December 18, 2015 

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Ave. SE 

Washington, D.C. 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regs. 

From 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 

91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("the Modernization 

and Reform Act") and 14 CFR Part 11, Joeris General Contractors, Ltd (Joeris), a general construction 

firm, hereby applies for an exemption from the listed Federal Aviation Regulations ("FAR's") to allow 

commercial operation of its small Unmanned Aircraft System ("sUAS's") for aerial imaging for safety, 

monitoring of secured and controlled construction sites, and aerial photographic documentation of 

construction progress, so long as such activities are conducted within and under the conditions outlined 

in this document or as may be established by the FAA as required by Section 333. 

As described in this document and the attached User Manuals, the requested exemption would 

permit the use of sUAS's under controlled and monitored conditions in airspace that is limited, 

predetermined, controlled as to access, and in a manner that would augment and supplement Joeris' 

existing safety practices and procedures used on all Joeris' construction sites. Approval of this 

exemption would thereby increase safety on Joeris' construction sites and fulfill the Secretary of 

Transportation's responsibilities to establish requirements for the safe operation of unmanned aircraft 

systems in the National Airspace System (NAS) as stated in Section 333 of the Modernization and 

Reform Act. 

The name and address of the applicant is: 

Joeris General Contractors, Ltd 

Andrew Pitcher 

Phone:210-494-1638 

Email: apitcher@joeris.com 

Address: 823 Arion Pkwy. 

San Antonio, TX 78250 

The regulations from which the exemption is requested: 

14 CFR Part 21 
14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

1. Statutory Authority For Exemptions 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under subsection 40101 of the Act, 

includes sUAS's, from the requirement that all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from the requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 USC subsection 44701 (f) See also 49 USC subsection 

44711 (a); 49 USC subsection 44704; 14 CFR subsection 91.203 (a) (1). 

Section 33 (b) of the Modernization and Reform Act tasks the Secretary with deciding with 

deciding whether sUAS's can operate in the NAS without creating hazards to users, the public, or threats 

to national security. The aspects for the Secretary to consider when deciding whether sUAS's may 

operate in the NAS without creating hazards to users, the public, or national security are "their size, 

weight, speed, operational capability, proximity to airports and populated areas, and operation within 

visual line of sight." 

Joeris intends to use various models of DJI's Phantom 2 quadcopter, a sUAS that is commercially 

available to the public and already in widespread use by many amateur and hobbyist sUAS pilots. These 

sUAS's are multirotor aircraft weighing less than 4 pounds with a maximum speed of 30 knots. They 

have the ability to hover and move simultaneously in the vertical and horizontal planes. Joeris will 

operate the sUAS only within the line of sight of the operator or a spotter assisting the operator, and will 

limit the range of the aircraft to within Joeris' construction site boundaries. Joeris has controlled access 

construction sites, so the sUAS will not be flown over publicly accessible areas. Joeris will enforce this 

limitation using methods described in the attached Phantom 2, Phantom 2 Vision, Phantom 2 Vision+, 

and Phantom 3 User Manuals ("User Manuals"). Such use will ensure that Joeris' operation of the sUAS 

will not create a hazard to other users of the NAS or the general public. 
Considering the small size and already widespread public use of the sUAS's Joeris intends to use 

as well as the restricted nature of the areas in which Joeris intends to use them, this application falls 

within the zone of safety that Congress intended the FAA to allow commercial sUAS's to operate under 

by exemption. Also, considering the operational environment, small size, and already widespread public 

use of the sUAS, approval of this application presents no national security issues. 

11. Public Interest 

Joeris is submitting this exemption application in congruence with Congress' intent in passing 

Section 333 (a) through (c) of the Modernization and Reform act. This section requires the Secretary of 

Transportation to assess whether certain UAS's may safely operate within the NAS before the 

completion of the rule making required under Section 332 of the same act. By granting this exemption 

the FAA will fulfill Congress' intent of allowing UAS to operate with significant safety precautions in low 

risk environments. 

The use of sUAS's in the construction industry offers many benefits that fit the public interest. 

Among these benefits are decreases in fall hazards, safer working areas due to decreases in site 

congestion, decreases in flights over public areas, and decreases in emissions. 

According to the Occupational Safety and Health Administration, falls are the number one cause 

of fatalities on construction job sites. Workers are often raised off the ground on lifts, ladders, or 

scaffolding while inspecting work in place, monitoring site progress, or assessing the safety conditions of 

other workers. sUAS's can keep these workers on the ground and greatly reduce their risk of falling by 

providing a safer way to remotely accomplish these tasks. sUAS's can also be used to verify that crews 

working in a manner that requires fall protection are wearing appropriate equipment and properly tied 

off. By greatly reducing or eliminating the risk of falls, the use of sUAS's on construction sites can save 

workers' lives. 

