September 5, 2015

U.S. Department of Transportation , Docket Operations West Building, Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590
Re: Exemption Request u nder Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Airstrike Aerial Photography, LLC (“Airstrike”) owners and operators of the AEE AP10 Toruk, seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A

. Details of Airstrike and the specifics of the sUAS are described in Appendix B . A summary of this request is attached as Appendix C. The requested exempt ion would permit Airstrike commercial operation of Airstrike’s A EE AP10 Toruk (see details in Appendix B), which weighs less than 5 pounds with battery and factory installed imaging payload, to perform bank owned and FDIC owned real property inspections fo r maintenance and erosion control compliance, aerial photo services to the real estate market, and municipality infrastructure inspections that consist of still photographs, video, and other data taken by factory installed, onbo ard cameras

. The AEE AP10 Toruk produce s high quality (16MP) still photographs and video that can be used in the assessment of current property conditions and the development and design of erosion remediation plans as required by the Georgia Soil and Water Conservation Commis s ion (GSWCC) and in compliance with the National Pollution Discharge Elimination System (NPDES) of which the owner is certified as “Level

- 1A Certified Personnel ”

. A pplications for this sUAS include inspection of municipal and privately owned infrastructure inc luding water holding towers, reservoir inlets and sensitive wetlands, emergency transmission antennas, bridge structures, farming facilities and other difficultly accessible areas. Use of the AEE AP10 Toruk for these inspection and surveying applications reduces the need to operate conventional aircraft, providing data more quickly, accurately, economically, safely, and wit h reduced environmental impact. Additionally, all of these services can be performed at low altitudes and mostly, away from the public

. Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized o perations using manned aircraft and under conditions as may be modified by the FAA a s requi red by Section 333. Additionally, Airstrike will distribute a flight plan/intent to any adjacent residences and/or businesses advising the time and scope of its operation, allowing ample feedback and necessary mediation. (PAGE 1 OF 15)As described more fully below, the requested exemption would authorize Airstrike to perform

commercial operations of aerial inspections and photography using the AEE AP10 Toruk which weighs less than 5 pounds in size and is powered electr ically by battery. T he AEE AP10 Toruk will be operated under controll ed conditions at low altitude s with automated control features in airspace that is limited in scope

. It is equipped as descr ibed in detail throughout this request. The AEE AP10 Toruk is a commercial rated craft and designed to be operated by one person but, flight operation s generally involve two people including an operator and an observer. The operator is responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining a visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, etc

. ) to ensure safe operation of t he sUAS. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe operatio n and proper separation of any hazards. The operator also will be an individual who has passe d an FAA approved or equivalent ground tra ining exam a nd have passed an authorized Airstrike training program for the AEE AP10 Toruk

. Finally, the airspace in which the AEE AP10 Toruk will operate wil l be disclosed to and approved as may be required by the FAA in advance. Under no circumstance will the AEE AP10 Toruk be operated within 5 miles of any public or private airport facility, without proper notification to that respective facility and proper authorization by that respective facility, as required by FAA. Airstrike respectfully submits t hat because this small, commercial rated AEE AP10 Toruk will be used in lieu of comparatively hazardous operations now condu cted with fixed wing, rotary conventional aircraft and humans placed in very dangerous positions, the FAA can have confidence that the operation s will achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities unde r Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” Additionally, and in the interest of the public, there is a rising demand for this type exposition in photography quality and exterior home inspe ctions by both real estate companies and home buyers. The contact and responsible party for this request is: Airstrike Aerial Photography, LLC Donald L. Gordon 197 Shields Road Stockbridge, GA 30281 (678) 428

