February 28, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of Mynampaty Enterprises Inc. DBA QEDrones for Exemption Pursuant to Section 333

of the FAA Modernization and Reform Act of 2012.

Attachments: ​These attachments are too large for submission via the submission portal.

They are available at the following websites for viewing or download.

DJI Phantom 3

http://www.dji.com/product/phantom­3/download

● Phantom 3 Professional User Manual (EN) v1.2

● Phantom 3 Professional Quick Start Guide (EN) v1.2

● Phantom 3 Advanced User Manual (EN) v1.2

● Phantom 3 Advanced Quick Start Guide (EN) v1.2

DJI Inspire

http://www.dji.com/product/inspire­1/download

● Inspire 1 Quick Start Guide (EN) v1.2

● Inspire 1 User Manual (EN) v1.4

3DRobotics Solo

http://3drobotics.com/kb/solo­user­manual/

3DRobotics Iris+

http://3drobotics.com/wp­content/uploads/2014/10/IRIS­Plus­Operation­Manual­vE­web.pdf

References:

1. FAA Exemption No. 11138, Regulatory Docket No. FAA20140481in the matter of the

petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the

petition of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Exemption No. 11080 Regulatory Docket No. FAA­2014­0355 in the matter of the

petition of FLYING CAM INC
To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

Mynampaty Enterprises Inc. (MEI), hereby applies for an exemption from Federal Aviation

Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial

system (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for exemption, the above

referenced, the DJI sUAS manufacturer's operations and/or instructions manual, DJI sUAS

User’s Manuals, DJI sUAS Quick Start Guides, 3D Robotics’ User Manuals, and any other

requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation by MEI, which uses the DJI Phantom 3 and

Inspire1 models and 3DR Solo and Iris+ to conduct sUAS flight training, STEM education,

agricultural and conservation research, aerial photography and cinematography, real estate

photography and videography, local promotional photography and videography to promote

tourism, news gathering, fire and rescue, support of fire department and law enforcement

activities, crop surveying, demonstration flights and inspections, and other flight operations.

MEI’s operation under the exemption will be subject to strict operating requirements and

conditions to ensure safety at all times and under conditions as may be modified by the FAA as

required by Section 333.

MEI drones will be operated under controlled Visual Flight Rules (VFR) conditions at low altitude

in airspace that is permitted in accordance with MEI's approved Certificate of Authorization

(COA). Finally, the FAA Air Traffic Control (“ATC”) will approve the airspace in which the sUAS

will operate in advance.

MEI respectfully submits this request for an exemption because it wishes to operate sUASs. The

operations MEI will be conducting will be in lieu of comparatively hazardous and inefficient

operations now conducted by others using fixed wing and rotary conventional aircraft. The FAA

can have confidence that the operations will be conducted at an equivalent level or greater level

of safety than those providers. Approval of this exemption would thereby enhance safety and

fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section

333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft

systems in the national airspace system.”

For your convenience, MEI has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest
VII. Privacy

VIII.Federal Registry Summary

IX. Conclusion

I. Petitioner's Description

MEI, headquartered in Southborough, Massachusetts, is a company that wishes to provide

sUAS support to news services, aerial photography and videography, local promotional

photography/videography, flight training, STEM education, fire and rescue, and aerial

inspections in a compliant and safe environment. MEI plans on providing a wide range of

services as the sUAS market expands.

MEI's goal is to operate in an accident­free environment by:

• Demonstrating a commitment by the petitioner to operate in a compliant manner.

• Identify hazard and risk while eliminating or controlling all these risks. Petitioner will

intervene and report when unsafe work practices or conditions appear to exist.

• Train all support personnel involved in flight operations to perform at the highest

standards.

