P. (787) 644

- 2917

F. (787) 293

- 1008

A. PMB 163 Suite 101

220 Western Auto Plaza Trujillo Alto, PR 00976

info@MicroCopterPro.com

December 30

, 2014

US Department of Transportation and

Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: AMENDMENT to Request of Exemption by t he US Congress PL 112

- 95, 2012, FAA

Modernization and Reform Act

, for safe and responsible commercial use of UAS

. Docket Id. FAA

- 2014

- 0557

Dear US DOT and FAA Officials:

This document is an AMENDMENT to our original  ̈ Request of Exemption  ̈ submitted on August

1 st , 2014. On October 8 we received a letter from the FAA (Docket Id: FAA

- 2014

- 0557

- 0006) in

which we were informed that beginning September 25 , 2014, the DOT

- FAA requires Request ers to comply with the  ̈ Public Guidance for Request s for Exemption Filed under Section 333

.  ̈

We are including all the credentials of our certified pilots with their appropriate airman certificate as prescribed by 14 CFR 61 for the proposed operation

.

We believ e our original Request meets all the requirements established by the US Congress in

PL 112

- 95 . Nevertheless, this AMENDMENT provides additional proof of our compliance with

the current  ̈Public Guidance ̈ and will facilitate the FAA’s evaluation

.

Following the recommendation from the  ̈Public Guidance  ̈ , we have adopted some arg u ments

from the Astraeus’ Request that we believe pertain to our case.

Also to facilitate the evaluation of the FAA

, we have reorganized the content of our Request including the following manuals and documents:Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 2

a. “UAS Flight Operations and Procedures Manual” (FOPM) Appendix A

• “UAS Commercial Flight Register” (UCFR) Appendix A

- 1

• “Permission to Operate Form” (POF) Appendix A

- 2

• “UAS Plan of Activities” (UPA) Appendix A

- 3

• “UAS Request of Authorization to ATC” (URAA) Appendix A

- 4

• “UAS Safety Flight Checklist” (USFC) Appendix A

- 5

• “UAS Crew Flight Log” (UC FL) Appendix A

- 6

• “Liability Release and Consent Form” Appendix A

- 7

b. “UAS Inspection and Maintenance Manual” (UIMM) Appendix B

Forms:

• “UAS Maintenance and Repair LogBook” (UMRL) Appendix B

- 1

• “UAS Fleet Specs and Manufacturers’ Manuals” Appendix B

- 2

c. “UAS Training Manual” (UTM) Appendix C

Form:

• “UC Training Log” (UT L) Appendix C

- 1

d. UAS Crew (UC) Members Personal Data Appendix D

T he DOT

- FAA should use this AMENDMENT as its main point of reference in regards to our Request as it includes the most important aspects of our original  ̈ Request of Exemption .”
Furthermore, This amendment includes additional information required to better comply with the

Public Guidance’s specific requirements and suggestions.

Congressional mandate PL 112

- 95, FAA Modernization and Reform Act, February 14, 2012,

Subtitle B

- Unmanned Aircraft Systems

, integrates Unmanned Aircraft Systems (UAS) into the

NAS by way of special rules.

US Congress used the term "Integration" in distinguishing UAS s as flying objects that are

different from conventional aircraft . Congress resolved that UAS integration i nto NAS must be done by establishing operational and security focused special rules for UAS that a re distinct

from those a pplied to conventional aircraft . These rules should be both reasonable and proportional in recognizing UAS’ characteristics.

It is common knowledge that som e UAS s have capabilities that resemble those of conven tional

aircraft . These capabilities include

, but are not limited to ; some unmanned aircraft’s operational and flying capacitie s outside of the pilot’s visual line of sight , its abilities to reach great altitudes and high speeds

, and its significant size and we ight

. These types of UAS s have a significantly more important and active presence in air traffic. Our UAS s DO ES NOT possess tho se capabilities, therefore these types of concerns do not apply to eith er our Request or to our proposed commercial use.Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 4

Note to US DOT

- FAA Docket Administrator :

For obvious reasons, we ask the US DOT

- FAA to keep the information presented on this application

, owned by our co mpany , as strictly CONFIDENTIAL. The information that we consider CONFIDENTIAL is the following :

1) “UAS Flight Operations and Procedures Manual” (FOPM) Appendix A Including all related documents and forms

2) “UAS Inspection and Maintenance Manual” (UIMM) Appendix B Including all related documents and forms

3) “UAS Training Manual” (UTM) Appendix C Including all related documents and forms

4) UAS Crew (UC) Members Personal Data Appendix D Including all related documents and formsExemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 5



## AMENDMENT to Request of Exemption

by the US Congress PL 112

- 95, 2012, FAA Modernization and Reform Act,

for safe and responsible commercial use of UAS.

