22-Sept-2015

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

Re: Exemption Request Section 333 ofthe EMReform Act and Part 11 ofthe 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 orMadam: ,-,·;,

; '···

Pursuant to Section 333 ofthe FMModernization and Reform Act of2012 (tlve Reform Act) and 14 C.F.R. Part 11, EmergentTechnologies LLC

.. hereinafter refereed t•o as Emergent, builder and operator ofSmall UnmannedAircraft Systems**("sUASs'~),** hereinafterrefereed 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 ofits UAS, so long as such operations are conducted within and under the conditions outlin•ed herein or as may be established by the FMas required by Section 333. As described more fully below, the requested exemption would permit the operation ofsmall, 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 ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FM Administrator's) responsibilities to"

... establish requirements for the safe

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operation ofsuch aircraft systems in the national airspace system." Secti«>n 333(c) ofthe ReformAct.

The name and address ofthe 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 submittedto fulfill Congress' g01alin passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to co.ns:ider whether certain unmanned aircraft.sy.stemsmay oper-ate safely in the national airspace system (NAS) before completion ofthe rule-making required under Section 332 ofthe Reform Act. In making this determination, the Secretaary is required to determine which types ofUAS do not create ahazard to users ofthe: NAS or the public orpose a threat to national security in light ofthe following:

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

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• Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS wjthin yjguaJ Jine ofsjgbt ofthe operator_

ReformAct§ 333 (a). Lastly, ifthe 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 §40101 ofthe Act, that includes UAS, from the requirememt that all civil aircraft must have a current airworthiness certificate. The Administratormay grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe 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 1UAS, a quad-copter aircraft, conatructed 

## \)"jon withfOO& (4)**t~~%~**fOO& (4)**~fb**

## m**a~ ~ft...~\~** (}{4), with a max gross weight ofseven (7) or fewer lbs. including payload and with serialt#AXOOl. The UAS will operate, under normal conditions at a speed ofno 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 ofsight ofUAS and will follow prccedures described in the confidential EmergentAerial 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 ofthe national airspace system or the public. Given the small size ofthe UAS involved and the restricted nature in wh:ich it will operate, the applicant falls squarely within that zone ofsafety (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 ofthe UAS and the nature in which the relevant UAS will operate, approval ofthe 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 ofsafety 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 ofthe reqthestedexemptions 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 ofsafety to operations under tbe currentregufatory structure. ·meproposedoperations 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 Emergentagrees 

### to bebound when conducting commercial operations under .an FAA issued exemption include:

2. The UAS will be operated at an altitude ofno 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 ofSight (VLOS) ofthe PIC at all times. This requires the PICto be able to use human vision unaided by any device other than corrective lenses.


### 5. All operations will utilize aVisual Observer (VO). The UAS will be oper·ated within VLOS ofthe VO at all times. The VO may be used to satisfy the VLOS requirement as long as thePIC 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 ofthe flight. ihePlC will ensure that the VO can perform the functions prescribed inthe AOH.
6. The AOH and the grant ofexemption 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).

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8. ANotice to Airman (NOTAM) will be issued not less than 24 hours in advance, prior to flight operations unless: (a) request has been made to Emergentby law enforcement, first responder or exigent circumstances exist that would preclude data collection iftprompt action is not taken and a wavier to the 24 hourNOTAM requirement has been given to Emergentby the controlling AirTraffic 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(), ControlledAirport-TheUAS will not operate within five (S) nautical miles·ofan airport reference point as denoted on a current FAA-published aeronautical chart unless:

(a) Prior approval has been givenby the controllingATO and two**wa~il** radio communication has been established with that controlling ATO prior to/and maintained during,the flight. Adeviation request (ifre{\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 offthe extended center line ofthe active runway unless 1l,iven.clearance fromthe 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 orwhen 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. Ifthe UAS loses communications or loses its GPS**signa~** 

### itwill return to apredetermined location within the planned operating area and land orbe 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% batterypowerremainjng.
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 ofthe UAS will comply withthe 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 ofthe UAS any time the UAS is operating. These documents willbe 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 ofthe risk ofoperating 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 ofan accident. The operator will ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 150 feet ofthe UAS, flight operations will cease immediately and/or; (b) The aircraft is operated near vessels, vehicles or structures where the owner/ controller ofsuch vessels, vehicles or structures has granted pennission orthe PIC has made a safety assessment ofthe risk ofoperating 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 overprivate 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 ofairworthiness 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 SubpartH meets the requirements of

### an equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 {f)) and Section 333 ofthe Reform Act both autlllorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports andpopulated areas oftheparticular UAS. In all cases, an analysis ofthese 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'DledWlng tlll\'A\'Jl'Cl'bft)**~\~**wi\han.**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, andoyerates as. setoutinth£ AOR.. Uulik.e other civitaircraft, 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 ofoperation as is now done 

### with conventional operations. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with these types ofoperations, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part21, SubpartH. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to

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2.For which an Airplane or Rotorcraft Flight Manual is not ifequired by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, andplacards, or any combination thereof. The UAS, given its size and configuration has no ability orplace to carry such a flight manual on the aircraft, not only because there is no pilot on board, butbec:ause therei".no.ronm nr c.apacizy to c.aoy

