operating area associated with the aircraft to be utilized by 

the AppJjcan~ an exemption frOJn 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 autlllorize 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 

'COO~'tn.\i\'11'1?4\ an'tlaft (f'Dled Wlng tlll\'A\'Jl'Cl'bft) ~\~ wi\h an. anw\'lrth~~ c~·ert):fi.'Ca\e 

without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than seven (7) lbs. fully loaded,. carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and oyerates as. set out in th£ AOR.. Uulik.e other civit aircraft, oyerations. under 1thls 

exemption will be tightly controlled and monitored by both the operator/PIC, pwrsuant to 

the AOH's requirements, and under the requirements and in compliance with loc;al public 

safety requirements, to provide security for the area of operation as is now done with 

conventional operations. The FAA will have advance notice of all operations. These 

safety enhancements, which already apply to civil aircraft operated in connection with 

these types of operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness 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 
2.For which an Airplane or Rotorcraft Flight Manual is not ifequired 

by §21.5 of this chapter, unless there is available in the aircraft a 

current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination 

thereof. 

The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but bec:ause 

there i" .no .ronm nr c.apacizy to c.aoy ..siJcll BD .item nn the .aircr.aft. 

The equivalent level of safety will be maintained by keeping the flight manual at 

the groond ~~ttcl ~t w\\u'e t\\<e ~\k,t f\~ tM- UA.S wi\\ WA"i'e ~~\~tte ~ess to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737,8738,9299,9299A,9S65,9565B, 10167,10167A, 10602,32827,and10700. 

14 C.F.R. § 91.103: Preflight action: 

This regulation requires each PIC to take certain actions before flight to insure the 

safety of flight. As FAA approved flight manuals will not be provided for the air~craft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in 

theA OR The .PJC wiD take .all .actions including .revjew.ing we.a.ther,..flight b.at:tery 

requirements, landing and takeoff distances and aircraft performance data befor~ 

initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 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 

functioning dual controls. 

UAS and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

co.mmllJlicates wjtb the .aircraft vja radio crunmunic.at.icm..'\.. Tbe FAA .has .approved 

exemptions for flight training without fully functional dual controls for a numbell' of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos.57'78K & 

~62A. 1he equivalent level of safety provided by the fact that neither a pilot no•r 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

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 prescribe·<!, 
its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, the 

operator will also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words .... )imited, .... ''·restricted,'"· .... )ight-sport, .... 

"experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemptio1n may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

the word "ExQerimental" can be Qlaced. Given the size of the UAV.._ two-inch letttering 

will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAV marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

U AV will see the identification. of the U AS as "ExQerimental" The FAA bas issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167' and 

10167A. 

14 C.FR. §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 exemption be granted, no FAA regulatory standard will exist for dete·rmining 

airworthiness. Given the size of the aircraft and the requirements contained in theAOH 

for maintenance and use of safety check lists prior to each flight, an equivalent l-evel of 

safety will be provided. 

14 C.F.R. § 91.9 (b) (l): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 
provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter 

.and tb.e exemptinn .r.eqn.e.st.~ JJJ.Jib.ru:izy to qrer_ate at .altit.ude..~ J.\0 to 200 A GL . .As .set forth 

herein, the UAS will never operate at higher than 200 AGL. 

1\.\e equivakn.t kv~l ~f 'Daf'Wj wi\\ ~ aclnev'ed g\v~\\ ~ 'D\1.~, w~\g\.\t, ~d ~f th.e 

UAS as well as the location where it is operated. No flight will be taken without the 

pennission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the aerial photography/cinematography/aerial data 

collection and UAS pilot training activity, all affected individuals will be aware of the 

planned flight operations as set forth in AOH. Compared to flight operations with aircraft 

or rotorcraft weighing far more than the maximum seven (7) lbs. proposed hereim and the 

lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircrart operating at or below 500 AGL in similar 

industry. In addition, the low-altitude operations of the UAS will ensure separati<>n 

between these UAS operations and the operations of conventional aircraft that \\"ill 

comply with Section 91.119. 

14 C.F..R. §91;121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altit\W&. by 1:~f~~ t~ an. a\ti\1\'et~ that i'D ~" ... ~ ~ d.~vatkm ~ft\\le ~~~ akpOO. 

or an appropriate altimeter setting available before departure." As the UAS may not have 

a barometric altimeter, but instead a GPS altitude hold, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the AOH and 

safety check list. 

