July

### 29,2Q14

U. S. Department ofTransportation Docket Management System 1200 New Jersey 

### Ave., SE 

### Washington, DC20590

Re: Exemption Request Section 333 of

### the FAA Reform Act.

Dear Sir or Madam:

Pursuant 

### to Section 333 of

### the FAA Modernization 

### and Reform 

### Act of 2012 

### (the Reform 

### Act), Slugwear, lnc, dba as Likeonatree 

### Aerial (the 

### operator), D. 

### Douglas Branch (the 

### applicant), planned operator of

### Small Unmanned 

### Aircraft Systems (sUASs) equipped to conduct 

### aerial photography and survey for

### various industries hereby applies 

### for an exemption 

### from FederalAviation Regulations (FARs) 

### to allow 

### commercialoperation 

### of their sUASs, 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. 

### As described more 

### fully below, 

### the requested exemption 

### would permit 

### the operation 

### of sUAS by

### the applicant for 

### commercial usethat

### would provide the

### following benefits: 

## 1. Operations 

### would be performed in an area of

### operation limited in size suitable to 

### thespecific use, in advance offlight. 

## 2. The flight 

### would be planned in advance 

### to minimize hazards 

### to persons and property in

### the air and on

### the ground. 

## 3. The operator 

### would reasonably limit or control access 

### to provide safety to those not involved in

### the operation. 

# 4. Operation of asUAS 

### would provide significant safety, environmental and other 

### enhancements not possible by larger sized aircraft. 

## 5. An FAA licensed airman 

### with a Commercial 

### grade or higher pilot certificate would operate 

### thesUAS or directly supervise 

### the operation. 

# 6. Provide a beneficial and 

### currently unavailable service 

### to government organizations and the 

### general public that 

### would serve 

### the public interest. 

### Approval ofthis exemption would 

### thereby enhance safety and fulfill 

### the Secretaryof Transportation's (the FAA 

### Administratof s) responsibilities 

### to "...establish requirements for the safe operation of such aircraft systems in

### the national airspace system." Section 333(c) of

### the Reform Act.

It is possible 

### to operate sUASs so

### to not create 

### a hazard 

### to users of

### the National 

### Airspace System (NAS), 

### the public or pose athreat 

### to national security if done so safely and 

### responsibly. The applicant has demonstrated their willingness 

### to act 

### safely and responsibly by not 

### engaging in commercial sUAS 

### operations. The 

### applicant has, infact, worked 

### with FAA employees at

### the local FSDO in an effort to

### flnd asafe and legal solution 

### to permit commercial 

### operation. Additionally, the fact that 

### the applicant currently holds 

### a FAA 

### AirlineTransport Pilot Certificate (ATP), and a

### current FAA Flight 

### lnstructorCertificate 

### (CFl) demonstrates that 

### the applicant has 

### a high regard 

### to safe operations, as



### well as a necessary 

### high-level understanding of

### the NAS 

### and 

### FARs. The experience these 

### two FAA 

### certificates represent serves 

### to add significantly to

### the level of safety in any 

### operation performed by

### the applicant or

### the applicant's employees.

AIRCRAFT 