- 1684 don.gordon@airstrikephotography.com

(PAGE 2 OF 15)The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 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. 91.9(b)(2) & (c) 14 C.F.R. 91.103 14 C.F.R. 91.109(a) 14 C.F.R. 91.119 ; 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(2 ) 14 C.F.R. 91.417(a) Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposa l set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Airstrike submits that grant of this exemption appl ication for use of the AEE AP10 Toruk in general property compliance inspections, local municipality infrastructure inspections and its use in identification and reduction of serious erosion issues, will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs into the nationa l airspace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Tra nsportation to consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking required under S ection 332 of the Reform Act. In making this determination, the Sec retary is required to determine which types of sUASs 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: ● The sUAS’s size, weight, sp eed, and operational capability ● Operaon of the sUAS in close proximity t o airports and populated areas ● Operaon of the sUAS within visua l line of sight of the operator Reform Act § 333(a ) (1) If the Secretary determines that such vehi cles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).2
(PAGE 3 OF 15)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 d efined under §40101 of the Act, from the requirement that all civil aircraft must have a current airwort hines s certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of se ctions 44702

-44716 of this title 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). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced sa fety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the AEE A P10 Toruk A critical element of the exemption application involves evidenc e of the airworthiness of AEE AP10 Toruk sUAS

. The AEE AP10 Toruk is manufactured by AEE Technology Co., LTD. The AEE AP10 Toruk is commercially rated and has a significant set of automated features to ensure safe takeoff, flight and landing in many conditions. Further details of operation and fail

- safe features can be found in Appendix B. Airstrike welcomes the opportunity to consult with FAA staff in order to address any issues or concer ns that this proposal may raise regarding the safe operation of this sUAS and the relative commercial rating. Mandatory Operating Conditions Grant of the exemption to Airstrike will be subject to the following mandatory conditions, which are base d upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions: ● All operao ns to occur in Class G airspace ● Operaons to avoid congested or populated areas, which are d epicted in yellow on VFR charts ● Operaons to be conducted over private or controlled access property ● Permission from land owner/controller required before commencing any flight ● Operaons to occur during Visual Flight Rules Meteorological Condi tions (VMC) ● Aircra to remain within Visual Line o f Sight (VLOS) by both operator and observer ● VLOS guaranteed with a cylinder of operaon around op erator of 1⁄2 nautical miles (NM) ● Cylinder walls may be expanded by observer w ith ability to control a ircraft ● Operaons to occur during daylight hours ● Above Ground Level (AGL) altu de to be restricted to 400 feet ● No operations to be conducted with 5 miles of any private or public airport ● A ll required permissions and permits will be obtained from ter ritorial, state, county or city jurisdictions, including local law enforcement, fire, or other ap propriate governmental agencies ● All operaons will include one pilot for flight control and at least one observer fo r VLOS enhancement of surroundin g area near the aircraft (PAGE 4 OF 15)Operator Requirements

A irstrike respectfully proposes that operator requirements should take i nto account the characteristics of the particular sUAS. Certain sUASs, such as the AEE AP10 Toruk, are cha racterized by a high degree of preprogrammed control and various built

- in technical capabiliti es that limit the potential for operation outside of the operating condition s set forth above. The AEE AP10 Toruk sUAS also provides many built

in functional , fail

- safe and safety features to assist the operator in safe and reliable operation. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a feature whereby, s hould the operator encounter an eme rgency durin g fl ight and lose or release control of the transmitter, the AEE AP10 Toruk will stop in flight and hold its exact position until the operator re gains control manually. If the signal from the operator controls is lost for more than 8 seconds, the AEE AP10 Toruk will program a return route and slowly return to the original launch position. The operator at any time during this descend can regain control of the sUAS. Airstrike notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS ) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen’s certificates. 49 USC §44701 (f).
In summary, Airstrike seeks an exemption from the FARs set forth a bove and in Appendix C to allow commercial operations of a small unmanned ve hicle in surveying, aerial property inspections and aerial photo services to the real estate market

. Approval of the exemption allowin g commercial o perations of the AEE AP10 Toruk for these services outlined herein will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aeria l vehicles carrying significant quant ities of combu stible fuels, and a multi