Construction sites are highly cbngested areas with dozens or even hundreds of tradesmen 

completing work, materials being stored around the site, and heavy equipment moving both to 

wherever they need to go. Any distractions or carelessness can easily lead to accidents. The use of 

sUAS's on construction sites can help reduce some of this congestion and keep some workers away from 

it entirely. Using sUAS's for inspecting work off the ground not only eliminates the fall hazard posed to 

the inspector, it keeps him away from congestion, greatly reduces drop hazards that would be under 

and around him, and reduces the use of lift equipment around the site. The unique perspective of the 

sUAS also gives superintendents an ability to routinely monitor and analyze the organization of laydown 

areas so that space can be used more efficiently in congested areas. This would give workers more room 

to work and reduce site traffic, which would lead to a safer working environment for all workers on the 

site. 

Currently, many projects are required to produce periodic aerial photographs of the site to 

document progress. This is accomplished with the use of helicopters or fixed wing aircraft. These aircraft 

are hundreds of times larger than the sUAS's Joeris proposes to fly in this application. They also carry 

large amounts of combustible fuel, unlike the battery powered sUAS's proposed in this application. 

Additionally, Joeris' proposed sUAS's can take off, fly over, and land solely over controlled access areas, 

whereas the helicopters and small fixed wing aircraft currently performing this role must take off at 

airports and fly over populated areas. Allowing sUAS's to fulfill this role offers a marked safety increase 
to the general public by eliminating flights of larger aircraft over populated areas and keeping pilots on 

the ground instead of in the air. 

The sUAS's proposed for use by Joeris use rechargeable lithium ion batteries, as opposed to the 

aviation fuel necessary for larger, manned aircraft. By allowing Joeris to utilize the proposed sUAS's to 

fulfill the site documentation role currently filled by manned aircraft, the FAA could decrease the 

burning of fossil fuels used by such manned aircraft and greatly reduce the environmental impact of 

these activities. 

Ill. Equivalent Level of Safety 

Joeris proposes that the exemption we are requesting apply to civil aircraft that have the 

characteristics and that operate within the limitations described in our request. The operation of these 

aircraft under the limitations provides an equivalent or higher level of safety to operations under the 

current regulatory structure because the proposed operations are an enhancement to the existing 

safety policies and procedures in place on construction job sites, as well as existing imaging and 

surveying operations conducted by manned helicopters and fixed wing aircraft. 

Joeris will not exceed the following limitations when conducting operations with a sUAS under 

an FAA issued exemption: 

1. Any sUAS used by Joeris will weigh no more than 10 pounds and will not carry any load 

or equipment that is not approved by the sUAS manufacturer or designed specifically for 

use with the sUAS. 

2. Any rotary wing sUAS used by Joeris will be equipped with manufacturer approved rotor 

guards, if available, to minimize the risk posed by its propellers to people and property 

in the event of a malfunction or collision. 

3. All flights will be conducted within visual line of sight of the pilot or second observer 

4. The maximum total flight time for any individual flight will not exceed 20 minutes. 

a. Joeris will only use sUAS'S that calculate their remaining battery percentage and 

flight time in real time. 

b. Joeris will only use sUAS's that will return to their ground station automatically 

with at least a 20% reserve battery level should that occur prior to the 20 

minute limit. 

c. The return to home altitude of any sUAS used by Joeris will be set higher than all 

buildings and equipment within 2000 feet of the operator to prevent collisions 

in the event that the aircraft returns to home at a critical battery level, but 

never more than 375 feet AGL. 

5. Flights will be conducted at an altitude of approximately 200 feet AGL, and never more 

than 400 feet AGL. 

6. The crew for each flight will consist of a pilot and observer. 

7. The sUAS pilot will be trained in flight, operations, and safety procedures as outlined in 

the User Manuals. 

8. The sUAS will only operate within the boundaries of construction sites under Joeris' 

control, and will not be flown beyond these boundaries over adjacent property. Written 

and/or oral permission will be obtained from the relevant property owners. 

9. The sUAS will not operate within Class A, B, C, D, or E airspace. 
10. Only the pilot and observer will be allowed within 40 feet of the takeoff and landing 

area used for the sUAS during these operations. 

11. All onsite personnel will consent to the sUAS flyover by signed waiver 

12. The pilot will have been trained in the general operation of sUAS's and demonstrated 

proficiency in takeoff, flight, and landing over an unoccupied area at an altitude not to 

exceed 100 feet AGL before being authorized to fly the sUAS over an active job site or 

otherwise occupied area. 

