## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 1 of 11 **DATE :**  September 25, 2015 **TO:** U.S. Department of Transportation

-- Docket Management S ys tem

1200 New Jersey

Ave., SE Washington DC 20590 **FROM:** Mr. Brian H. Morgan

N7036 Riverwoods Dr Sheboygan, WI 53083 **RE:** Exemption Request Pursuant to Public L aw 112
- 95, Section 333 of the FAA Reform

Act and Part 11 of the Code of Federal Regulations from: 14 CFR 21 subpart **H;** 14 CFR 47.3(b)(2); 14 CFR 47.31(c); 14 CFR 91.9 (b)(2); 14 CFR 91.109(a); 14 CFR 91.119(d)(1); 14 CFR 91.121; 14 CFR 91.131(b)(1); 14 CFR 91.131(d)(1)&(2); 14 CFR 91.203(a)&(b); 14 C.F.R. 91.403(b)&(c); 14 CFR 91.405; 14 CFR 91.407; 14 CFR 91.409 and 14 CFR 91.417. Note: 14 CFR Part 61 in its current fo rm applies to manned aircraft. 14 CFR 61.3 refers specifically to flight crew members who is defined in Part 1. 1 as a pilot, flight engineer, or flight navigator assigned to duty "in an aircraft" during flight time; therefore no exemptions from Part 61 is being sought for as it is not applicable at the time of this exemption request. Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, Bradley Pierce, operator of a small Unmanned Aircraft Sy stem (UAS), hereb y applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333. The exemption would permit Bradley Pierce to operate a small Unmanned Aircraft Sy stem (UAS) for the commercial purposes stated in Docket No.: FAA

- 2015

- 0150; Notice No.15

- 01, including aerial video and photograph y over certa in areas of the United States. Briefly described: 1. Aerial photograph y and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photograph y fo r public and/or private use including television, public events, cinematograph y and news gathering. 3. Aerial inspection/photograph y of residential/commercial structures under contract with the owners or local government authority

. 4. Aerial inspection/photogr aph y of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 2 of 11 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emer gency or natural disaster onl y when the local authorities or government has requested it by contract and/or donation. 6. The ability

to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace Sy stem (NAS) as well as for the protection of the persons and propert y. As described fully

below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presentl y using conventional aircraft. Appro val of this exemption would thereb y enhance safety and fulfill the Secretary of Transportation's and the FAA Administrator's responsibilities to " ...establish r equirements for the safe operation of such aircraft sy stems in the national airspace s ys tem.
**The name, address ,**  **and contact information of the Petitioner is:** Mr. Brian H. Morgan N7036 Riverwoods Dr

. Sheboygan, WI 53083 Mobile Phone: (920) 889

- 0256 brianhmorgan@me .com
**Regulations from which the exemption is requested:** 14 CFR Part21 Subpart H 14 CFR 91.131(b)(1) 14 CFR 47.3(b)(2) 14 CFR 91.131(d)(1)&(2) 14 CFR 47.31(c) 14 CFR 91.203(a)&(b) 14 CFR 91.9(b)(2) 14 C.F.R. 91.403(b)&(c) 14 CFR 91.1 09(a) 14 CFR 91.405 14 CFR 91.119(d)(1) 14 CFR 91.407 14 CFR 91.121 14 CFR 91.409 14 CFR 91.417

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 3 of 11 **Description and specifications of UAS to be used by the Petitioner :**  DJI Phantom 3 Professional Gross Weight 3
. 1 pounds S ize 23.3 inches (maximum to propeller tips) Max Speed 35.8 mph ( straight and level flight) GPS/GL ONASS E lectric Propulsion

-- Lithium Poly mer Batteries and Brushless DC Motors Flight t ime a

pproximately

2 5 m inutes DJI Phantom Vision 2 Plus Gross Weight 3.2 pounds S ize 23.3 inches (maximum to propeller tips) Max Speed 35.8 mph ( straight and level flight) GPS & Datali nk Ground Station Autonomous Control Option E lectric Propulsion

-- Lithium Poly mer Batteries and Brushless DC Motors Flight t ime a

pproximately

2 5 m inutes 3D Robotics Solo Gross Weight 2 .8 pounds S ize 16.1 inches Max Speed 55 mph ( straight flight) GPS/GL ONASS Electric P ropulsion

-- Lithium Poly mer Batteries and Brushless DC Motors Flight Time Approximately 20 minutes DJI Matrice 100 Gross Weight 7.5 pounds S ize 37
. 5 inches (maximum to propeller tips) Max Speed 4 5 mph ( straight and level flight ) GPS /GL ONASS/Ground Station Autonomous Control Option E lectric Propulsion

-- Lithium Poly mer Batteries and Brushless DC Motors Flight t ime maximum 40 m inutes

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 4 of 11 The Petitioner will operate the UAS in line of sight within a predetermined area owned and/operated b y the property representative. Given the small size of the UAS and the controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval of this application presents no national securi ty issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public intere st. Accordingl y the Petitioner requests that the FAA grant the requested exemption with minimum delay

.

