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## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

# Drone Business Systems, LLC

FOR AN EXEMPTION S EEKING RELIEF FROM THE REQUIREMENTS OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATIO N OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on September 15 , 2015

Drone Business Systems, LLC
222 Hickman Drive Ste. 101 Sanford, FL 32771

407

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www.DroneBusinessSystems.com info@DroneBusinessSystems.comwww.DroneBusinessSystems.com 407

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## Table of Contents

GLOSSARY OF ABBREVIATIONS

................................ ................................ ......... 3

INTRODUCTION & INTERESTS OF THE PETITIONER

................................ ....... 4
Executive Summary

................................ ................................ ................................ . 4
Expeditious Summary Grant Approval Request

................................ .................. 4
Description of Type, Make and Models of sUAV/UAS Requested

......................... 5
Commercial (Mission, Operation) Purpose

................................ ............................. 6
Regulations from which Specific Relief is requested:

................................ ......... 6

The name and address of the Petitioner

................................ ............................. 6
Background

................................ ................................ ................................ .......... 7
Commitment to Safety

................................ ................................ ......................... 7
Expertise & Experience

................................ ................................ ........................ 7
The Exemption Request

................................ ................................ .......................... 8
Operator Requirements

................................ ................................ ........................... 9
Aircraft and Equivalent Level of Safety

................................ ................................ . 11
Specific Uses Public Benefits

................................ ................................ ................ 11
Equivalent Level of Safety

................................ ................................ ................. 12
14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

................................ ................ 13
14 C.F.R. §91.119: Minimum safe altitudes

................................ ...................... 13
14 C.F.R. § 91.121 Altimeter Settings

................................ ................................ 14
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

......... 14
14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections

................................ ................................ ................... 14
Federal Register Publication

................................ ................................ .............. 15
Petitioner seeks an exemption from the following rules

................................ .... 15
Privacy and National Security

................................ ................................ ............ 16
Summary

................................ ................................ ................................ ............ 16

APPENDIX A

– FLIGHT OPERATIONS MANUAL

................................ ............... 18

APPENDIX B

- TECHNICAL MANUALS AND SPECIFICATIONS

...................... 19

APP ENDIX C

- MAINTENANCE AND REPAIR LOG

................................ ........... 20

APPENDIX D

– MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS
MANUAL

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## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administra tion
FAR Federal Aviation Regulation GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice t o Airman
PIC Pilot i n Command
Section 333 FAA Modernization and Reform Act of 2 012 (FMRA) Sec 333
SO Safety Observer
SOP Standard Operating Procedures
sUAS Small Unmanned Aircraft System
sUAV Small Unmanned Aircraft Vehicle
UA Unmanned Aircraft
UAS Unmanned Aircraft System
UAV Unmanned Aircraft Vehicle
VFR Visual Flight Rules VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Take

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## INTRODUCTION & INTERESTS OF THE PETITIONER

Gentlemen :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Drone Busine ss Systems, LLC , (“ DBS ”) an Operator of Small Unmanned Aircraft Systems (“sUASs”) that is equipped to offer on

demand co mmercial UAS operations for a multitude of businesses and industries . DBS

desires to perform flights for the purposes listed below, and hereby applies for an exemption from specific Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAV’s/UAS, within and under the conditions stated herein or as may be established by the FAA in an exemption gra nted under either Sect ion 333 of Section 49 U.S.C. §44701(f)

Our requested exemption would permit the operation of a UAS under controlled

conditions in NAS that is 1) limited; 2) predetermined; and 3) would heighten safety in
fields operations , which presently relies upon conve ntional aircraft or humans climbing on dangerous structures, traversing treacherous terrain , and working on hazardous
infrastructure s. Approving this exemption would enhance public safety and help fulfill the Secretary of Transportation’s and the FAA’s res ponsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system ” Section 333(c) of the Reform Act. 1



## Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this application. Petitioner has provided specific exemption numbers whereby the FAA has already granted a previous exemption similar or iden tical to each of our requests.

The petitioner requests to operate an unmanned ai rcraft system (UAS) for aerial data
collection 2 to conduct aerial inspection, photography, filmmaking, cinematography, videography, precision agriculture, wildlife and forestry monitoring and mosquito and

1 DBS relies upon the following exemptions where specific reference to an exemption is not provided:
Exemptions 11062 thru 11067, 11080, and 11109 through 11112, 11114, 11213, 11062, 11857 and 12496.

2 Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical m easurement (particulate measurement, etc.), or any other gathering of data by
instruments aboard the UA S

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.