Docket Id. FAA

- 2014

- 0557



## Mic roCopter Professional Services Inc.

(MicroCopter Pro)

December 30 , 2014

MicroCopter Professional Services Inc. (MicroCopter Pr o) is submitting this Request as follows:

1. General Request of Exemption: That, taking into consideration that :

a) a ll of our operations will be subj ect to FAA supervision and regulations , and will

never interfere with air traffic and/o r any other government activity;

b) w e are com mitted to comply rigorously with the FAA’s safety measures, the protection of third party rights, and the procedure s that are part of this R equest including the manua ls and risk mitigation procedures ;

c) a forementioned security measures as well as our comprehensive manuals are equivalent to conventional aircraft regulations, and therefore mitigate proportional

and reasonable air and ground safety in what pertains to these small devices;

d) o ur flights would only tak e place under 4 00 feet (AGL), during daytime , far away from airports and congested or populated areas, following strict security measures, within

the PIC visual line of sight (VLOS), with written authorization from the owners of the property in whi ch the activity is taking place and/or written authorization from a government agency. Due to the nature of the services we will offer, most of our flights will take place between 100 and 200 feet (AGL);

e) o ur services benefit the public interest as a whole ;

f) w e have FAA certified pilots and trained specialists with expertise in the maintenance

of UAS s , and we have a workshop specialized in the repair, maintainance, and programming of UAS

- Model A ircrafts and other R/C devices;

g) i n order to address the NAS and national security co ncerns, all our staff has with

necessary credentials and experience to perform their respective tasks ;

h) w e are hereby providing all the specifications for each and every one of our devices that are already ac ceptable in the national market as Model Aircrafts; andExemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 6

i) w e will offer commercial and professional services in a safer, more cost

- effective

, and accessible way than other conventional methods, which are used for these

services

...

...t he DOT

- FAA grant s us authorization to offer profes sional and commercial services using the UAS s specified herein, subject to what is included in this Request and any

other conditions which the US DOT

- FAA understands must be amended or included.

2. Commercial Activities: That , within the condi tions described in this Request and any
others the US DOT

- FAA understands must be included, authorization be granted to us to

use UAS s , as described herein, which are equipped with cameras and sensors, in order to engage in the following professional and commercial activities:

(a) Video filming and photography by air for public and private purposes, including:

televisio n, cinematography, advertising and promotions

, only with the written

authorization of the owners or producers.

(b) Video filming and photography by air to support professional operations in engineering, land surveying, architecture, real estate and other relat ed professional
activities, only with the written authorization of the owners

.

(c) Video filming and i nspectio ns by air of agri cultural areas only under contract with the owners or with a government entity.

(d) Video filming and i nspections by air of infrastructure such as bridges, highways, electrical installations, dams, aqueducts, photovoltaic power stations, pipe lines and

wind farms, only under cont ract with the owners or with a government entity

.

(e) Video filming and i nspection by air of land and residential, commercial and industrial structures, only under contract with the owners or with any government authority.

(f) Inspections b y air to detect sources of pollution, gas emissions and leaks , under

contract with the owner s of the properties involved or with a government entity

.

(g) Provide support to search and rescue operations and reconnaissance in cases of
need, law enforcement oper ations, emergency or natural disasters and only when government authorities have requested it by contract or donation.