**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safet y of persons, property and also manned aircraft in the NAS. These limitations and conditions to which the Petitioner, hereafter referred to as the operator, agrees to adhere to when conducting commercial operations under the FAA is sued exemption limitations, and as set forth in the Flight Operations Manual (FOM) include: 1. The small UAS, as specifically designated and described in this petition, will weigh less than 55 lbs including payload. 2. The UA S will be operated within visual line of sight (VLOS) at all times by the operator or visual observers. (VO). 3. The UA S will remain close enough to the operator so that human vision unaided by an y device other than corrective lenses will be used. 4. The UA S wi ll not be operated over persons not directly involved in the operation unless those persons remain under a covered structure. 5. The UA S will only

be operated during daylight (official sunrise to official sunset of local operation area) unless specific authorization from the FAA is granted prior to operations. 6. The operator may

use VOs for certain operations and will ensure each VO is trained on procedures listed in the operator's FOM. 7. The UA S will not be operated at a speed exceeding 87 knots (1 00 mil es per hour) using ground speed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA S be operated at airspeeds greater than the maximum UA operating airspeed recommended b y the aircraft manufacturer.

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 5 of 11 8. Th e UA S will be operated at an altitude of no more than 500 feet above ground level (AGL). Altitude will be measured in feet AGL. If an object to be inspected, such as an antenna, exceeds 500 feet AGL , the operator will limit the flight to within 200 feet hi gher than the structure being photographed. The operator will notify the FAA and local authorities of the proposed plan to include date, time, location and height of the object to be inspected prior to operations. The UA will be flown in safe manner in clo se proximity to the object as to not interfere with traffic in the NAS. 9. The UA S will not be operated unless visibility is greater than day

requirements listed in 14 CFR 91.155 for the Class of airspace at the operator's ground station, on location. 10. The UA S will not be operated in Class A airspace (18,000 feet and above). 11. The operator will receive appropriate ATC permission prior to operations in Class B, C, D and E airspace. 12. The operator will ensure that any VOs, if used, will only

monitor one UA S at an y given time. 13. The operator will not allow operations from another aircraft. 14. The operator will not conduct an y careless or reckless operations. A flight will be terminated immediatel y as possible if the safety of the operation cannot be maintained. 15. Prior to each flight, the operator will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If th e inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, logged and the UAS is found to be in a condition for safe flight. 16. The operator will not operate an y UA if a ph ys ical or mental condition would prevent the safe operation of that aircraft. 17. When using a VO or VOs, the operator and VO must be able to communicate at all times. Radio communications or communication

- assisting devices may be us ed. Electronic messaging or texting will not be permitted during flight operations. Dais y - chaining of VOs for the purpose of expanding the operations area will not be permitted. 18. The operator will be responsible to see and avoid all other users of the NAS in which the UAS is operating. 19. The holder of this exemption will be responsible to ensure its aircraft are properl y registered in accordance with 14 CFR Part 47, and have identification (N

-Number) markings in accordance with 14 CFR Part 45, Subpart C. Markings will be as large as practicable.

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 6 of 11 20. The UAS operator will be designated before the flight and cannot transfer his or her designation for the duration of the flight unless a medical duress or unforeseen emergency

is preventing safe operation of the UAS. In which case the VO, who has been deemed qualified and trained in the operation of the UAS, will operate the controls to land the UA in a predetermined "emergency plan" set forth by

the operator who was granted this exemption. The holder of this exemp tion must ensure that VOs, if used, can perform the duties required of a VO. 21. Documents for UAS operations and maintenance will be made available to the FAA upon request. If a discrepancy

exists between the conditions and limitations in this exemption and the procedures outlined in the FOM, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in the FOM. The operator may update or revise its operating documents. Itis the operator's responsibility

to track such revisions and present revised documents to the FAA or an y law enforcement official upon request. I f the operator determines that any update or revision would affect the basis upon which the FAA granted an exemption, then the operator must petition for an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 22. Any UAS that has undergone maintenance or alterations that affect UAS operations or flight characteristics, e.g. replacement of a flight critical component, must undergo an operational check flight prior to conducting further operations under this exemption. Operational check flights may onl y be c onducted by