### AND EQUIVALENT LEVEL OF SAFETY 

### The applicant proposes that 

### the exemption requested herein apply 

### to civil aircraft 

### that have

### the characteristics of sUAS and

### that operate with 

### the limitations listed herein. 

### These limitations provide for 

### at least an 

### equivalent or higher level of safety 

### to operations under 

### the current regulatory structure as

### the proposed 

### operations represent asafety enhancement to

### the already safe aerial commercial photography and survey operations conducted with conventional aircraft.



### ThesUAS's planned 

### to be operated 

### are rotorcraft andfixed 

### wing aircraft, each weighing 55 or

### fewer pounds including payload. They 

### would operate, under normal conditions, at
aspeed 

### of no more 

### than50 

### knots. The principal construction material of

### these sUAS craft

### would be

### foamand/or 

### plastic. Operations 

### will be 

### performed by a qualified sUAS PlC, as 

### outlined below, 

### to insure that the sUAS 

### will "not create a hazard 

### to users ofthe national airspace 

### system or

### the public." Given 

### the small size ofthe 

### sUASs involved and 

### the pre-planned environment 

### withinwhich they 

### will operate, 

### the applicant believes 

### that these operations 

### fall squarely within that zone 

### of safety (an 

### equivalent level of

### safety) in 

### which Congress envisioned that 

### the FAA must, by

### exemption, allow commercial operations of sUASs 

### tocommence immediately. Also,operation in a researched (to include applicable NOTAMs), pre-defined area 

### will prevent 

### the possibility ofa national security 

### issue. The operation of 

### sUASs by knowledgeable professionals with experience in

### the NAS

### will serve 

### to enhance safety, add to

### the public benefit 

### and reduce 

### environmental impacts related 

### to current methods of 

### aerial photography and survey.

These limitations and conditions towhich 

### the operator, or it's employees, acting as 

### sUAS PIC agrees 

### to be bound 

### when conducting commercial operations under 

### an FAA issued exemption:
Safety 

### will be the 

### first and

### foremost consideration in any 

### sUAS operation. 

### sUAS pilot

### will be 

### an FAA licensed airman 

### with at least a Commercial Pilot certificate or

### thesUAS pilot

### will be 

### directly supervised by 

### an FAA licensed airman 

### with at least a Commercial Pilot certificate. 

### ThesUAS FAA licensed airman 

### will be

### considered Pilot in Command (PlC), whether 

### flying or supervising, and

### will be responsible for safe operation of

### the flight. Flights 

### will be operated 

### within line of sight of

### the PIC 

### andlor an observer. 

### The sUAS 

### willweigh less

### than 55 lbs total. Flights

### will be operated in Class G airspace 

### whenever 

### possible. lf

### operation in other airspace is required, 

### the relevant 

### controlling agency 

### will be notified 

### at least 

### 24 hours prior to

### the operation and, if required, 

### any necessary permission obtained. Flights 

### will be 

### operated under 

### visibility and cloud clearance requirements equivalent to 

### Msual Flight Rules (VFR). 

## 8. The sUAS 

### will at

### alltimes give way 

### toany aircraft 

### carrying persons. 

## 9. Minimum crew for each operation 

### will consist of

### thesUAS 

### PlC. An observer will be utilized if

### the sUAS 

### will be

### flown beyond line of sight of

### the PlC. 

### The observer, if required, and PIC 

### will atalltimes be able 

### to communicate by

### voice and/or text. 3. 1. 2.

4. 5. 6.