The contact information for Petitioners is as follows:

Ravindra Mynampaty, President

Mynampaty Enterprises Inc

6 Sarsen Stone Way

Southborough, MA 01772

Cell: 508­919­6611

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a)

through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned

aircraft systems (“UAS”) may operate safely in the National Airspace System ("NAS") before

completion of the

formal UAS rulemaking, based on the following considerations:

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

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

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

Note:​MEI's submission places a duty on the Administrator to not only process applications for

exemptions under Section 333, but for the Administrator, if he deems the conditions proposed

herein require modification in order to allow approval, to supply conditions for the safe operation

of the sUAS. MEI welcomes the opportunity to consult with FAA staff in order to address any

issues or concerns that this proposal may raise that they believe may require modification.
If the Secretary determines that such vehicles "may operate safely in the National Airspace

System, the Secretary shall establish requirements for the safe operation of such aircraft in the

National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards when the Administrator decides a requested exemption is

in the public interest. A party requesting an exemption must explain the reasons why the

exemption:

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it

would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. See 49

U.S.C. § 44701, which provides:

The Administrator may grant an exemption from a requirement of a

regulation prescribed under subsection (a) or (b) of this section or any of sections

44702–44716 of this title if the Administrator finds the exemption is in the public

interest.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, from the requirement that all civil aircraft must have a current

airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in

commercial service.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under

Section 333 of the Reform Act.

The proposed operations would permit MEI the use of sUAS under controlled conditions in

airspace that is: (1) predetermined; and that (2) provides an increased level of safety beyond

that existing when fixed or rotor wing aircraft are used by others to accomplish the same

purpose.

MEI will use sUASs that are multirotor, weighing less than 25 pounds including payload. They

will operate, under normal conditions, at speeds not to exceed 50 mph. The multirotor has the

capability to hover and move in the vertical and horizontal plane. MEI’s sUASs will operate in

line of sight and during daylight hours. MEI will operate at or below 400 feet above ground level

(“AGL”). All required permissions and permits would be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies prior to operating a sUAS.

Given the small size of the sUAS involved and the environment within which they will operate,

MEI’s exemption falls within the zone of safety and demonstrates an equivalent level of safety,
in which Congress desired the FAA to permit commercial UAS operations by exemption pending

completion of formal rulemaking. Also, due to the size of the sUAS and the confined area in

which the sUAS will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed

operations, and the significant public benefit, the grant of the requested exemptions is also in

the public interest.

IV. Description of Proposed Operations

To assist the FAA in its safety assessment of MEI's proposed sUAS operations, below is

a summary of operational limitations and conditions that will ensure an equivalent or higher level

of safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the Pilot in Command (“PIC”) and visual

observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time

the sUAS can be flown and still maintain a reserve battery power of no less than 25%.

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

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited

structures, buildings, vehicles, vessels, people not associated with the operation or who

have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS PIC (and a Visual Observer

(“VO”)/Camera Operator when appropriate).

7. MEI will designate a PIC for each mission.

8. The sUAS will operate only within a confined safe and uncongested area.

9. Prior to the operations at a particular location, a site inspection will be conducted. On the

day of the mission the MEI manager with operational control and the PIC will concur on

performing the mission after reviewing all safety issue compliance.

10. Prior to initiating each mission a briefing will be conducted in regard to the planned sUAS

operations. It will be mandatory that all personnel who will be performing duties within

the boundaries of the safe and uncongested area be present for this briefing.

11. MEI crew will use a safety and airworthiness checklist.

12. The sUAS will be maintained in compliance with the manufacturer’s guidelines.

13. In the event of an accident involving an MEI sUAS, petitioner will cease operations and

report the accident to the NTSB and AFS­80.

14. PIC and VO will at all times be able to communicate by voice.

15. PIC, Camera Operator, VO, and Operational Personnel will have been trained and

tested by the petitioners.

16. All required permissions and permits will be obtained in advance from territorial, state,

county or city jurisdictions, including local law enforcement, fire or other appropriate

governmental agencies.

17. In compliance with approved exemption, MEI management will submit a written “Plan of

Activities” to the local Flight Standards District Office (FSDO) having jurisdiction over the
area of proposed filming three days in advance of operations during film or movie

productions.