We believe that t he FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In G rants of Exemption Nos. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. ( see Docket No. FAA−2014−0642), in these cases the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than
a manned aircraft of significantly greater proportions, carry ing crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

In addition the FAA has issued exemptions to other petitioners requesting exemptions for

reasons similar to our request. S pecifically :



###  relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112,
and 11213 are similar in all material respects to our request ;



###  The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112,
and 11213 also apply to our situation ; and



###  A grant of exemption is in the public interest.



## Description of Type, Make and Models of sUAV/UAS Requested :

The petitioner is seeking an exemption to commercially operate sUAV’s makes and

models as follows:

DJI

- Phantom 2; DJI

- Phantom 3; DJI

- Inspire 1; DJI

– Spreading Wings S800; DJI

– Spreading Wings S900; DJI

– Spreading Wings S1000; DJI

– Matrix 100; Cinestar 8 Octo; Altavian Nova F6500; Blade 350 QX3; 3DRobotics X8; 3DRobotics I ris; Sen seFly eBee; and the Yuneec Q50 0 Typhon.

Each of these sUAV’s weighs 55 lbs. or less, with imaging payload and equipment.

Equipment operation manuals for each sUAV listed above are available through the
manufacture and have been previously approved by the FAA for other petitioners that have been issued exemptions 3

.

3 E xemption number 12496 included all of the sUAV’s listed by this parishioner.www.DroneBusinessSystems.com 407

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Page 6 

## Commercial (Mission, Operation) Purpose :

This exemption request would allow the petitioner to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspecti on, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not l imited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, Aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed an d live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, pr ofessional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, and disaster or catastrophe events

s uch as hurricanes, tornados, tsunamis , and aerial data collection act ivities

.



### Regulations from which Specific Relief is requested:

14 C.F.R. § 61.113 (a) & (b) 14 C.F.R. § 61.133(a) 14 C.F.R. § 91.7(a) 14 C.F. R.§ 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151 (a) 14 C.F.R. § 91.405 (a) 14 C.F.R. § 407 (a) (1) 14 C.F.R. § 409 (a) (2) 14 C.F.R. § 417 (a) & (b)



### The name and address of the Petitioner : Drone Business Systems, LLC Attn: Richard H. Simonton, Sr.
222 Hickman Dr. Ste. 101 Sanford, FL 32771 RichSimonton@Dr oneBusinessSystems.comwww.DroneBusinessSystems.com 407

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### Background

The Petitioner is under Bruce Rhea and Richard Simonton’s direction. Bruce Rhea is a highly accomplished, capable and experienced licensed pilot, cell tower owner, entrepreneur and sales professional with ma ny years of ex perience in radio, cellphones, and electronics. Richard Simonton is license pilot and an experienced financial
institution executive , compliance officer, and federal examiner.

Drone Business Systems, LLC is a local Sanford, Florida small business seeking relief
to conduct aerial inspection, photography, filmmaking, cinematography, videography, precision agriculture, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, public entity support operations, training 4 , special event s, motion picture production, surf ace mining, closed set filming, and data collection using sUAS.



### Commitment to Safety

As part of its commitment to safety and innovation, we are asking for this exemption in part, to reduce the risk of injury to its employe es and contractors who participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natural habitat, buildings and other structures within the United States.



### Expertise & Experience

Drone Business Syste ms, LLC owner s are experience d pilots and entrepreneurs and qualified to perform the sUAV activities requested

. They are fast becoming subject matter expert s in the Sanford area for UAS of all types, models and make to help
businesses choose the best UAS f or their specific application and budget.

4 We recognize that the FAA is unable to authorize UAS operations fo r training until such time as the FAA completes its assessment. However, the petitioner will train its own pilot in commands and visual observers
in accordance with 14 CFR § 61.51, § 91.119 and the other conditions and limitations that the FAA sets forth
i n the exemption once issued

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## The Exemption Request

Drone Business Systems (DBS) proposes the use of the sUAV’s will be for capture of high resolution imagery and video of residential or commercial applications and purposes to a level of qualit y that allows the Petitioner to use the imagery to identify, record, memorialize events and objects according to the purposes noted.

The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructu re to conduct bridge inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and vid eography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife

an d forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and securit y of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including telev ision, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events.

The UAS will be oper ated by DBS and or contracting operators on occasion to capture high

- resolution imagery/video of large structures (wide and tall) such as warehouses, high rise buildings, bridges, and construction sites, as well as sky views of fire and explosion sites. Gi ven the small size of the sUAV’s involved, no more than 55 lbs., the usually velocity of operation is between 5

- 15 mph and is restricted by the environment within which they operate. T he Petitioner believes that it falls within the parameters of an equival ent level of safety in which Congress envisioned commercial operations of UASs as permitted by the FAA.