7.10. Prior 

### to a sUAS flight, an area ofoperation 

### will be 

### established. This area 

### of operation 

### will include a

### defined lateral and

### vertical area, where 

### the sUAS will 

### operate. Safety procedures 

### will beestablished 

### for persons, property and applicable airspace 

### withinthe area 

### of operation. 11. Flight planning 

### will include 

### flight completion 

### with at least 20o/obattery 

### power remaining 

### as measured by

### the sUAS or appropriate timing. 12. lf equipped, and appropriate for the operation, sUAS aircraft 

### will utilize GPS navigation, 

### failsafe, return-to-home (RTH) and/or 

### flight abort safety features. 13.

### A briefing 

### will be 

### conducted in regard to

### the planned sUAS 

### operations prior to operation at 

### each new 

### location.All personnelwho will be performing duties within 

### the boundaries of

### the area of operation 

### will be present for 

### this briefing. 14. All required permissions and permits 

### will beobtained 

### from appropriate state, county or city

### jurisdictions, including local law enforcement, fire, or other appropriate 

### governmental agencies. 15.Written, 

### to include 

### electronic, and/or oral permission from 

### the relevant property
owners 

### will be 

### obtained prior

### to an operation. 16.

### ThesUAS pilot

### will be

### trained in advance for

### the safe 

### operation of

### the sUAS to be

### operated. This 

### will include operation ofthe 

### sUAS both in normal and 

### emergency modes of

### operation, and

### will include familiarization with 

### the operation manual (or

### similar) if 

### published by

### the sUAS 

### manufacturer. Training 

### will also include 

### types of maneuvers 

### to be performed and 

### the safe operation in relation to persons, property and applicable airspace. 

### 17.The sUAS PIC will 

### establish a

### working relationship 

### with a representative at

### the local FSDO with which 

### to annually review safety procedures and other operations to

### further enhance safety.



### Attached please 

### find a letter from 

### the City 

### of SeaTac, requesting asUAS operation 

### that will document a current 

### highway 

### project. This operation serves as an excellent example of

### the benefits of using a

### sUAS, it represents an 

### enhancement in safety as

### well as benefiting 

### the public 

### interest. lt is respectfully requested that 

### the FAA grant an exemption as soon as possible 

### to enable 

### the City of 

### SeaTac's project 

### to be documented.

It is

### the applicant's belief that 

### the size, speed, operating 

### environment, limitations and level of 

### applicant'sexperience in

### the NAS outlined provides 

### an "equivalent level 

### of safety" 

### or better

### when operating asUAS for 

### the public interest as 

### outlined in 

### Section 333 in

### the FAA Modernization and Reform 

### Act of

### 2012. lt is requested that 

### the FAA issue an exemption 

### to permit safe, legal, commercial sUAS 

### operation by

### the applicant as soon as possible. 

# HHtutk

Likeonatree Aerial P.O. 