a qualified operator familiar with the specific UAS being checked and must remain 500 feet from any persons unless they remain under a covered structure. (NPRM wording) The operational check flight must be conducted in such a manner so as to no t pose an undue hazard to persons and property. 23. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 24. The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 25. The holder of this exemption will follow manufacturer's safety bulletins for each UAS operated under this exemption. 26. The holder of this exemption will ensure that each operator is 17 ye ars or older, a US citizen and has a state issued driver's license. 27. The holder of this exemption will require that its operators demonstrate the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated in this petition, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. Qualification flight hours and currency may be logged in a manner consistent with 14 CFR 61.51 (b). Flights for the purposes of training the operator's and VOs (training, proficiency , and experience

building) and determining the ability to safely operate the UAS in a manner consistent

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 7 of 11 with how the UAS will be operated, will be permitted. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights will be conducted 500 feet from any persons that are not intended to be part of such training operations unless those persons remain und er a covered structure. 28. The operator will use UAS that have safety features allowing it to return to a preset location if it loses communications with its ground station. The operator will set this pre

determined location within the private or controlled

- access property as to minimize any possible contact with objects. 29. The operator is prohibited from beginning a flight (considering wind and forecast weather conditions) unless there is enough available power for the UA to conduct the intended operation and to operate after that with at least 25% energy reserves or with the reserve power recommended b y the manufacturer, whichever is greater. The operator will perform training tests, in a designated training area as prescribed herein, to assess the true energ y characteristics of the specific UAS battery system to determine the actual flight time for reserve battery power. Said energy tests will deem the "safet y" operating procedure for actual emergencies and useful flight time. 30. The exemption holder will ensur e that operators and VOs have a cop y of this exemption, the FOM and applicable aircraft registrations located at the ground station during operations. These documents will be made available to the Administrator or any law enforcement official upon request. 31. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. 32. The exemption holder will be responsible to report to the FAA any small UAS operation that resu lts in: (1) any injury to a person; or (2) damage to property other than the small unmanned aircraft. The report would have to be made within 10 day s of the operation that resulted in injury

or damage to property . Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Current NTSB accident reporting is required when 1) An y person suffers death or serious injury

. 2) Any UAS with max gross takeoff weight exceeding 300 pounds sustains substantial damage Operations for closed

-set motion picture and television filming and production include the following limitations: 33. The operator must have a motion picture and television operations manual (MPTOM) in his/her possession. 34. At le ast 3 day s before aerial filming, the operator of the UAS must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 8 of 11 the area of proposed filming. The 3

- day notification may

be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

-Number of UAS to be used; e. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; f. Signature of operator or representative; and g. A description of the flight activity , including maps or diagrams of any area, city , town, county , and/or state over which filming will be conducted and the altitudes esse ntial to accomplish the operation. 35. Flight operations may be conducted over/near participating persons consenting to be involved and necessary

for the filming production, as specified in the operator's MPTOM. **Regulations from which the exemption is reque sted:**  **14 CFR Part 21, Subpart H and 14 CFR §91.203(a)(1)&(b): Airworthiness Certificates** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 CFR 91.203(a)(1 ). Given the size and limited operating area associated with the aircraft to be utilized by the Petitioner, an exemption from Part 21 Subpart H m eets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , an d proximity

to airports and populated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating wi th an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries n either a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness c ertificates issued under 14 C.F.R. Part 21, Subpart H. Lastl y, application of these same criteria demonstrates that there is no credible threat to national security posed b y the UAS, due to its size, speed of operation, location of operation, nearl y silent operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 9 of 11 **14 CFR 47.3(b)(2) and 14 CFR 47.31(c) and 14 CFR 91.203(a)(2): Registration required**  This regulation states in part: No person may operate an aircraft that is eligible for registration under 49 U.S.C. 44101

- 44104 unless the aircraft is carrying aboard the temporary authorization required b y §47.31(c). Part 91.203(a)(2) reads similar. The Petitioner will be operating small UAS. Placing registration paperwork inside the UA will be impractical. An equivalent level of safety can be achieved by the Petitioner ensuring that all temporary or permanent registration paperwork for the UAS being operated is located on site at the ground station a s stated in item 30 in this document. **14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft** Section 91.9(b)(2) provides: No person may operate a U.S.
- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration ha s no ability or place to carry