This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:www.DroneBusinessSystems.com 407

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###  The UAS’s size, weight, speed, and operational capability;



###  Operation of the UA S in close proximity to airports and populated areas; and



###  Operation of the UAS within visual line of sight of the Operator.

The Reform Act § 333 (a). Lastly, 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 nationa l airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: 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 ti tle if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of commercial operation of a ircraft without an FAA issued pilot’s license.

DBS in filing this application is requesting that the FAA combine the grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its DBS ’ sUAV wi thout the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 e xemptions, provide the separation needed from other
aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeron autical chart, unless a letter of agreement with that airport’s management is obtained, DBS requests that operations over congested or densely populated areas be allowed. The DJI Phantom 3

, and other sUAV’s

, do have GPS geo

fencing, it will operate at a ve ry low altitude, within confined areas, at low speed and weighs no more than 55 lbs.. Such operations will only be under

- taken with the approval
of the land or homeowner (s) and will comply with the distance limitation requirements in
effect at the time unl ess approval has been provided by the adjacent land owner (s).



## Operator Requirements

Given the sUAV proposed by DBS, some flight operations should not require the PIC to hold a private pilot license. DBS believes that at a minimum 1) the operator, should ha ve knowledge and experience that enables the safe operation of a small, remotely piloted
sUAV

, should understand airspace restrictions

, aircraft separation requirements from
other aircraft and from non

- participants and property; 2) the sUAV has built

- in te chnical capabilities that limit the potential for unsafe operation and 3) there are securitywww.DroneBusinessSystems.com 407

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.

Advanced sU AV’s have navigation and control system s inc luding auto

- pilot that allows it to execute very accurate pre

- programed flights. Flights are pre

- programmed with GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights

under auto

- pilot are not directed by positive manual input, but through pre programmed flight parameters that are executed by the auto

- pilot. In the case of unplanned events, the Operator inputs preprogrammed evasive maneuvers from the control unit, and the autopilo t executes those maneuvers. Pre

- programmed Operator interventions include: initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (flight

terminat ion system). Additional automated safety functions and safety enhancing features of the Advanced sUAV’s may include the following:



### 1) Auto

- pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 

### 2) Low power on the aircraft tri ggers escalating alarms at GCS at 35% and 10% levels. Low power below 10% triggers an immediate landing, 

### 3) If the auto

- pilot detects a lost

- link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is n ot restored, execute a return to home and land, 

### 4) Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un

- commanded deviation from the flight path, 

### 5) The aircraft, weighs less than 55 lbs., fully loaded, 

### 6) The motors are driven by pulse width modulated signals, not analog signals, 

### 7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum of 400
feet A GL.

See Federal Aviation Administration, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013); As the FAA has determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the requir ements for private pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, was sufficient to allow private pilots to operate sUAV’s under those

ex emptions.

Based upon that analysis, DBS believes successful completion of FAA private pilot ground school is a suitable predicate to operating the sUAV under this exemption. DBS proposes that the Operator accumulate required sUAV flight training hours thro ugh the operation of sUAV’s rather than flight hours in conventional aircraft.www.DroneBusinessSystems.com 407

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, DBS asks that our exemption be issued without the requirement for a visua l
observer for all flights . This request is based on the fact that an equivalent level of safety is provided by the size, speed and control capabilities of the sUAV

, in addition to the operational procedures that are applicable to all our flight s . These factors limit the safety
benefit that a visual observer may provide during many fight opera tions . Many times flight operations take place in areas where the risk to people and property is limited, thereby, mitigating the benefit or need for a visual observer to be present.

Also, the NPRM does not require the use of a visual observer. Given the clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, re duction in environmental impacts, including reduced emissions associated with allowing battery powered sUAV’s for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot license, the gr ant of the requested exem ptions is in the public interest.



## Aircraft and Equivalent Level 

## of Safety

The Petitioner s uggests that the exemption requested apply to civil aircraft that have the characteristics and that operate with the limitations list ed w ithin or petition . These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. S uch conditions a s those found in previously

issued Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112,
11213 and 11857

.



## Specific Uses Public Benefits

Drone Business Systems, LLC proposes use of its sUAV prov ided equivalent or augmented levels of safety for each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are now conducted by either humans wading through swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or otherwise hazardous or by the use of conventional aircraft.

The current procedures can r esult in significant injuries to the people who must climb on the roofs or require the use of aircraft that are orders of magnitude greater in size thanwww.DroneBusinessSystems.com 407

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increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage
from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those undertaken with a sUAV.