### Box 16492 Seattle, 

### WA 98116 

### 206-227-5406

### Appendix 

### A

EXEMPTION REQUESTS 

### AND EQUIVALENT LEVEL OF 

### SAFETY
Slugwear, lnc, 

### dba Likeonatree 

### Aerial, requests an exemption from the following regulations as

### well as any 

### additional regulations that may 

### technically apply tothe operation of sUAS's:

14

### CFR 

### Part21, Subpart H:

### Ainrorthiness Certificates This part establishes 

### the procedures for 

### the issuance of an ainryorthiness certificate. While 

### the FAA continues towork 

### todevelop airworthiness standards 

### for UAS,

### we request an experimental 

### certificate be issued for the 

### sUAS's operated by the 

### applicant under either 

### or both ofthe 

### following provisions: 21 .191 Experimental certificates. Experimental certificates 

### are issued for the

### following purposes: (a) 

### Research 

### and developmenf. Testing new aircraft 

### designconcepts, new aircraft 

### equipment, new 

### aircraft installations, new 

### aircraft operating techniques, 

### or new uses

### for aircraft. 

### (b) 

### Showing compliance 

### with regulations. Conducting flight tests and other operations 

### to show compliance with 

### the airworthiness regulations including flights to show compliance 

### for issuance of

### type and supplemental 

### type certificates, flights to 

### substantiate major 

### design changes, and flights 

### to show compliance 

### withthe

### function and reliability requirements of

### the regulations. Since 

### the experimental certificate 

### can be used

### for commercial purposes such 

### as market surveys, sales demonstrations, and customer crew training, we

### would expect 

### that an experimental certificate 

### would permit our commercial purpose as well. 

### The aircraft 

### will not 

### carry persons or property and

### will only 

### fly under strict operational requirements. Combined with the fact 

### that any aircraft operated 

### would be light

### weight and is constructed primarily out of

### foam or plastic, 

### we propose 

### that a sUAS 

### will be at least as safe, if not safer, 

### than a conventionally certificated aircraft performing the same function. lf an experimental 

### airworthiness certificate is not appropriate for this application, then we request an 

### exemption of 14

### CFR 

### Part21, Subpart H, and

### the requirement 

### for an airworthiness 

### certificate in general, citing 

### the equivalent level of safety 

### outlined in

### the previous paragraph.

14 CFR 

### 91.203(a) & (b)

### Givilaircraft: Certifications required. The regulation provides that an airworthiness certificate, with 

### the registration number assigned to

### the aircraft and a registration 

### certificate must be aboard 

### the aircraft. 

### Additionally, subparagraph (b) provides that 

### the airworthiness 

### certificate be "displayed at 

### the cabin or cockpit entrance so

### that it is legible 

### to passengers or crew." 

### A sUAS istoo small 

### to carry documentation, does not have an entrance, and is not capable of carrying passengers or 

### crew. To obtain an 

### equivalent level of safety and meet 

### the intent 

### of 91.203, 

### we propose 

### that documents deemed appropriate for this 

### aircraft by

### the FAA will be co-located with 

### the crew atthe ground control 

### station and available 

### for inspection upon 

### request. ln order 

### to identify 

### the aircraft, 

### we propose 

### the use of

### thesUAS' unique manufacturers serial number, and a contact 

### telephone number be mounted on

### the sUAS
on a placard 

### of reasonable size in relation to the 

### sUAS. lnthe event 

### that a unique manufacturers serial number is not available, 

### the previously mentioned placard 

### will be affixed tothe 

### sUAS consisting of

### the model name and number of

### the sUAS, as

### well as a



### 4contact 

### telephone number.

14

### CFR 45.23 

### Display 

### of marks; general and 45.29 

### Size 

### of marks. These regulations provide that each 

### aircraft must display "N" and

### the aircraft's registration number in letters at least 3 inches high.

### Additionally,the aircraft must display the 

### word "EXPERIMENTAL" in letters at least 

### 2 inches high near the entrance tothe cabin, cockpit, or pilot station. 

### A sUAS 

### does not have an 

### entrance inwhich the word "EXPERIMENTAL" 

### can be placed, 

### and may not have a registration number assigned to it by

### the 

### FAA. We propose 

### toachieve an 

### equivalent level of

### safety by including the word "EXPERIMENTAL" onthe top or side of

### the aircrafi, inthe 

### form of a 

### placard. The label 

### will be 

### of a size that 

### will not 

### ovenrhelm the 

### aircraft, but

### will be 

### reasonably readable to someone near the 

### sUAS. The placard 

### outlined in

### the previous paragraph 

### will provide 

### sufficient identiflably should someone discover 

### the aircraft onthe ground.

14 CFR 91.9 