- person crew in piloting and observation roles. These operations require transit to and from the location of the activity, an d often take place in congested environments including proximity to physical obstacles and/or presence of the general public. By contrast, the AEE AP10 Toruk, weighing less than 5 pounds including payloads and uses a battery for power, is carried to/from the area of activity, removes the need for airborne pilots/ob servers, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised by the grant of the requested exemptions. Given the size, zero load carrying capacity, speed at which it operates, and the fact t hat it carries no explosives or other dangerous materials, t he AEE AP10 Toruk poses no threat to national security. The operation of the AEE AP10 Toruk for photography and inspection operations in accordance with the strict conditions outlined above will provid e an equivalent level of s afety supporti ng the grant of the exemptions requested herein, incl uding exempting Airstrike from the requirements of Part 21.

(PAGE 5 OF 15)The AEE AP10 Toruk’s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight,

speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual line of sight, and national security and its showing of an equivalent leve l of safety as it may relate to the requirement for a pilot’s license, prov ide more than adequate justification for th e grant of the requ ested exemptions allowing Airstrike comme rcial operation of the AEE AP10 Toruk in the services and inspection operations as outlined herein

. Respectfully Submitted,

Don ald L. Gordon Airstrike Aerial Photography, LLC

- Owner

(PAGE 6 OF 15)APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Airstrike requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the AEE AP10 Toruk : 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.203(a )(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the si ze of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exempt ion meets the requirements of an equivalent level of s afety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certifi cate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS involved. In this case, an analysis of these criteria demonstrates that the AEE AP10 Toruk operated without an airwo rthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The AEE AP10 Toruk weighs less than 5 pounds fully loaded and has no additional load bearing capabilities

. It will not carry a pilot or passenger or flammable fuel, and will operate exclusively within areas disclosed herein and in compliance with conditio ns set forth herein. Operations under this exemption will be tightly controlled and monitored by bot h the operator, pursuant to the conditions set forth above, and by lo cal public safety requirements. The automated safety features including redundant sensor systems as described in Appendix B and throughout this document h ighlight the d esign intentions towards safety and reliability of the AEE AP10 Toruk

. 14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that a ircraft marks consisting of the Ro man capital letter “N” (denoting United States registratio n) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on li mited, restricted or light sport category aircraft or experimental or provision ally certificated aircraft, the operator must als o display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “ light sport,” “exper imental,” or “provisional,” as applicable. Regulation 91.9(c) provides: No pers on may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. (PAGE 7 OF 15)The AEE AP10 Toruk has no entrance to the cabin, cockpit, or pilot stati on on which the markings can be

placed. Give n the size of the sUAS, two inch lettering will be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. The AEE AP10 Toruk is currently marked with a fixed label co ntaining Manufacture ID and Serial Number. Airstrike is prepared to mark the inspection system with the name of the organization with contact information and fulfi ll any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, a nd others working with the sUAS will see the identification of t he sUAS. The FAA has issued the followin g exemptions to this regulation ( see Exemption Nos. 8738, 10167, 10167A and 10700 )

. 14 C.F.R. § 61.113(a) & (b) ; 61.133(a): Private Pilot Privi leges and Limitations; Pilot in Command ; Commercial Pilot Privileges an d Limitations. Section 61.113(a) & (b) limit private pilots to noncommercial operations. Unlike a conventional aircraft that carries a pilot, pass engers, and cargo, the AEE AP10 Toruk is remotely controlled with no passengers or property of others on boa rd. 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. Airstrike respectfully proposes that operator requiremen ts should take into account the ch aracteristics of the particular sUAS. Airstrike’s AEE AP10 Toruk has a high degree of preprogrammed control and engineered technical capabilities that strictly limit the potential for operation outside of the operat ing conditions set forth in the exemption application. The A EE AP10 Toruk has an all

- digital software platform with advanced feature s previously restricted to full size unmanned aircraft. Automate d features and advanced fly safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.

● The AEE AP10 Toruk is equipped with a series of flashing lights at start up signaling the operator of certain conditions and will not fly until the operator calibrates and or corrects these conditions.