13. All required permissions and permits will be obtained from state, county, and city 

jurisdictions, including emergency response services or other appropriate governmental 

agencies. 

14. Any sUAS used by Joeris will have the ability to return to its ground control station or 

land immediately in a controlled manner if the sUAS loses its control signal. 

111. Description of Specific Regulations 

14 CFR Part 21, Subpart H: Airworthiness Certificates FAR §91.203 (a) (1) 

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 size and limited operating area 

associated with the aircraft to be used by Joeris, 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. Both the 

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act authorize the FAA to 

exempt aircraft for an airworthiness certificate upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. Joeris' small 

UAS will be operated at low speed in controlled environments, at least five miles from airports, and only 

over restricted access areas. An analysis of these criteria demonstrates that the sUAS operated without 

an airworthiness certificate, under the proposed restrictions and restricted environment, will be at least 

as safe as or safer than a manned helicopter or fixed wing aircraft operating with an airworthiness 

certificate without the restrictions and conditions proposed. 

Any sUAS operated by Joeris under the proposed restrictions and conditions will weigh no more than 10 

pounds when fully loaded, carries no explosive or flammable liquids or materials, and will be operated 

only over restricted access areas. Like other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the operator, pursuant to the User Manual's requirements, and in 

compliance with all local public safety requirements to provide security for the area of operation as is 

currently done on construction sites. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

construction sites, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart 

H. Lastly, application of these same criteria demonstrate that there is no credible threat to national 

security posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive or 

flammable materials or liquid fuels, and ability to carry an external load less than two pounds. 

14 CFR 45.23 (b): Marking of the Aircraft 

14 CFR 45.23 (b) requires certain experimental, provisionally certificated aircraft, or light sport category 

aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light 
sport," or "provisional," near each entrance to a cabin, cockpit, or pilot station. Even though the sUAS 

will have no airworthiness certificate, an exemption may be necessary because the sUAS will not have a 

cabin, cockpit, or pilot station on which any of these words can be placed. Given the size of the sUAS, 

two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer, and any others working with the sUAS will see the identification of 

the sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemption 

Nos. 10700, 8738, 10167 and 10167 A. 

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot In Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the pilot operating the aircraft to have demonstrated familiarization with the 

aircraft and its operations, as well as proficiency in takeoff, flight, and landing. This familiarization and 

proficiency would be proven through a written examination on the aircraft's controls, preflight checklist, 

and safety requirements, as well as completion of 10 hours of logged flight time and 20 unassisted 

takeoffs and landings. 

Unlike a manned aircraft that carries a crew and passengers, the sUAS is remotely controlled with no 

living thing or cargo on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance to minimize the risk to any bystanders or property below or around 

the aircraft while in flight. The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with commercial operations contemplated in Part 61 when drafted, that 

allowing operations of the sUAS as requested with a pilot who has demonstrated familiarity with the 

aircraft and its operation, as well as proficiency in flight, takeoff, and landing, exceeds the present level 

of safety achieved by 14 CFR §61.113 (a) & (b). 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

This regulation states that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the User Manuals for maintenance and safety checklists prior to each flight, 

an equivalent level of safety will be provided. 

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 

The sUAS, given its size and configuration, has no ability or place to carry a flight manual on the aircraft. 

As there is no pilot on board, there is no need such an item on the aircraft itself. The equivalent level of 

safety will be maintained by keeping the flight manual; at the ground control point where the pilot flying 

the sUAS will have immediate access to it. The FAA has issued the following exemption to this 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 

and 10700. 
14 CFR 91.103: Preflight Action 

This regulation requires the pilot in command to take certain actions before flight to ensure the safety of 

the flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, 

including checking for weather conditions, checking flight battery requirements, checking takeoff and 

landing locations, and all other actions in the Preflight Checklist in the User Manuals. These actions will 

provide an equivalent level of safety. 

14 CFR 91.109: Flight Instruction 

Section 91.103 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. 

By design, sUAS's and remotely piloted aircraft do not have fully functional dual controls. Flight control 

is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has previously approved exemptions for aircraft without fully functional dual 

controls. See Exemption Nos. 5778K and 9862A. The equivalent level of safety is provided by the fact 

that neither a pilot nor passengers will be carried on the aircraft, the ability to control the sUAS via radio 

signals from the controller, and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters and 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. This exemption is 

for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which 

will typically operate at 200ft AGL, so an exemption may be needed to allow such operations. The sUAS 

will never operate above 400ft AGL and will be above a restricted access area, where people and 

property will not be exposed to operations without prior consent. 