### Civil 

### aircraft

### flight manual, marking, and placard requirements. This regulation provides 

### that no person may operate an 

### aircraft unless a current, approved 

### flight manual is in

### the

### aircraft. The intent of

### this requirement is

### to ensure 

### that flight manual information isavailable to

### the aircrew 

### while operating 

### the aircraft. We request an exemption to

### this requirement since 

### the sUAS cannot carry such a manual, and if

### the sUAS 

### did carry 

### such manual, it

### would be unavailable to

### the crew 

### for review. To obtain an 

### equivalent level of safety and meet 

### the intent 

### of 91.9, 

### we propose that a current, sUAS 

### operation manual or 

### equivalent be available 

### the crew atthe ground station anytime the 

### aircraft is in,

### or preparing for, flight.

14 CFR 

### 91.109 

### Flight 

### instruction; Simulated instrument 

### flight and certain

### flight tests The regulation provides that 

### "No person may operate a civil aircraft 

### that is being used

### for flight instruction unless that 

### aircraft has fully functioning dual controls." The controls for a sUAS 

### do not 

### currently have aset offully 

### functioning dual 

### controls. lf a

### sUAS pilot is being trained, 

### the pilot performing the training 

### would be directly supervising and could 

### take over 

### the controls from 

### the pilot in

### training if

### the need 

### arose. This 

### would be similar 

### to the

### technique of a "throw-over type" control 

### wheel in some fixed 

### wing 

### aircraft. We feel that this

### technique meets 

### the intent 91 .109 and provides an 

### equivalent level of safety.

14 CFR 

### 91.119 

### Minimum safe 

### altitudes: General. The regulation provides that over 

### sparsely populated areas 

### the aircraft cannot be operated closer 

### than 500 feet

### to any person, vessel, 

### vehicle, or

### structure. Since the 

### typical mission ofthis sUAS 

### would be photography or

### surveyof persons, vessels, vehicles or structures it

### would be necessary 

### to operate closer 

### than 500 feet to

### the items 

### listed. Operations 

### will only be

### flown over property or persons 

### where permission has been obtained, and careful pre-planning has been 

### performed. Further, sUAS aircraft operate at avery slow airspeed, and a low mass, and 

### do not need as much space to operate safely, as outlined in 

### 91.119. We believe the slower speed, 

### smaller mass and careful pre-planning 

### would provide an 

### equivalent level of safety.

14

### CFR

### 9l.l21Altimeter settings. The regulation provides 

### that aircraft shall maintain cruising altitudes by reference 

### to an altimeter setting available 

### within 100 nautical miles of

### the aircraft. 

### The sUAS will normally be

### flying close tothe ground, and in line ofsight of

### the PIC or an observer. 

### This line of sight operation 

### will provide separation 

### from other aircraft, obstructions andterrain, and

### would override 

### the use of an altimeter for such 

### a 

### purpose. We feel that this



### will provide an 

### equivalent level of safety.

14 CFR 

### 91.151 Fuel 

### requirements for

### flight in VFR 

### conditions. The regulation provides 

### that no person may begin a

### flight in an 

### airplane under day-VFR 

### conditions unless 

### there is enough fuel to flyto

### thefirst point 

### of intended landing and to 

### fly after that 

### for at least 30 minutes. We feel 

### the intention of

### this paragraph it

### to provide a reasonable reserve of energy 

### to plan 

### for a

### safe landing should 

### there be a delay in 

### landing. The close proximity 

### tothe ground station, the ability 

### for both rotorcraft and small fixed 

### wing aircraft 

### to land in avery small space and 

### the built in energy level monitoring of

### the sUAS we

### feel provide an 

### equivalent level of safety ifthe

### flight is planned 

### to becompleted 

### with 2oo/obattery 

### energy 

### remaining. We request an exemption tothe

### word "fuel" and ask for an 

### equivalent interpretation with the

### word "energy".

14 CFR 

### Subpart E 

### (91.401 

### -91.4171- Maintenance, Preventive Maintenance, 

### and 

### Alterations The regulation provides that 

### the operator 

### is primarily responsible 

### for maintaining 

### the aircraft in an 

### airworthy condition, including compliance 

### with part 39 and 

### 43. Paragraphs 91.407 and 91.409 require that 

### the aircraft be "approved 

### for return 

### toservice by a person 

### authorized under 43.7" after maintenance 

### and inspection. lt is

### our intention that 

### the PIC perform maintenance 

### and inspection ofthe aircraft and 

### "be authorized 

### to approve the aircraft 

### for return 

### to seryice." Prior

### to every flight, 

### the PIC 

### will inspect 

### the aircraft 

### to ensure 

### that it is in an airworthy 

### condition. Any general maintenance procedures or replacement of 

### consumable items outlined by

### the sUAS manufacturer, if applicable, 

### will be complied 

### with by

### the 

### PlC. ln no circumstance 

### will a

### sUAS be 

### operated in a condition 

### that is deemed, or suspected 

### to be, 

### unsafe. lf such a

### determination is reached, and

### the problem cannot 

### be remedied 

### tothe satisfaction of

### the PlC, the sUAS 

### will not be 

### operated until consulting with the manufacturer or one 

### of it's authorized dealers 

### to complete necessary 

### repairs. We feel 

### that due

### tothe size, 

### construction, and 

### simplicity of

### the aircraft, 

### the PIC can 

### ensure an 

### equivalent level of safety.

8900.227 