such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the UAS flight manual at the ground station where the UAS operator will have immediate access to it. **14 CFR 91.1 09(a): Flight Instruction** Section 91.1 09(a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. The Petitioner will be operating small UAS that do not have fully functional dual controls. Flight control is accomplished through the use of a control box transmitter that communicates with the aircraft via radio communications. Th e equivalent level of safety is provided b y the fact that neither a pilot nor passengers will be carried in the aircraft and b y the size and speed of the aircraft. Flight instruction is ac complished b y handing the transmitter between the instructor and trainee or b y the use of a buddy box system. Instruction will also be accomplished in accordance with item 27 in this document. **14 CFR 91.119(d)(1): Minimum Safe Altitudes** Section 91.119 e stablishes safe altitudes for operation of civil aircraft. Section 91.119( d)( 1) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helic opters b y the FAA. As this exemption is for a UAS that is similar to a helicopter and the exemption requests authority to operate at altitudes up to 500 AGL , or not more than 200 above a structure from which filming is planned, an exemption may be needed t o allow such operations. As set forth herein, the UAS will never operate at higher than 500 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 10 of 11 500 feet AGL, the UAS will not be operat ed more than 200 feet above the highest point on the structure in accordance with procedures outlined in item 8 of this document. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity , all affected individuals will be aware of the planned flight op erations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs proposed herein and the lack of flammable fuel, noise and any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The procedures outlined in this document prohibit flight over persons not involved in operations unless they remain under a covered structure. **14 CFR 91.121: Altimeter Settings** This regulation requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the small UAS does not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safet y will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Flights will be conducted 500 feet above that read out or within 200 feet above the highest point of the structure being filmed as outlined in item 8 of this document

. **14 CFR 91.131(b)(1): Pilot requirements for Class B airspace** This regulation states that no person m ay operate a civil aircraft within a Class B airspace unless that person is a private pilot, recreational pilot, sport pilot or is a student pilot that meets requirements of §61.94 or §61.95 of this chapter. An exemption from this regulation may be require d. An equivalent level of safet y will be achieved b y operating the small UAS at altitudes listed in the limitation section of this document. The UA will not be landing or departing from airports in Class B airspace nor fl yi ng through Class B airspace. The UAS will be flown in a controlled environment within VL OS. The UAS operator will require ATC permission prior to conducting operations and will give right of way to any manned aircraft. **14 CFR 91.131 (d)(1 )&(2): Equipment requirements for Class B airspa ce**  The regulation states that no person may operate an aircraft in Class B airspace unless it is equipped with a transponder and after January 1, 2020 an ADS
- Bout s ys tem. An exemption may be required. Due to the size, weight and payload capacity of the small UAS, installing these sy stems is not practical. An equivalent level of safety will be achieved by operating the small UAS at altitudes listed in the limitations section of this document. The UAS will not be landing

## September 2015 Request for UAS Exemption by **Brian H. Morga n** 

Page 11 of 11 or departing from airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a controlled environment within VLOS. The UAS operator will require ATC permission prior to conducting operations and will give right of way to any manned aircraft.
**14 C.F .R. 91.403(b)&(c); 91.405; 91.407; 91.409; 91.4**  **17: Maintenance and Inspections** These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, hav e discrepancies repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in accordance with Part 43. Part 43 only

applies to aircraft with a US airworthiness certificate or foreign registered aircraft oper ating in common carriage under provisions of Part 121 or 135. These sections will not apply to the Petitioner who will be operating a small UAS. An equivalent level of safety will be achieved as the UAS will be maintained in accordance with the UAS manufac turer’s instructions and limitations listed in the operator's FOM. The small UAS will carry a small payload and operate in a controlled area for a limited period of time. I f mechanical issues arise the UAS can land immediately

and will be operating from no higher than 500 feet AGL, without prior FAA authorization. The operator will ensure that the UAS is in working order prior to initiating flight, perform required and preventative maintenance, and keep a log of an y maintenance performed. Moreover, the oper ator 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

. **Additional Information** The Petitioner, Brian H. Morgan , has held his private pilot c ertificate No. 3013324 since 200 4. He has been fl yi ng radio control ( RC ) models for 41 ye ars. He has taught RC safety and fl yi ng to local enthusiasts using the safety guidelines set by the Academy of Model Aeronautics ( AMA )

. Brian is an expert level model builder , has every experience in repairing, maintaining and fl yi ng experience on all types of fixed wing, rotorcraft, multi

- rotor, and with OEM proprietary air craft as well

. He also holds a Bachelor of Science for Mechanical Engineering and Design degree from Northern Illinois University , DeKalb , IL... as well as an Associates of Arts degree in Aviation Maintenance and Management, Lewis University , Romeoville, IL also resulting in award of Air frame and Power Plant Maintenance (A&P) Certificates. Sati sfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial o peration of the Petitioner's UAV s ys tems and airframes

. Very Respectfully , Brian Morgan