September 2015 Request for UAS Exemption by Brian H. Morgan

Page 1 of 11

DATE: September 25, 2015

TO: U.S. Department of Transportation -- Docket Management System

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 Law 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 form 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 System (UAS), 

hereby 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 System 

(UAS) for the commercial purposes stated in Docket No.: FAA-2015-0150; Notice No.15-01, 

including aerial video and photography over certain areas of the United States. Briefly described:

1. Aerial photography 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 photography for public and/or private use including television, public 

events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority.

4. Aerial inspection/photography 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. Morgan

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5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only 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 

System (NAS) as well as for the protection of the persons and property.

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 presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation's and the FAA Administrator's responsibilities to " ...establish 

requirements for the safe operation of such aircraft systems in the national airspace system.

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. Morgan

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Description and specifications of UAS to be used by the Petitioner:

DJI Phantom 3 Professional

Gross Weight 3.1 pounds

Size 23.3 inches (maximum to propeller tips)

Max Speed 35.8 mph (straight and level flight)

GPS/GLONASS

Electric Propulsion -- Lithium Polymer Batteries and Brushless DC Motors

Flight time approximately 25 minutes

DJI Phantom Vision 2 Plus

Gross Weight 3.2 pounds

Size 23.3 inches (maximum to propeller tips)

Max Speed 35.8 mph (straight and level flight)

GPS & Datalink Ground Station Autonomous Control Option

Electric Propulsion -- Lithium Polymer Batteries and Brushless DC Motors

Flight time approximately 25 minutes

3D Robotics Solo

Gross Weight 2.8 pounds

Size 16.1 inches

Max Speed 55 mph (straight flight)

GPS/GLONASS

Electric Propulsion -- Lithium Polymer Batteries and Brushless DC Motors

Flight Time Approximately 20 minutes

DJI Matrice 100

Gross Weight 7.5 pounds

Size 37.5 inches (maximum to propeller tips)

Max Speed 45 mph (straight and level flight)

GPS/GLONASS/Ground Station Autonomous Control Option

Electric Propulsion -- Lithium Polymer Batteries and Brushless DC Motors

Flight time maximum 40 minutes
September 2015 Request for UAS Exemption by Brian H. Morgan

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The Petitioner will operate the UAS in line of sight within a predetermined area owned

and/operated by 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 security 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 interest. Accordingly 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 safety 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 issued 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 UAS will be operated within visual line of sight (VLOS) at all times by the operator 

or visual observers. (VO).

3. The UAS will remain close enough to the operator so that human vision unaided by any 

device other than corrective lenses will be used.

4. The UAS will not be operated over persons not directly involved in the operation unless 

those persons remain under a covered structure.

5. The UAS 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 UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour) using 

ground speed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UAS be operated at airspeeds greater than the maximum 

UA operating airspeed recommended by the aircraft manufacturer.
September 2015 Request for UAS Exemption by Brian H. Morgan

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8. The UAS 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 higher 

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 close proximity

to the object as to not interfere with traffic in the NAS.

9. The UAS 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 UAS 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 UAS at any given 

time.

13. The operator will not allow operations from another aircraft.

14. The operator will not conduct any careless or reckless operations. A flight will be 

terminated immediately 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 the 

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 any UA if a physical 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 used. Electronic 

messaging or texting will not be permitted during flight operations. Daisy-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 properly 

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. Morgan

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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 exemption 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. It is the 

operator's responsibility to track such revisions and present revised documents to the 

FAA or any law enforcement official upon request. If 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 only be conducted 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 not 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 years 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 

safely 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 experiencebuilding) and determining the ability to safely operate the UAS in a manner consistent 
September 2015 Request for UAS Exemption by Brian H. Morgan

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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 under 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 predetermined 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 by the manufacturer, whichever is greater. The operator will 

perform training tests, in a designated training area as prescribed herein, to assess the true

energy characteristics of the specific UAS battery system to determine the actual flight 

time for reserve battery power. Said energy tests will deem the "safety" operating 

procedure for actual emergencies and useful flight time.

30. The exemption holder will ensure that operators and VOs have a copy 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 results 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 days 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) Any 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 least 3 days 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. Morgan

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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 

essential 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 requested:

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 meets 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, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis 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 with an airworthiness certificate 

without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither 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 certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the UAS, 

due to its size, speed of operation, location of operation, nearly 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. Morgan

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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 by §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 as 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 by §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 has 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 fully 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. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. Flight instruction is accomplished by handing the transmitter 

between the instructor and trainee or by 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 establishes 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 helicopters by 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 to 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. Morgan

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500 feet AGL, the UAS will not be operated 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 

operations. 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 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 small UAS does 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 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 may 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 

required. An equivalent level of safety will be achieved by 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 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 CFR 91.131 (d)(1 )&(2): Equipment requirements for Class B airspace

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 system. An exemption may

be required. Due to the size, weight and payload capacity of the small UAS, installing these 

systems 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. Morgan

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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; 91.417: 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, have 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 

operating 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 manufacturer’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. If 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 any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain

the aircraft in an airworthy condition to provide the equivalent level of safety.

Additional Information

The Petitioner, Brian H. Morgan, has held his private pilot certificate No. 3013324 since 2004. 

He has been flying radio control (RC) models for 41 years. He has taught RC safety and flying 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 flying 

experience on all types of fixed wing, rotorcraft, multi-rotor, and with OEM proprietary aircraft

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 Airframe and Power Plant Maintenance (A&P) Certificates.

Satisfaction 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 

operation of the Petitioner's UAV systems and airframes.

Very Respectfully,

Brian Morgan