(h) O ffer consultancy , demonstrations, and training to private and public entities, which

are interested in t he DOT

- FAA authorization for the use of UASs like ours. In our

staff is included a FAA certified Pilot

- Instructor

. This activity of professional services

– consulting, demonstrations and training

- does not imply that Microcopter Pro can issue certificates or permits of any kind.Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 7

3. Applicant’s information:

MicroCopter Professional Services Inc. (MicroCopter Pro):

President: Sergio Montañez

Email: sergio@MicroCopterPro.com

Address: PMB 163 Suite101

220 Western Auto Plaza Trujillo Al to, Puerto Rico 00976

MicroCopter Pro fessional Services Inc. (MicroCopter Pro) is a registered company on the Registry of Corporations of the Department of Sate in San Juan, Puerto Rico, under

No. 339370 and Em ployer Identification Number: XX

- XX

- 2686. Its commercial purpose is to consolidate activities of Hobby Shop and offer Professional and Commercial

Services with UASs :

a. Hobby Shop

- the sale of these small and light

- weight devices, primarily multi

- rotor (microcopters), for recreational purposes;

b. Workshop for Maintanance, repairs and programming of UASs and other R/C
devices; and

c. Professional and Commercial Services

- with our own and specialized devices for conducting aerial filming and inspections under contract with industries, private and pub lic sectors, including air filming services for commercial and television purposes.

DJI Innovations recognize our workshop as the only one Technical Support and Repair

Center in Puerto Rico.

Our headquarters and facilities are located in San Juan, Puerto Rico and consist of the following: Hobby Shop, Workshop, Executive offices, Editing Room, Warehouse, and

Conference Rooms. So far the only performed activity is Workshop.Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 8

4. Specific sections of 14 CFR from which MicroCopter Pro is seeking exemptions:

14 CFR Part 21, Subpart H Airworthiness Certificates

14 CF R 91.7 Civil aircraft airworthiness

14 CFR 91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements

14 CFR 91.103 Preflight action

14 CFR 91.109 (a) and Flight instruction

14 CFR 91.319 (a) (1) Simulated instrument flight and certain flight tests

14 CFR 91.119 Minimum safe altitudes: General

14 CFR 91.121 Altimeter settings

14 CFR 91.151 (a) Fuel requirements for flight in VFR conditions

14 CF R 91.203 (a) (b) Civil aircraft: Certifications required

14 CFR 91.405 (a) Maintenance required

14 CFR 91.407 (a) (1) Operation after maintenance, preventive maintenance, rebuilding or alteration

14 CFR 91.409 (a) (2) Inspections

14 CFR 91.417 (a) Maintenance records

14 CFR 45.23 (b) Display of marks; general

14 CFR 45.29 Size of marks

14 CFR 

### 61.113(a) (b) Certification: pilots, flight instructors, and ground

instructors

5. Extent and the reason of relief:

a. 14 CFR Part 21, Subpart H Airworthiness Certificates

Section 91.203 (a) (1) requires all civil aircraft to have a certificate of airworthiness. Part 21, 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 of our UAS (less than 25 lbs.) and the limited operating area

associated with its operation , it is unnecessary to go through the certificate ofExemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 9

airworthiness process under Part 21 Subpart H to achieve or exceed current safety

levels.

Such an exemption meets the requirements of an equivalent level of safety under Part

11 and Section 333 of the Modernization and Reform Act . The Federal Aviation Act and

Section 333 of the Modernization and Reform Act both auth orize the FAA to exempt

UAS from the requirement of an airworthiness cert ificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of

the UAS involved.

In this case, an analysis of these cr iteria demonstrates that all of our UAS s included in this Request of E xemption operated without an airworthiness certificate, under the conditions proposed herein, are safer than or as safe as a conventional aircraft with an

airworthiness certificate.

All of our UAS s weigh less than 25 lbs. when fully loaded. They do not carry pilot s,

passenger, commercial goods or flammable fuel s , and will be operate d exclusiv ely within an area predetermined and in compliance with the conditions set forth herein. Operations under this exemption will be tight ly controlled and monitored by the o perator,
pursuant to the conditions set forth above

. Documented permission and knowledge prior to the operation of the land or property owner and/or responsible governmental authorities, planning of the operations and th e characteristics of our UAS

- size, absence of flammable fuel, a nd the fact that they are deployed at th e location and not flown there

all establish the equivalent level of safety. O ur UAS s provide a gr e ater or equal level of safety in the types of operations proposed when compared to a conventional aircraft.