- Compass Calibration

-Accelerometer Calibration

- Gyro Calibration

- Barometric Calibration

- GPS satellite downloads ● Smart ba eries and charger: Flight time and battery condition is monitored at all times. The system will default to a fail

- safe, return home mode and lan d automatically if user control signals are lost or if battery capabilities have been exceeded by extended flight of operator

. ● Controller Signal loss: The AEE AP10 will return to original launch position if the operator signal is lost during flight. ● Automatic preflight ch ecks: The system self

-calibrates all of its sensors and performs a self

-test prio r to takeoff. ● FPV: The operator has a “ bird’s eye” view via attachment of a smart phone/device to the controls. The operator does not have to rel y solely on line of sight view from the ground.
Given these safety features, Airstrike proposes that operators of the AEE AP10 Toruk should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: (PAGE 8 OF 15)● h ave successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA

Private Pilot written examination or FAA recognized equivalents including ICAO issued commercial, pr ivate license and ground school. ● ha ve completed Airstrike’s training program for operation of the sUAS. ● h ave completed a minimum of 10 hours operation of the AEE AP10 Toruk in an open, safe environment away from any people, structures or obstacles

. Airstrike notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N89 00.227, Unmanned Aircraft Systems (UAS ) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C . § 44701(f) to w aive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the AEE AP10 Toruk without a private pilot’s certificate or a commercial pilot’s certificate, under t he conditions set forth herein. The risks associated wit h the operation of the AE E AP10 Toruk (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from th e level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixe d wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) an d does not rise to the level of requiring a commercial pilot to operate the aircraft un der § 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 comme rcial operation of the AEE AP10 To ruk without an airworthiness certificate, no standard will exist fo r airworthiness of the AEE AP10 Toruk

. Given the size of the aircraft and the COAs issued for Airstrike’s AEE AP10 Toruk, an equivalent level of safety will be achieved by ens uring complia nce with the Airstrike’s manuals prior to each flight. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No pers on 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, a nd placards, or any combination thereof. Given the size an d configurati on of the AEE AP10 Toruk, it 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 achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulat ion: Exem ption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. (PAGE 9 OF 15 )14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provid ed as set forth in the AEE AP10 Toruk’s User Manual (exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distance s and aircraft performance data before initiation of flight. 14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The AEE AP10 Toruk is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that com municates with the aircraft via a WIFI radio repeater

. The flight plan is manually c ontrolle d by the operator as the sUAS is o perated

. If instruction is accomplished through a training program, as set fo rth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions fo r flight training without fully functional dual controls for a number of aircra ft and for flight instructio n in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the AEE AP10 Toruk

. 14 CFR § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested area s to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
As set forth herein, the AEE AP10 Toruk will never operate at higher than 400 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work must be accomplis hed at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed. The equivalent level of safety will be achieved given the size, weight, speed, and material with which the AEE AP10 Toruk is built. Also, no flight will be taken without the permis sion of the land owner or those who control the land. Because of the advance notice to the landowner, all affecte d individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorc raft weighing far more than 5 lbs. and carrying flammable fuel, any risk a ssociated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of th e sUAS will maintai n separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

(PAGE 10 OF 15)14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation p rohibits an individual from beginning “a flight in a n airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fl y to the first point of intended landing and, assuming normal cruising speed (1) During the day, to fly after that for at least 30 minutes ; or (2) At night, to fly after that for at least 45 minutes.” The AEE AP10 Toruk battery system provide s approximately 25 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those pro posed operations, a longer time frame for flight in dayligh t VFR conditions is reasonable. Airstrike believes th at an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel doe s not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the sUAS operates. The fact that it carries no pilot, passenger, or cargo a lso enhances its safety. Additionally, limiting AEE AP10 Toruk fligh ts to 20 minutes would greatly reduce their utility. In the unlikely event that the AEE AP10 Toruk should run out of fuel (low battery), it would simply land. Gi ven its weight and construction material, the risks are less than contemplated by the current regulation. Airstrike believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate to return the sUAS t o its planned landing zone from anywhe re in its operating area. The FAA has granted similar exemptions to others, including Ex emptions 2689F, 5745, 10673 and 10808. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a) ... no person may operate a civil aircraft unless it h as ... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight aut hor ization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The AEE AP10 Toruk fully l oaded weighs less than 5 pounds