18. If the sUAS loses communications signal, the sUAS will have the capability to return to a

predetermined location within the safe and uncongested area.

19. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the pilot and the observer.

20. The sUAS has the capability to abort a flight in case of unpredicted obstacles or

emergencies.

21. MEI will assure no individual’s privacy is violated.

22. Procedures have been established to contact ATC prior to operating in airspace, except

with respect to Exemption G below, which does not necessitate contacting ATC.

V. Regulations From Which Exemption is Requested

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command

(PIC)

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR § 91.113: Right­of­Way Rules

D. 14 CFR § 91.119 (c): Minimum Safe Altitudes

E. 14 CFR § 91.121: Altimeter Settings

F. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in

Command

Section 61.113(a) & (b) limit private pilots to non­commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the DJI and 3DR sUAS’s are remotely

controlled with no passengers or property of others on board. MEI respectfully proposes that the

FAA should take into account the characteristics and procedures of the particular sUAS.

MEI proposes that the actual operation of the DJI and 3DR sUAS does not require the PIC to

hold a private pilot certificate. MEI proposes the following requirements:

• Pilot in Command Requirement

1. The PIC must have accumulated and logged a minimum of five hours as sUAS pilot

with the make and model of sUAS to be utilized for operations

under the exemption and three takeoffs and landings in the preceding 90 days.

2. The PIC must have successfully completed the qualification process as required by

the petitioner, to include a knowledge and skill test.

B. 14 CFR § 91.103: Preflight Action
MEI requests an exemption from the preflight actions requirements of 14 CFR 91.113

that prescribes the preflight actions under which aircraft may operate:

The Petitioner shall, before beginning a flight, become familiar with all available information

concerning that flight.

a) Flight under Instrument Flight Rules (IFR) or a flight not in the vicinity of an airport, weather

reports and forecasts, battery charge levels alternatives available if the planned flight cannot be

completed, and any known traffic delays of which the pilot in command has been advised by

ATC;

b) For every flight, the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing

takeoff and landing distance data is required, the takeoff and landing distance data

contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other

reliable information appropriate to the aircraft, relating to aircraft performance under

expected values of airport elevation and runway slope, aircraft gross weight, and wind

and temperature.

MEI will not operate sUAS’s under IFR conditions, or when the ceilings are below 1000 feet and

the visibility is below 3 statute miles. DJI’s and 3DR sUAS’s do not have published approved

Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data.

Equivalent Level of Safety

The PIC along with the person having operational control must assure that the weather will be

adequate to complete the mission in VFR condition. Since MEI also operates in rural

Massachusetts where the density altitude may exceed 2000 feet, sUAS performance may be

affected. When used in those locations the intended sUAS will be test flown at gross weight to

test performance limitations prior to conducting sUAS operations.

C. 14 CFR 91.113: Right­of­Way Rules

MEI request an exemption from 14 CFR 91.113 Right­of­way rules, requiring vigilance

by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this

section gives another aircraft the right­of­way, the pilot shall give way to that aircraft and may

not pass over, under, or ahead of it unless well clear.

MEI will operate pilotless sUAS’s and cannot comply with these rules as they have been written.

Equivalent Level of Safety

MEI will operate sUAS’s at or below an altitude of 400 feet AGL, well below the normal

operating altitude of other aircraft. MEI specifies that a PIC with experience will perform each

mission and have knowledge of the avoid rules. It’s the responsibility of the PIC to cease

operations and land the sUAS immediately whenever an aircraft comes into the vicinity creating
a potential threat or safety concern. Operations will not recommence until the potential threat is

clear or safety concern has been resolved.

D. 14 CFR. § 91.119: Minimum Safe Altitudes

MEI requests an exemption from the minimum safe altitude requirements of 14 CFR

91.119 that prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000

feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer

than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when

it can be operated "without hazard to persons or property on the surface," provided that "each

person operating the helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA."

To provide the intended operations, the sUAS is normally operated below 400 feet AGL.

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral

distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from

people not associated with the operation.