b. 14 CFR 91.7 Civil Aircraft A irworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allo wing comm ercial operation of

the UAS included in this Request to fly without an airworthiness certificate, no standard

will exist to determine their a irworthiness . Given the size of our UAS s and the requirements that have already been met in the approval process ( “UAS Inspection and Maintenance Manual” (UIMM)

, “UAS Flight Operations and Procedures Manual” (FOPM)

, “UAS Safety Flight Checklist” (USFC)

, “UAS Training Manual” (UTM) )

, and

other mitigation procedures included in t hi s Request , an equivalent level of safet y will be

achi eved prior, during and after each flight.

c. 14 CFR 91.9 (b) (2) Civil Aircraft Flight Manual, Marking

, and Placard

R equirements

This sect ion requires an aircraft flight manual in the aircraft. As there are no pilots , crew

or passen gers, and given the size of our UAS , this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a “UAS Flight Operations and Procedures Manual” (FOPM) at PIC’s Ground Control Station (GCS) during any operation . The FAA has previou sly issued exemptions to this regulation in ExemptionExemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 10

No s . 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and

32827.

d. 14 CFR 91.103 Preflight Actions

Prescribes that each PIC shall, before beginning a flight, become familiar with all available information concerning that flight. An equivalent level of safety will be achieved by the PIC taking all preflight actions as set forth in our FOPM, including reviewing weather, flight battery requirements, landing and takeoff distances, and UAS performance data before initiation of flight. Additionally, MicroCopter will offer a briefing prior to each flight regarding planned UAS operations, and all personnel who will be performing dutie s within the boundaries of the Safety P erimeter will be required to

attend.

e. 14 CFR 91.109 (a) Flight I nstruction; and 14 CFR 91.319 (a) (1): Simulated Instrument Flight and Certain Flight T ests

These regulations provide 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. All UAS s in our Request are remotely operated and by design do not have fully functional dual controls. Flight cont rol is accomplished through the use

of a Radio Control (R/C) tha t communicates with the UAS via radio communications. If instruction is accomplished through a training program, as set forth in our “UAS Training Manual” (UTM) , an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft s . See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by our training program and the use of experienced and FAA certified pilots.

f. 14 CFR 91.119 Minimum Safe A ltitudes: General

E stablishes safe altitudes for operation of civil aircraft s . Specifically, 91.119 (c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the ground , except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet t o any person, vessel, vehicle or structure.

As set forth herein, our UAS wil l never operate at higher than 3 00 feet AGL a t congested or populated areas . In the majority of case s our fligh ts will be between 100 and 200 feet (AGL) due to the nature of the services that we will offer. Actually, we will ne ver need to fly at more than 300 feet (AGL). Because our operations must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieve d given the size, weight, speed and material

with which our UAS are built. Also, no flight will be taken without the permission of the

land or property owner, those who control it

, or a governmental authority . Because of the

advance notice to the owners , all affected individuals will be aware of the flights.Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 11

Compared to aerial operations conducted with aircraft or rotor craft weighing far more

than 25 lbs. and carrying flammable fuel s , any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low

- altitude operations of the UAS will maintain separation between these operations and the operations of conventiona l aircraft that must comply

with Section 91.119.

g. 14 CFR 91. 121 Altimeter S ettings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "... to the elevation of the departure air port or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the PIC , pursuant to th e “UAS Safety Flight Checklist” (USFC) , confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Our R/C Transmitter box have Telemetry monitor with all of the information needs to fly UAS safely: altitude, flight speed , distance, direction and

other.

h. 14 CFR 91.151 (a) Fuel Requirements for Flight in VFR C onditions

P rohibits 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 speed

- (1) During the 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 our UAS provi de approximately 30 minutes of powered flight. To

meet the 30 minute s reserve requirement in 14 CFR 91.151, UAS flights would be

limited to 0 (zero) minutes.

Our maximum total flight time for each operational flight will be 20 minutes. Flights will

be t erminated at 33 % mi nimum battery power reserve. We will never make flight operations at night

.