14 C.F.R. § 91.15l(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

syeed- (1) During, the day-> to fly after that for at least 30 minutes; or (2) At nig)ltt-> to fly 

after that for at least 45 minutes." 

The battery powering the VAS provides approximate1y 12 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would 

be limited to approximately nine (9) minutes in length. Given the limitations on the UAS 

proposed flight area and the UAS can be landed within a very short time frame a nine (9) 

minute flight time seems reasonable. 
Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to nine (9) minutes or 25% of battery power whichever happens first. Thi:s 

re.strictjon would he mare than .adequate to retum the UAS to jt.s p.lannt'.d landing 2.one 

from anywhere in its limited operating area. 

Sum\w t-~t-mpt~ h.a--v~ treen gran.tt-d '~ ~t '\)}Yen~,~\~ B~t-~~ 

2689F, 5745, 10673, 11138 and 10808. 

14 C.F.R. §91.:Z6J (a) and (b): Carrying Civil Aircraft Certification and Keg:istration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil ;aircraft 

unless it has within it the following: 

( 1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than seven (7) lbs and is operated without 

an on-board pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. 

An equiVltlent level ofsarety will be achieved by keeping these document's at the 

ground control point where the pilot flying the UAS will have immediate access to them, 

to the extent they are applicable to the UAS. The FAA has issued numerous exennptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

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

These regulations require that an aircraft operator or owner "shall have th at 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepanci,es 

repaired as pre..qcrlbed .in pari 43 of this chaprer_-1', and others sbaJJ inspect o.r J.llJllintain 

the aircraft in compliance with Part 43. 

G\--v'e\\ that~ ~~ti\m. and ¥art 4l aw\~ ~~ \{) a~~1aft ... it\\ 'lA\ aiwvoo.b.ine~~ 

certificate, these sections will not apply to the applicant. Maintenance will be 
• 

accomplished by the operator/PIC pursuant to the AOH. An equivalent level of s.afety will 

be achieved because these UAS are very limited in size and will carry a small payload 

and operate for limited periods of time. If mechanical issues arise the UAS can l:and 

immediately and will be operating from no higher than 200 feet AGL. As provided in the 

AOH, the operator/PIC will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the egJ.Iivalent level of safety. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Regi£te1; should it he determined that Quhlicatiou i'i needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, sULbpart H; 

14 C.F.R45.23(b);14 C.P.R.§§ 91.7 (a); 91.9(b)(2);91.1DJ(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); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmamned 

vehicle (55lbs or less) in aerial photography/cinematography/aerial data collection 

and UAS pilot training operations. 

Approval of exemptions allowing commercial operations ofUAS in the a.erial 

photography/cinematography/aerial data collection and UAS pilot training indus:try will 

enha~e safety by reducing risk.. 0Qeratiou of conventional aircraft in these s:ituations., 

using turbine or piston powered aircraft, weighing thousands of pounds, carrying large 

amounts of Jet A or Avgas fuel, and operating in close proximity to people and sU:ructures 

present a far greater risk to peopie and property than a UAS in the same situation .. 

Manned aircraft have to fly to and from the operations location wasting time ancl 

resources that can be used in obtaining product. In addition, customers who are not 

wealthy enough to pay hundreds of dollars to rent manned aircraft and equipment 

operators are excluded from obtaining these services. In contrast, UAS flights are of a 

shorter duration, they weighing fewer than 55 lbs., and are powered by batteries which 

eliminates virtually all of the above risk given the reduced mass and lack of combustible 

fuel. UAS operations are not started until the operations area is cleared and operations 

can be stopped in seconds if none participating personnel enter the operations area. The 

U AS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UAS, weighting less than 55 lbs., conducted in the 

\::.\>im~ti'\'ii"£ mit\i't"fed aoov-e, w\1\ pi(}~ide, ?U't tq>ui~'t.\tn.t \t'i'tl 'Of ~;;af-et'j <;;U~mg the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight ;aircraft 

operate at slow speeds, close to the ground, are in a supervised environment and" as a 
• • 

result, are far safer than conventional operations conducted with conventional manned 

aircraft operating in close proximity to the ground and people.