The equivalent level of safety will be achieved given the size weight, and speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

applicable local officials. Compared to flight operations with manned aircraft or rotorcraft weighing far 

more than the maximum 10 pounds proposed in this request and carrying flammable fuel, any risk 

associated with the proposed operations is far less than those presented with such conventional aircraft 

operating at or below 500ft AGL in the construction industry. In addition, the low altitude operations of 

the UAS will ensure separation between these sUAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. 

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 sUAS may not have a barometric altimeter, but instead a GPS 

altitude readout, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator by confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 
..... --------------~ 

14 CFR 91.151 (a): Fuel Requirements for flight in VFR Conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The proposed 

UAS's are limited to operations in sterile and controlled environments as outlined in the User Manual, 

and has a limited range and flight time which require an exemption from 14 CFR 91.151 (a). 

The battery powering the sUAS provides approximately 23 minutes of flight time. This is already below 

30 minute reserve requirement in 14 CFR 91.151. Given the limitations on the sUAS's proposed flight 

area and range, the fact that it will not be carrying people or property, the proposed restriction to flight 

only during daylight VFR conditions, and the location of proposed operations within a predetermined 

area, a shorter reserve time is reasonable. 

Joeris believes that an exemption from 14 CFR 91.151 (a) falls within the scope of prior exemptions. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 14 CFR 

91.151 (a)). Operating the sUAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than the required 30 minutes 

of reserve fuel, does not present the risks that Section 91.151 (a) was intended to alleviate given the 

size, speed, and range of radio control of the sUAS. Additionally, requiring a 30 minute reserve when the 

aircraft's battery provides only 30 minutes of flight time would nullify the utility of the proposed 

exemption if granted. 

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery reserve 

to ensure that the sUAS lands at the ground station with at least 20% of battery power in reserve (as 

determined by the onboard monitoring system and the pilot), whichever happens first. This restriction 

would be more than adequate to return the sUAS to its planned landing zone from anywhere within the 

operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808. 

14 CFR 91.203 (a) & {b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in part 

(a) Except asprovided in §91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) 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 authorization issued under §91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers and crew. 

The sUAS fully loaded weighs no more than 10 lbs and is operated without an onboard pilot. Therefore 

there is no place to carry certification and registration documents or to display them on the sUAS. 

An equivalent level of safety will be established by keeping these documents at the ground flight control 

point where the pilot flying the sUAS will have immediate access to them, to the extent they are 
--------------------

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9816A, and 10700. 

14 CFR 91.405 (a); 407 {a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner :shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between require inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Joeris. Maintenance will be accomplished by the operator pursuant to the 

flight manual and operating handbook as referenced in the manual. An equivalent level of safety will be 

achieved because these small UAS's are limited in size, will carry a small payload, and will only operate 

in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately 

and will be operating from an altitude no higher than 400 feet AGL. As provided in the Manual, the 

operator will endure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator 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. 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Applicant seeks exemption from the following rules: 

14 CFR Part 21, Subpart H: Airworthiness Certificates FAR §91.203 (a) (1) 

14 CFR 45.23 (b): Marking of the Aircraft 

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot In Command 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 

14 CFR 91.103: Preflight Action 

14 CFR 91.109: Flight Instruction 

14 CFR 91.119: Minimum Safe Altitudes 

14 CFR 91.121: Altimeter Settings 

14 CFR 91.151 (a): Fuel Requirements for flight in VFR Conditions 

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections 

to operate commercially a small unmanned vehicle (SSibs or less) in construction operations. 

Approval of exemptions allowing commercial operations of sUAS's in the construction industry enhances 

safety while reducing risk. Manned aircraft monitoring and surveying create a greater risk because the 

craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS 

weighing fewer than 10 lbs and powered by batteries eliminates virtually all of the risk he reduced mass 
and lack of combustible fuel on board. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft flights. 

The operation of small UAS's, weighing less than lOibs, conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile 

environment and, as a result, are safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. Images taken will be of individuals who have also consented to being filmed or 

otherwise have agreed to be in the area where aerial photography will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security- provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UAS's in construction industry pursuant to the 

appended Manual. 

Sincerely, 

Andrew Pitcher 

Joeris General Contractors, LTD 

Sr. BIM Specialist 

Kristian Pearson 

Joeris General Contractors 

VP Strategic Technologies & Integration 

Michelle Seward-Davis 

Joeris General Contractors 

Chief Financial Officer