Operating the UAS in controlled area s where only people and property owners or official representatives who have signed waivers will be allowed, with less than 20 minutes of flight operation time, does not give rise to the type of risks that Section 91.151 (a) was intended to alleviate particularly given the size and speed of the UAS

.

i. 14 CFR. 91.203 (a) (b) Civil Aircraft: Certifications R equired

This section p rovides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at the PIC’s Groun d Control Station (GCS) box during any operation

.Exemption Request to FAA Under Section 333, PL 112

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AMENDMENT

- Docket Id. FAA

- 2014

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December 30 , 2014 Page: 12

j. 14 CFR 91.405(a) Maintenance required 14 CFR 91.407(a) (1) Operation after maintenance, preventive maintenance, rebuilding or alteration 14 CFR 91.409(a) (2) Inspections

14 CFR 91. 417(a) (b) Maintenance records

Section 91.405 (a) requires that an aircraft operator or owner “shall have that aircraft inspected a s prescribed in S ubpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, hav e discrepan cies repaired as prescribed in Part 43 of this chapter... ” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409 (a)(2) requires an annual inspection fo r the

issuance of an air worthiness certificate.

Section 91.417( a) requires the owner or company operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the UAS included in this Request wi ll be accomplished by MicroCopter

Pro pursuant to the “UAS Inspe ction and Maintenance Manual” (UIMM) and “UAS Maintenance and Repair Log” (UMRL) . An equivalent level of safe ty will be achieved

because UAS are small in size, will operate only in restricted predetermined areas

, and is not a complex mechan ical devise. As provided in our “ UAS Inspection and

Maintenance Manual” (UIMM) and the “UAS Safety Flight Checklist” (USFC)

, the PIC

and our maintenance crew wi ll ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and will keep a log of any maintenance , repair or replacing parts that is performed. Moreover, the PIC is the person most familiar with the

UAS and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.

MicroCopter Pro has a workshop

- of daily operation

- offering repair, maintenance and programming services for UAS as Model Aircrafts and ot hers R/C devices

.

k. 14 CFR 45.23 (b) Display of marks; general

14 CFR 45.29 Size of marks

These regulations require aircraft s to be marked according to certain specifications. Our

UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases.

All our UAS authorized for these commercial activities will have, to firmly adhere to the

surface of the most resistant part of their structure, a light

- weight plate on which i s engraved

- not written in ink

- the code or information which the FAA will require on the authorization notice to our company.

The FAA has previously issued exemptions to this regulation through Exe mptions 8738,
10167, 10167A and 10700.Exemption Request to FAA Under Section 333, PL 112

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December 30 , 2014 Page: 13

l. 14 CFR Part 61.113 (a)(b) Certification: P ilots, Flight Instructors, and Ground

I nstructors

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations

. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s li cense to operate this UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated i n advance as set forth in the “UAS Flight Operations and Procedures Manual” (FOPM) . The level of safety provided by the requirements included in the FOPM exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested with a private p ilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

6. Reasons That Benefit the Public Interest as a W hole:

Cost

- effectiveness and safety for the public interest as a whole

a. Our propose d filming and air inspection servi ces are conventionally offered by manned

aircraft s and climbers. The preceding may incur in elevated costs and pose a greater risk to persons and properties, therefore increasing the threat to air and ground safety.

Conventional manned aircrafts also have a greater environmental footprint, and therefore harm the environment on a scale that far exceeds that posed by a UAS.

b. The use of manned aircraft s also greatly reduces the flexibility in the variety and angles of the images sought by contracting parties. That is, it is not possible to obtain with the
same detailed, close

- up images with the use of a conventional aircraft.

c. The use of our UAS dramatically reduces the costs and risks related to ground and air safety. Even in situations where accidents occur, the consequences are minimal when compared with those caused by manned aircraft s

.

d. The proposed commercial use of UAS would reduce both the risks and costs that many persons, profession als and companies would inc ur if our services were not available. By hiring our services, persons, professionals and companies would be contributing to technological innovations and promote economic activity in a new line of services.

e. Our UASs are also much more accessible, safe an d effective resource to support government authorities in their operations of reconnaissance

, search and rescue and in cases of emergency or natural disasters

.

f. Studies forecast the UAS industry to have a $13.6 billion impact on the first three years after clearance to operate in the NAS is granted. The same studies predict that the USExemption Request to FAA Under Section 333, PL 112

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December 30 , 2014 Page: 14

economy will lose $10 billion per year if the UAS integration into the NAS is

u nreasonably limited or delayed.

g. Studies also predict that more than 70,000 new jobs will be cr eated in the first three

years of UAS integration

.