The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site because the aircraft must be flown to and from the site. By contrast, the sUAV is carried to the site and transits no other property.
Conventional aircr aft carry flammable fuels that are not carried by the UAS and emit pollutants associated with internal combustion engines. The sUAV’s proposed herein are battery powered and have no emissions.



### Equivalent Level 

## of Safety

14 C.F.R. § 61.113(a) & (b);: Priva te Pilot Privileges and Limitations; Pilot in Command;

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

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the DBS sUAV is remotely controlled with no passen gers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire.

Instead, it would seem more appropriate for sSUV Operators to have successfully completed the FAA private pilot ground instruction and passed the FAA Private Pilot
written examination or FAA

- recognized equivalents.

DBS notes that the FAA has found that safety factors permitted operation of UASs by Operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Federal Aviation Administration, Notice N 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013) . Likewise, DBS notes that the NPRM does not require that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the DBS ’ sUAV without a private pilot’s certificate or a commercial pilot’s certificate, but having passed the FAA Private Pilot written examination.

The level of risk associated with the operation of the DBS ’ sUAV (given its size, speed, operational capabilities, and lack of fla mmable fuel) are low compared to the level of riskwww.DroneBusinessSystems.com 407

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61 with convent ional aircraft . Because of this, operations of UAS by operators not holding private of commercial pilot s licenses should provide a level of safety required under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of skill requiring of a commercial pilot to operate a sUAV aircraft under § 61.133(a).



### 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthines s of the UA. Given the size of the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to eac h flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.



### 14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 ( d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is opera ted. No flight will be taken without the permission of the property owner, facility owner, and/or local officials. Because of the advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conve ntional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply w ith Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemption s 11062 through 11067, 11080, 11110 and

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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 airport or an appropriate altimeter setting available before departure.” As the DBS ’ sUAV, in manual or emergency mode, will not have a barometric altimeter display, bu t instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar opera tions in Exemption s 11062 through 11067, 11080, 11110, 12496

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wi nd 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.”

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a t ightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviat e given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to
30 minutes or 20

- 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.



### 14 C. F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 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 in spections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.www.DroneBusinessSystems.com 407

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Drone Business Systems, LLC 222 Hickman Drive Ste. 101, Sanford, FL 32771 Page 15 Given that these sections and Part 43 ap ply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals atta ched as confidential Exhibits An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067,
11080 and 11110.



### Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is neede d:



### Petitioner seeks an exemption from the following rules :

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for t he following purposes: to conduct bridge inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to el ectrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surv eying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography fo r public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current a nd future UAS operations within the NAS, special events: including high schools. Colleges , professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events.www.DroneBusinessSystems.com 407

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### Privacy and National Security

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Inspection will be of inanimate objects in areas where the
owners will have consente d to the inspections or otherwise have agreed to allow the UAS and the Operator to be in the area where operations will take place.The size of the UAS, its speed and restricted area of operation do not raise national security issues.



### Summary

Approval of ex emptions allowing commercial operations of sUAV’s for petitioner to operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photograp hy of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on
board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events, will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing people in swamps, on roofs o r tall, hazardous or weakened structures, exposes them to higher
risks than those created by use of a sUAV’s . The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose

them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. Thes e lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in clos e proximity to the ground and people or the use of individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airp orts and populated areas andwww.DroneBusinessSystems.com 407

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Drone Business Systems, LLC 222 Hickman Drive Ste. 101, Sanford, FL 32771 Page 17 operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11171 through 11174, 11176, 11 177, 11062, 11109, 11112, 11213, 11857 and 

### 12496

.

Sincerely,

Richard H. Simonton, Sr. President Drone Business Systems, LLC

222 Hickman D r. Suite 101 Sanford, FL 32771www.DroneBusinessSystems.com 407

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## APPENDIX A

– FLIGHT OPERATIONS MANUAL

Petitioner submits the Appendix A F light Operations Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b).

Flight Operations M anual s ubmitted as a separate document

.www.DroneBusinessSystems.com 407

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## APPENDIX B

- TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix B Technical Manuals & Specifications marked “CONFIDENTIAL,” as they contain propriet ary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b).

M anuals and Specifications s ubmitted as a separate document

.www.DroneBusinessSystems.com 407

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## APPENDIX C

- MAINTENANCE AND REPAIR LOG

Petitioner submits th is Appendix C Maintenance and Repair Log marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform
Act S ection 333 (b).

Logs s ubmitted as a separate document

.www.DroneBusinessSystems.com 407

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## APPENDIX D

– MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS
MANUAL

Petitioner submits the Appendix D M otion Picture and Television Flight Operations Manual marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b).

Logs s ubmitted as a separate document

.