### Paragraph 16(cXa) PIG 

### Medical. 

### and Paragraph 16(eX1) 

### Observer Medical. This policy provides 

### that both

### the PIC and observer must have a

### valid FAA second-class medical 

### certificate issued under part 67 in order 

### to perform as a pilot or observer. Requiring 

### the crew 

### to meet

### thesame medical requirements as a commercial pilot carrying passengers in

### a large 

### aircraft is

### an unnecessary burden. 

### We propose that 

### the minimum medical requirements be

### vision corrected 

### to 2012Oand a valid, 

### state-issued driver's 

### license. The risk 

### of both

### the PIC and observer becoming incapacitated at

### the same 

### time and suddenly is

### very 

### low. Further, since the 

### sUAS is operating close tothe 

### ground, it 

### could be brought in

### for landing in avery short 

### time if incapacitation 

### was

### suspected. Finally, most 

### sUAS's are equipped 

### with an 

### automatic return 

### to home feature which 

### would provide a

### final level of

### safety. We feel this would provide an 

### equivalent level of safety.4800 South 188s Street SeaTac, WA 98188-8605
CityHall: 206.973.4800 Fax: 206.973.4809 TDD: 206.973.4808

Mayor Mia Gregerson

Deputy Mayor Tony Anderson

Gouncilmembers Barry Ladenburg Kathryn Campbell Terry Anderson Dave Bush Pam Fernald

City Manager Todd Cutts

Assistant City Manager Gwen Voelpel
City Attorney Mary Mirante Bartolo
City Clerk Kristina Gregg Iuly 28,2014

D. Douglas Branch Slugwear, Inc. dba LikeonatreeAerial PO Box 16492 SeattleWA 981

### l6

Re: Videofor Connecting2S'hl24b Ave S Project

Dear Doug,

As you and I discussed, SeaTac is the lead agency for asignificant road construction project known as "Connecting 286124'h AveS". This projectwill connect an arterial road, as the name implies, located between S 200th St and S 208th St in SeaTac. This connectionwill complete the principal arterial route
on 28'h and24'hAve S in the cities of Des Moines and SeaTacfrom S2l6th St to S 188th St. The corurected corridor will provide anorth-south alternative to congested State Route 99, open access to undeveloped propertiesfor economic development and improve circulation around the new light rail station at S 200th St and 28thAve S.At atotal cost of over $25 million, it is the largest project theCity of SeaTac has undertaken in itstwenty four year history. Construction is expected to begin in about a year andthe new road opened in early 2017

.

There is apublic interest to educate and inform the public of this $25 million dollar public investment and to promote the needfor transportation funding. In order to get our message out and be distinguishable, we needto explore alternatives to simple narratives.A short videowill help achieve
our objectivesto educate, inform and promotewhich are all in the public interest.

The project currently is at a stage to generate some really captivating images. A recently completed milestone involved stockpiling high quality excavated soils generated fromwork at theairport. The stockpiles are quite impressive in that they contain enough material to

### fill about 67 Olympic sized swimming pools. Options of helicopter andfixed-wing aircraft to photographfrom above the stockpiles

were briefly considered but not pursued dueto concerns ofsafety, proximity to the airport and expense.

We have afantastic opportunity hereto utilize Small UnmannedAircraft Systems (uAUSs) to flyjust above the stockpiles and along the new road alignment. The captured images would be usedto create

an informative video thatwill play an instrumental role in explaining the project and promoting further transportation funding andtherefore be beneficial totheCity of SeaTacand the public.

In orderto beof the highest quality and be most beneficial, thevideo flight should occur soon during goodweather. Also, the sooner thevideo is produced, the more the public benefit can be maximized.

Should anyone needadditional information, I can be reached at 206-973-4741 ortsut(4ci.seatac.wa.us.

Best Regards, 

# Var.arzry-r

Tom Gut, PE Public Works Director

Attachment: VicinityMap 

## Cc: Gwen Voelpel, AssistantCity Manager

Florendo Cabudol, PE, Connecting2Sthl24'h Ave S Project Manager

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Date PrepaFd: Feb 27, 2014
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or implied as to accuracl, @mpleteness, or for any specific use. Not to be used for purposas :- of legal description or definition. Not a substitute ' for a proiessional suruey.