### ..siJcll BD .item nn the .aircr.aft. The equivalent level ofsafety will be maintained by keeping the flight manual at the groond**~~ttcl ~t** w\\u'et\\<e**~\k,t f\~** 

### tM- UA.S wi\\WA"i'e**~~\~tte ~ess** to

### it. The FAAhas 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 offlight. As FAA approved flight manuals will not be provided for the**air~craft** an exemption will be needed. An equivalent level ofsafety will be provided as set forth in theAOR The.PJC wiD take .all .actions including.revjew.ing we.a.ther,..flightb.at:tery requirements, landing and takeoffdistances and aircraft performance data**befor~** initiation offlight. 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 instructionunless 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 ofa control box that co.mmllJlicates wjtb the .aircraft vjaradio 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 equivalentlevel ofsafetyprovidedbythe fact that neither a pilot no•r passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribe·<!,its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load.
14 C.F.R. § 45.23 (b). Marking oftheAircraft 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 orprovisionally 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 incheshigh, 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 orpilot station on which the word "ExQerimental" can be Qlaced. Given the size ofthe 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 ofsafety 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 UAV willsee the identification.ofthe UAS as "ExQerimental" The FAAbas 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 itis in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, shouldthis exemption be granted, no FAA regulatory standard will exist for dete·rmining airworthiness. Given the size ofthe aircraft and the requirements contained in theAOH for maintenance and use ofsafety 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 FlightManualin theAircraft. 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 .andtb.e exemptinn**.r.eqn.e.st.~**JJJ.Jib.ru:izy to qrer_ate at**.altit.ude..~** J.\0 to200 A GL

..As .setforth herein, the UAS will never operate at higher than 200 AGL. 1\.\eequivakn.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 ofthe property owner or local officials. Because ofthe 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 ofthe planned flight operations 

### as set forth inAOH. Compared to flight operations with aircraft orrotorcraft weighing far more than the maximum seven (7) lbs. proposed hereim and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircrart operating at or below 500AGL in similar industry. In addition, the low-altitude operations ofthe UAS will ensure separati<>n between these UAS operations and the operations ofconventional aircraft that \\"ill comply with Section 91.119.
14C.F..R. §91;121 AltimeterSettings This regulation requires each person operating an aircraft to maintain cruising altit\W&. by**1:~f~~ t~**  an.**a\ti\1\'et~** thati'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 ofsafety 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 "aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended 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 

### batterypowering the VASprovides 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.

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Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to nine (9) minutes or 25% ofbattery power whichever happens first. Thi:s re.strictjon would he 

### mare than .adequate 

### to retum the UAS 

### tojt.sp.lannt'.d landing 2.one from anywhere in its limited operating area. Sum\w**t-~t-mpt~ h.a--v~** treengran.tt-d**'~ ~t** **'\)}Yen~,~\~ B~t-~~**  2689F, 5745, 10673, 11138 and 10808. 

### 14 C.F.R. 

### §91.:Z6J (a) and (b): 

### Carrying 

### CivilAircraft 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) ofthis 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 orplace to carry certification and registration documents or to display them on the UAS.
An equiVltlent

### level ofsarety

### will be 

### achieved bykeepingthese 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. Arepresentative sample ofother 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 ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepanci,es repaired as pre..qcrlbed 

### .inpari 43 ofthis chaprer_-1', and others sbaJJ inspect 

### o.rJ.llJllintain the aircraft in compliance with Part 43. G\--v'e\\**that~ ~~ti\m.**  and¥art4l**aw\~ ~~**  \{)**a~~1aft**...it\\ 'lA\**aiwvoo.b.ine~~** certificate, these sections will not apply to the applicant. Maintenance will be

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accomplished by the operator/PIC pursuant to theAOH. An equivalent level ofs.afety will be achieved because these UAS are very limited in size and will carry a small payload and operate for limitedperiods oftime. Ifmechanical issues arise the UAS can l:and immediately and will be operating from no higher than 200 feet AGL. As providedin the AOH, the operator/PIC will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, andkeep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suitedto maintain the aircraft in an airworthy condition toprovide the egJ.Iivalent level of safety.
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication inthe FederalRegi£te1; should ithe determinedthatQuhlicatioui'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 ofexemptions allowing commercial operations ofUAS in the a.erial photography/cinematography/aerial data collection and UAS pilot training indus:try will**enha~e** safety by reducingrisk.. 0Qeratiouofconventionalaircraft inthese s:ituations., using turbine orpiston powered aircraft, weighing thousands ofpounds, carrying large amounts ofJetA orAvgas fuel, and operating in close proximity to people and sU:ructures present a far greater risk to peopie andproperty 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 payhundreds ofdollars to rent manned aircraft and equipment operators are excluded from obtaining these services. In contrast, UAS flights are ofa shorterduration, they weighing fewer than 55 lbs., and are powered by batteries which eliminates virtually all ofthe above risk given the reduced mass and lack ofcombustible fuel. UAS operations are not starteduntil the operations area is cleared and operations
can be stopped in seconds ifnone participating personnel enter the operations area. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated withmanned aircraftflights.
The operation ofsmall 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 ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight ;aircraft operate at slow speeds, close to the ground, are in a supervised environment and" as a

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result, are far safer than conventional operations conducted with conventional manned aircraft operating in close proximity to the ground and people.