Equivalent Level of Safety

Compared to flight of normal aircraft, MEI’s multi­rotor aircraft weigh a maximum of 25 pounds,

and given the lack of flammable fuel, any risk associated with these operations is far less than

those that presently exist with conventional aircraft. An equivalent level of safety will be

achieved given the size, weight, and speed of the sUAS, as well as the location where it is

operated. As set forth in the Operations Manual, the sUAS will be operated in a safe and

uncongested area, where buildings and people will not be exposed to operations without their

pre­obtained consent. Because of the advance notice to the property owners and participants,

all affected individuals will be well aware of the planned flight operations.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that

are subject to the minimum safe altitude regulations. Finally, the successful safety record of the

DJI and 3DR sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes

and closer operating environments.

E. 14 C.F.R. § 91.121: Altimeter Settings

MEI seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of
the departure airport or barometric pressure. An exemption is required because the sUAS does

not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following these procedures:

1. MEI will confirm the altitude of the launch site shown on the GPS altitude indicator before

flight.

2. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the sUAS's

height, thus ensuring operation at safe altitudes.

F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

MEI requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

a) No person may begin 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 speed –

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering MEI's sUAS’s provide approximately 20­25 minutes of powered

flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be

conducted. Given the limitations on the sUAS's proposed flight area and the location of its

proposed operations within a predetermined area, a safety margin based on a reserve amount

of battery life is needed.

MEI will not be conducting any sUAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on­site

without significant transit time by the sUAS. All flights will be planned to terminate with no less

than 25% reserve battery power still available. This restriction would be more than adequate to

return the sUAS safely to its planned landing zone from anywhere in its confined area of

operation even in the event of an unexpected occurrence. Operation of the sUAS with less than

30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was

intended to alleviate given the size and speed of the sUAS, and the proximity of the flight

operation to the landing zone. Moreover, operation will be limited to controlled areas where only

people and property owners, or official representatives will be allowed.

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance

Inspections

MEI also seeks an exemption from the maintenance inspection requirements contained

in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a)
(stating that each owner or operator of an aircraft "shall have the aircraft inspected as

prescribed in subpart E of this part and shall between required inspections...have discrepancies

repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which

the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the DJI and 3DR User’s Manuals. The operator will ensure that

the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a

log of any maintenance performed. The operator is the person most familiar with the aircraft and

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight

operations will only take place in pre­designated areas for limited periods of time during daylight

hours, creates less risk than that associated with conventional rotorcraft performing the same

operation.

VI. PUBLIC INTEREST

Granting MEI an exemption furthers the public interest. National policy set by Congress favors

early integration of sUAS into the national airspace in controlled, safe working environments

such as those proposed in this petition. MEI would like to help facilitate safe integration of

sUAS’s into mainstream USA in the following areas:

• Agriculture and Conservation

MEI would introduce and demonstrate to farmers of all types that the sUAS can aid

commercial agriculture, land management and conservation efforts by assessing crops,

mapping flood zones, measuring snowpack and more. The sUAS can fly pre­saved

missions via the fully automated ground station, which allows for time­lapse photos of

fields, crops and known land tracts. It also can accurately recreate the same pattern

during all seasons, providing invaluable data for land and soil management. Using HD

video, HD photos, and IR cameras allows for detailed analysis and recording. With photo

rendering software, 3D maps and topography can be used in conjunction with time­lapse

photos to create highly detailed maps for erosion, flood mapping and other critical

aspects of land management.

• Real Estate

The sUAS can be used in all areas of real estate, including agricultural, vacant land,

commercial, residential and industrial properties. Using a sUAS, real estate

professionals can create promotional videos, photos and unique shots that normal

camera aspects cannot capture. The remote platform is great for new planning, zoning
and large developments. Simple and easy­to­use video and photos allow for multiple

height pictures and elevation views.