7. Reasons why g ranting the E xem ption would not adversely affect safety, or how the Exemption would p rovid e a level of safety at least equal to that provided by the Rules

from which we are s eeking E xemptions:

All human activities in the operation of equipment entail risks. But this does not mean that all devices which entail risks must be prohibited or regulated to the extreme degree of imposing a prohibition in practical terms. Under this premise, nearly everything would have to be prohibited: planes, helicopters, spacecraft, cars, bicycles, and even kitchen knives. Similar kinds of prohibitions would never occur to anyone, despite the fact that

the equipment described above entail more risks and have produced more accidents, injuries and deaths than those which have been produced or which could be produced by the UAS which we plan to include in our commercial activities.

We all know that what makes a particular piece of equipment hazardous or dangerous is not whether money is charged for using it. In the final analysis, it would be irrelevant, from a preventive, security or investigative perspe ctive or with the intention of serving the ends of justice, whether or not some person, criminal or terrorist had used an UAS irresponsibly in exchange for money. His crime would be to have caused hazards or damages. And, in order to commit a crime , he w ou ld have to use an aircraft

-- whether

manned or not

-- that is regulated by the FAA, a car, a bicycle, and even his own hands.

In reality, what defines whether a piece of equipment is feasibly and reasonably safe

are : its specifications, its operating fea tures and the safety controls applied during its

use.

Our staff has accumulated decades of experience in the operation and maintenance of

these UASs as Model Aircrafts

. We have never been involved in accidents in which individuals, properties or aircrafts were harmed. We h ave always followed air and ground security rules and regulations, even though we have not been engaged in commercial activity and were not under FAA supervision. If this Request is accepted, we would put ourselves under FAA supervision a nd regulations , adding an extra layer of security to our potential future activities.

US Congress PL 112

- 95, 2012, FAA Modernization and Reform Act,  ̈Subtitle B

– Unmanned Aircraft Systems ̈ establish a physical and operational equivalence bet ween
what is considered a small “Unmanned Aircraft  ̈, as defined in Sections 331 and 333,

and a  ̈Model Aircraft ̈, as defined in Section 336. The only difference between the

aforementioned devices is that if a  ̈Model Aircraft ̈ is given commercial use, it becomes

a small “ Unmanned Aircraft ̈ for DOT

- FAA regulatory purposes. The regulation of small

“ Unmanned Aircraft ̈ as mentioned in this Request is done by way of special rules, as established by Congress. If a potential small “ Unmanned Aircraft ̈ is used forExemption Request to FAA Under Section 333, PL 112

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December 30 , 2014 Page: 15

recreational, no n

- commercial purposes

– like a hobby

– then it becomes a  ̈Model

Aircraft ̈ that is not subject to DOT

- FAA regulations.

For decades and as of today , without the need of any DOT

- FAA authorization,  ̈Model Aircrafts ̈ are used freely in the NAS, as p er Congress ional decision. The o perators of  ̈Model Aircrafts ̈ hold varying degrees of skills and ranks. These flights are carried out in, or near, populated areas, with absolutely no proof of their ability to do so safely. Congress and the DOT

- FAA allow this activity to take place based on the mere assumption that  ̈Model Aircraft ̈ o perators follow a security guidance promoted by some community organizations with links to these types of activities.

Our commercial activity involved this type of UASs which are physically equivalent to

Model Aircrafts will not pose any greater threat to the NAS or air traffic as those posed currently by Model Aircrafts. On the contrary, to submit us to the supervision and regulations of the DOT

- FAA

, including the adoption of equal regulations or mitigation procedures

, a safer operation is guaranteed.