. As such, there is no ability or pl ace to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by keeping these docume nts at the ground control point where the pilot flying the sUAS will have immediat e access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. § 91.405(a) ; 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided i n paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” (PAGE 11 OF 15)Section 91.407 similarly makes reference to requirements in Part 43 ; S ection 91.409(a) (2) requires an

annual inspection for the issuance of an air worthiness certi ficate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance wor k that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service

. The AEE AP10 Toruk is nearly maintenance free, it performs automatic preflight checks and the failure of any check will prevent takeoff. Checks which cannot be done by th e system will be performed by a qualified person prior to each flight and at prede fined intervals as part of the Maintenance Schedule in the User Manual (see Exhibit 1). Preflight checklist includes:
1. Visual inspection of the airframe 2. Visual inspections of rotor integrity 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station) 4. Visual inspection of all lights for proper operation An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and i s not a complex mechanical devic e. As provided in the attached User Guide (System Maintenance section), the operator of AEE AP10 Toruk will ensure that the sUAS is in working order prior to initiating flight, pe rform required maintenance, and keep a l og of any maintenance that is performed. Moreover, the opera tor is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airwo rthy condition and to ensure an equivalent level of safety. The AEE Ap10 Toruk’s m aintena nce guidelines and pre

-flight checklist ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any component failure detectable by the system will be indicated and will cause the UAV to perform a Fatal Condition Resp onse (FCR) or Non

Fatal Conditioned Response (NFCR), depending on the type of failure.
APPENDIX B
SMALL UNMANNED AERIAL SYSTEM DESCRIPTION Airstrike’s Corporate Overview : Airstrike Aerial Photography, LLC is a U.S. company located in Stockbridge, GA. Airstrike is focused on providing micro unmanned aerial system services and captured images to local municipalities, construction companies, real estate service providers and other private parties as the needs develop. Airstrike’s owner, (through another company) has provided inspection and property maintenance services for the FDIC, banks and private land owners on vacant acreage for several years and recognizes the need for better, more thorough inspection process es beyond where a person can travel. Ma ny properties border streams and bodies of water whereby shorelines are impossible to reach. The AEE AP10 Toruk will enable accurate, low flight images of these areas and better aid owners in developing a sustainable erosion remediation program. The real estate market has proven aerial photography is a huge sale booster. With low

-flight aerial images, a potential buyer can get a better “3

- D” image of a property from all angles. (PAGE 12 OF 15)AEE AP10 Toruk Overview : AE E Technology Co., LTD is a global leader and provide r of recording

equipment, body cameras, multi

- rotor UAV Systems and Unmanned Aircraft technology. The development of the F

- 100 auto tracking UAV system allows law enforcement and the military to lock onto moving or stationery targ ets and monitors them from a ground station. These systems are used for anti

-terrorism, anti

- rioting, traffic monitoring and disaster, relief and rescue situations. This technolo gy and experience has transformed into the AEE AP10 Toruk. Many features ha ve already been covered in this Exemption Request. The AEE AP10 Toruk is a very sophisticated, commercial rated, digital computerized sUAS encompassing a series of operational sensors that aid in stability, compensation for temperature and barometric pres sure, stabilization via GPS control and fail