• Movies, Videography, and Cinematography

Whether the shot requires unique views and expansive panning or extreme altitude with

radical views, the sUAS is designed to hold up under demanding conditions. Because of

the autopilot feature with pre­designed mission management and R/C control interrupt,

the pilot and camera operator can easily create the ultimate shot with HD video or HD

still photos. When working close in on a closed set the hazards to the actors are greatly

reduced due to the size of the sUAS.

• News Gathering

Similar to movies and videography, each news assignment may require a completely

different shot or view of a scene. With budgets for traditional helicopter use being greatly

reduced, the sUAS is the perfect solution to allow for easy news gathering for a fraction

of the cost. The sUAS can and will be operated in a safe manner away from the public,

while the traditional helicopter must hover over persons and property increasing the

danger to individuals.

• Fire and Rescue

MEI would introduce and demonstrate to fire and rescue personnel the sUAS’s

reliability and the capability to perform in extreme situations. The ability to offer real time

HD and IR video facilitates placing personnel and equipment in the right places. MEI's

mission is to assist governmental agencies safely into the NAS.

● Aerial Inspections

MEI will use sUASs to conduct aerial inspections for scenarios such as assisting utility

companies to assess conditions of power and communication lines, aiding public and

municipal officials to survey land and properties, helping construction and geological

projects to manage site operations efficiently by providing key reconnaissance data, etc.

Using HD video, HD photos, and IR cameras allows for detailed analysis and recording.

With photo rendering software, required details can be obtained aerially to allow for

efficient management of resources and operations.

● Flight Training

MEI will use sUASs to train interested parties to pilot sUASs in a safe manner. The

pilot training will teach participants how to operate and control the sUASs to achieve the

purpose of the flight, be it for purposes of aerial inspections and photography, fire and

rescue, agriculture and conservation, public safety, etc. MEI’s mission is to be an expert

resource in helping those interested in operating sUASs to master the piloting of sUASs

in a manner that is safe and follows the guidelines set by FAA and related agencies

safeguarding public privacy and safety.
● STEM Education

MEI will use sUAS’s to teach children and adults alike STEM fundamentals to

gain a deeper understanding and appreciation for the science, mathematics, engineering

and programming and technology involved in the development and operation of sUAS.

Since sUAS are equipped with onboard, high resolution video cameras, students can

also learn to express their creativity through video productions. sUAS are excellent tools

for educators to instill and encourage students to explore concepts related to science,

technology, engineering, and mathematics (STEM); disciplines that continue to be vital

for sustained technological innovation leadership for USA.

VII. Privacy

MEI knows that many individuals have concerns about privacy from the operations of sUAS’s.

MEI has created and will use a privacy notice that informs residents, commercial property

owners, churches, schools, and governmental organizations of our intent to conduct commercial

drone operations in proximity to their property.

VIII. Federal Registry Summary

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:

MEI seeks an exemption from the following rules:

14 CFR Part 61.113 (a) and (b); 14 CFR 91. 103; 14 CFR 91.113; 14 CFR 91.119; 14 CFR

91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR; 91.409(a)(2); 14

CFR 91.417(a) and (b).

Approval of this exemption request allows MEI to conduct commercial operations with

small and lightweight unmanned aerial systems. MEI's vision is to enhance safety of sUAS

operations in the NAS while reducing risk to the general public and property owners.

The DJI and 3DRobotics sUAS, weighing less than 25 pounds and powered by batteries,

eliminates virtually all of the risk given the reduced mass and lack of combustible fuel carried on

board. The sUAS is transported to the designated mission area and set up there. 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 this sUAS will provide an equivalent level of safety, supporting the grant of the

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

several regulations and allowing commercial operations. These lightweight sUAS's operate at

slow speeds, close to the ground and in a safe and uncongested environment. As a result, they

are far safer than conventional aerial survey and inspection operations conducted with fixed

wing aircraft or helicopters.
If additional information is required, or if you have any questions regarding this Petition for

Exemption, please contact the undersigned.

Ravindra Mynampaty, President/Petitioner

Mynampaty Enterprises Inc

Cell Phone: 508­919­6611

Email: ravi@qedrones.com