In order to provide further guarantees of the security regulations and risk mitigation procedures that will be followed, we include in this Request :

a. “UAS Flight Operations and Procedures Manual” (FOPM) Appendi x A

Forms:

• “UAS Commercial Flight Register” (UCFR) Appendix A

- 1

• “Permission to Operate Form” (POF) Appendix A

- 2

• “UAS Plan of Activities” (UPA) Appendix A

- 3

• “UAS Request of Authorization to ATC” (URAA) Appendix A

- 4

• “UAS Safety Flight Checklist” (USFC) Appendix A

- 5

• “UAS Crew Flight Log” (UC FL) Appendix A

- 6

• “Liability Release and Consent Form” Appendix A

- 7

b. “UAS Inspection and Maintenance Manual” (UIMM) Appendix B

Forms:

• “UAS Maintenance and Repair LogBook” (UMRL) Appendix B

- 1

• “UAS Fleet Specs and Manufacturers’ Manuals” Appendix B

- 2

c. “UAS Training Manual” (UTM) Appendix C

Form:

• “UC Training Log” (UT L) Appendix C

- 1

d. UAS Crew (UC) Members Personal Data Appendix DExemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 16

8. UAS s Physical and Technical Specifications : We desc ribe those which pertain to our UAS s and their components, which would be used by MicroCopterPro in its commercial activities authorized by the DOT

- FAA. At a minimum, our equipment complies with the following features:

(a) The part of the UAS that sta tes that the larges t size shall not exceed 1.5 meter long
and, in flight, the total weight of each UAS will not exceed 25 pounds, including all of its components and equipment.

(b) When UAS s , their equipment and components exceed the 15 pounds of weight at the time of the flight, they will use a system of parachute activated by Radio Control for the purpose of eliminating or minimizing possible damages during a potential accident. Our system is: Mars Parachute for UAV’s . This system is capable of working on an aircraft of up to 25 pounds utilizing a high energy compression spring

and a servo to deploy the chute and reduce the falling speed of craft in the event of a

malfunction.

(c) The maximum s peed capability in flight of these UAS s will not exceed 50 knots (57.539 mph).

(d) All our UAS s use lithium battery charge as fuel, are already authorized for sale in the

United States as Model Aircrafts

. Maximum total battery charge for each flight will be

of 30 m inutes. Flights will be terminated at 33% battery power reserve.

(e) All our UASs operate with Radio Control (R/C) systems, are already authorized for

sale in the United States as Model Aircrafts

, and meet all requirements related to the

Federal Commun ications Commission (FCC).

(f) Its flight systems are supported electronically by GPS and the “Safe Return” mechanism to guarantee that, in the event of the loss of the radio control signal, the UAS can return to the point of take

- off in an autonomous and saf e way. The point of

take

- off and “Safe Ret urn” are always located within the “ Maximum Safety
Perimeter”, as we define it in our UAS Flight Operatio ns and Procedures Manual (FOPM).

(g) All our UAS s operate with propellers. Only those manufactured from flexible materials, capable of breaking up upon impact with other objects, will be used. Propellers manufactured with any type of metal in the blades will never be used.

(h) All our UAS s authorized for these comm ercial activities will have, to firmly adhered to the surface of the most resistant part of their structure, a light

- weight plate a light

weight plate on which is engraved

- not written in ink

- the code or information which the FAA will require on the autho rization notice to our company.Exemption Request to FAA Under Section 333, PL 112

- 95, 2014

AMENDMENT

- Docket Id. FAA

- 2014

- 0557

December 30 , 2014 Page: 17

9. Skilled personnel: We are describing the legal obligations, experience, skills , personal data and medical condition of all our staff directly engaged with the commercial operation of the UAS, including FAA cer tified pilots as PICs, VOs and M aintenance Technicians (MT) of

UAS

.

10. Security and Operational Rules and Manuals: We are describing in our Manuals all the regulations, rules and mitigation procedures that will be rigorously followed when performing

our o perations, including those applied before, during and after each flight. In addition t o the safety standards describe d in this Request , the safety rules established by the FAA will also be rigorously followed.

If this Request is authorized by the DOT

- FAA, we recog nize and agree that it will be strictly limited to legitimate commercial activities, the operating conditions, the safety

rules

, and the types of equipment, which are contained in said authorization. We also recognize and agree that any other element that is not specifically authorized by the FAA will require a new application for evaluation or the submission of another Request to amend the authorization previously granted.

11. S ummary to publish i n the Federal Register:

Amendment to Request for Exemption regarding to the new “ Public Guidance for Request s for Exemption Filed under Section 333 ”, FAA

- September 25, 2014 for safe

and re sponsible commercial use of UAS

.

Docket No.: FAA

– 2014

– 0557 Request er: MicroCopter Professional Services Inc. (MicroCopter Pro)