- safe, return home features which minimize any possible hazard to the environment or people on the ground All flight operations are GPS controlled making the system extremely easy to navigate. At any poi nt if the operator is not explicitly commanding the system to move, the system automatically holds its GPS position (i.e. GPS ho ld for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the most stability of any system in its commercial class. The AEE AP10 Toruk can be operated in both manual and GPS flight modes. While Airstrike has issued strict compliance to GPS operational mode, the manual mode is available as a backup in the event of signal loss whereby adequate control can be maintained and not have the sU AS return on its own. The series of lights on the motorized arms have distinct flashing sequence modes that indicate to the operator current flight and equipment conditions, allowing ample time to recover and abort a mission prior to any problems. Equally, the linked smart device attached to the controls indicates these conditions as well. The battery life remaining is divided into equal thirds and the lights blink in a specific sequence indicating same. The AEE AP10 is a 6 axis system allowing very stabl e operation. The handheld transmitter operates at 915 MHz and includes a safety lanyard to prevent accidental dropping of the unit while in flight. Propulsion System ● Engines

- The AEE AP10 Toruk is powered by 4 electric brushless DC motors. ● Batteries

- 5400mAh Lithium P ol ymer batteries are removable and lock in place during operation. ● Propellers

– 4 each, 10” heavy plastic with stainless steel reverse directional threaded mounts Performance Characteristics ● Maximum Altude

– 1,680 feet ● Maximum Endurance

- 28 minutes ● Wheelbase

– 1.48 feet ● Maximum Tilt Angle

– 35 degrees ● Wi nds Maximum

– 8

- 10 MPH sustained ● Hover Accuracy
– Horizontal=6.5 feet, Vertical=3.2 feet (GPS Mode) ● Camera Resolution

– 4608 X 3456 ● Icing conditions

– light snow ● Pre cipitation

– light drizzle ● Temperature Operating Range

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- 122F (PAGE 13 OF 15)Maintenance

The UAS is nearly maintenance free, it performs automatic preflight checks and the failure of any check will prevent takeoff. Checks not perfo rmed (visual) by the system will be performed by a qualified person prior to each flight. Preflight Checklist ● Visual inspecon of the airframe ● Visual inspecons of rotor integrity ● Check charge of all ba eries (aerial vehicle, command staon, rad io repeater station) ● Check all landing gear and motor mount screws Reliability The system is designed for maximum reliability and to maintain performance over its life. The only components that experience routine wear are rotors, batteries and motors. Battery conditions are monitored by the system with deviations reported to the operator. Motors will be check each month or every 10 hours for proper amperage. Rotors are protected by mounted propeller guards which will prevent a fatal crash in the event of light contact with objects . Any d amaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations.

. Takeoff and Landing The AEE AP10 Toruk has vertical lift autonomous launch and recovery. A Landing Zone “LZ” is designated by the ope rators and identified in the GPS software. For launch procedures the aircraft will power up and hold until further operator instruction is given. Navigation System The navigation system is manually controlled by the operator with the assistance and stability of GPS sensors. Only during a signal loss or power reduction will the sUAS return safely to its original launch site and slowly land, shutting down. Redundant Systems The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure.
Loss of Line of Sight All flight operations will be conducted with the s UAS within visual sight of the pilot. If the pilot’s view becomes obstructed and line of sight is lost, the pilot may instruct the s UAS to hover in place until line of sight is reestablished, to return to the takeoff position, or to land at the current position.

(PAG E 14 OF 15)APPENDIX C

SUMMARY OF AIRSTRIKE AERIAL PHOTOGRAPHY, LLC SECTION 333 EXEMPTION REQUEST Airstrike hereby provides pursuant to Part 11 a summary of its exemption application to allow comme rcial operation of the AEE AP10 Toruk small unmanned syste m in precision aerial photography and inspections. An exemption is requested from the following regulations:
14 C.F.R. Part 21 ; 14 C.F.R. 45.23(b) ; 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. 91.9(b)(2) & (c) ; 14 C.F.R. 9 1.103 ; 14 C.F.R. 91.109(a) ; 14 C.F.R. 91.119 ; 14 C.F.R. 91.151(a) ; 14 C.F.R. 91.203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(2) ; 14 C.F.R. 91.417(a).

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