Section of 14 CFR which we seek exemption from:

Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate various, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of t he speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The operation of various UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpart H. Accordingly, we requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Wesubmit that the requested relief is proper since an equivalent level of safety will be ensured. Wewill use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, Op Specs, etc). Furthermore, we will document and maintain all maintenance records for the individual UAS we operate. Relief from certain requirements of Sect ion 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate , and who has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the various UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate d istances from people, vessels, vehicles and structures. Weseeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the various UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As s uch, W e submit that we will ensure that the various UAS are in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and Op Specs, etc), and that the aircra ft are in a condition for safe flight. Wealso seek an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the various UAS will not have a typical barometric altimeter onboard. However, altitude information of the UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with ouroperation of th e UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of

safety equivalent to Section 91.121. Additionally, we seek an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR condition s. We submit that safety will not be affected by operation of the UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of less than 30 minutes. Battery po wer indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off. SIMILAR EXEMPTIONS This request is similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 12701 Benefit to Public Interest Granting these exemptions would benefit the public, by giving additional opportunities to educate other UAS operators, such that they would be able to o perate safely in the NAS. In addition to education, the UAS may be used for aerial monitoring. Visual and other sensors will allow monitoring from the air with minimum endangering of the public, or the situation being monitored. The small craft are able to get into places where manned aircraft cannot, and are able to be carefully maneuvered without contacting structures. Should the UAS detect and unsafe condition, it will either return to the launch site, or drop to the ground. Modern UAS controller syste ms such as the Pixhawk controller have enabled a new level of safety greatly reducing the workload on the UAS operator. The operator will be in control at all times, the controller will only augment that control. A majority of our planned operations will be for training of other UAS operators. Keeping other operators aware of the current situation of the UAS and NAS developments will greatly enhance the NAS keeping other pilots safe. Keeping the operators and pilots safe will help the general public avoid being injured from poor operations. Prior to any flight, the UAS will be inspected for potential points of failure, and other damage. If the system is not deemed safe for flight, the defect will be logged for maintenance personnel to make suitable repairs. As part of the pre

- flight inspectio n maintenance logs will be reviewed to insure any prior issue has been properly repaired. All operations will be conducted with two or more operators, a pilot and an observer. Using two operators will enhance safety allowing the pilot to concentrate on c urrent situation, and the observer to any threats to the UAS or anyone in the vicinity. Additional crew (IE sensor operator) will be used when mission dictates. These specifications meet with the Model Aircraft Operating Standards as set below:● The peti tioner will only operate its UAS in line

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- sight of a pilot and/or observer and will

operate at sites that are `sufficient distance' from populated areas within the sterile area described in the FOPM. ● Such operations will ensure that the UAS will "not create a hazard to users of the national airspace system or the public." ● Wh en f lying the UAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right

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- way to avoid flying in the proximity of full

- scale aircraft. Maximum flight time for each operation will be 30 minutes. ● Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the UAS. ● Minimum crew for each operation shall consist of: UAS pilot, a visual UAS observer, and if using any cameras, the camera operator. ● The UAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current FAA medical certificate. ● The UAS operated by the petitioner weighs less tha n 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal). ● The UAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. ● Given the small size of the UAS and the restrict ed sterile environment within which it will operate, operations adhere to the Reform Act's safety requirements.