December 18, 2015
U.S. Department ofTransportation Docket Operations 1200 NewJersey Ave. SE Washington, D.C. 20590
Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regs. From 14CFR 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 ofthe FAA Modernization and Reform Act of2012 ("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 ofits small Unmanned Aircraft System ("sUAS's") for aerial imagingfor safety, monitoring ofsecured and controlled construction sites, and aerial photographic documentation of construction progress, so long as such activities are conducted within and underthe conditions outlined in this document or as may be established bythe FAA as required by Section 333.
As described in this document and the attached User Manuals, the requested exemption would permitthe use ofsUAS's under controlled and monitored conditions in airspace that is limited, predetermined, controlled as to access, and in a mannerthat would augment and supplementJoeris' existing safety practices and procedures used on all Joeris' construction sites. Approval ofthis exemption would thereby increase safety on Joeris' construction sites and fulfill the Secretary of Transportation's responsibilities to establish requirementsforthe safe operation of unmanned aircraft systems in the National Airspace System (NAS) as stated in Section 333 ofthe Modernization and Reform Act.
The name and address ofthe 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 2114 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 14CFR 91.109 14 CFR 91.119 14CFR 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. StatutoryAuthority For Exemptions
The Federal Aviation Act expressly grantsthe FAA authorityto issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined undersubsection 40101 ofthe Act, includes sUAS's, from the requirementthat all civil aircraft must have a current airworthiness certificate.
The Administrator maygrant an exemption from the requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section or any sections 44702-44716 ofthistitle ifthe Administrator finds the exemption in the public interest. 49 USC subsection 44701 (f) See also 49 USC subsection 44711 (a); 49 USC subsection 44704; 14CFR subsection 91.203 (a) (1).
Section 33 (b) ofthe 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, orthreats to national security. The aspects forthe Secretaryto consider when decidingwhether sUAS's may operate in the NAS without creating hazards to users, the public, or national security are "their size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight."
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 multirotoraircraft weighing less than 4 pounds with a maximum speed of30 knots. They have the ability to hover and move simultaneously in thevertical and horizontal planes. Joeris will operate the sUAS onlywithin the line ofsight ofthe operatorora spotter assisting the operator, and will limitthe range ofthe aircraft to withinJoeris' 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 2Vision+, and Phantom 3 User Manuals ("User Manuals"). Such use will ensure thatJoeris' operation ofthe sUAS will not create a hazard to other users ofthe NAS orthe general public.Considering the small size and alreadywidespread public use ofthe sUAS's Joeris intendsto use as well as the restricted nature ofthe areas in which Joeris intends to use them, this application falls within the zone of safetythat 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 ofthe sUAS, approval ofthis application presents no national security issues.



### 11. Public Interest
Joeris is submittingthis exemption application in congruence with Congress' intent in passing Section 333 (a) through (c) ofthe 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 ofthe rule making required under Section 332 ofthe same act. By grantingthis exemption the FAA will fulfill Congress' intent ofallowing UAS to operate with significant safety precautions in low risk environments. The use ofsUAS's in the construction industry offers many benefitsthat 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 tothe Occupational Safety and Health Administration, falls are the numberone cause offatalities on construction job sites. Workers are often raised offthe ground on lifts, ladders, or scaffolding while inspecting work in place, monitoringsite progress, or assessing the safety conditions of otherworkers. sUAS's can keep these workers on the ground and greatly reduce their risk offalling by providing a safer way to remotely accomplish these tasks. sUAS's can also be used toverify that crews working in a mannerthat requires fall protection are wearing appropriate equipment and properlytied off. By greatly reducing oreliminatingthe risk offalls, the use ofsUAS's on construction sites can save workers' lives. Construction sites are highly cbngested areas with dozens oreven hundreds oftradesmen completingwork, materials being stored around the site, and heavy equipment moving both to whereverthey need to go. Any distractions orcarelessness can easily lead to accidents. The use of sUAS's on construction sites can help reduce some ofthis congestion and keep some workers awayfrom it entirely. Using sUAS's for inspecting work offthe ground notonlyeliminatesthe 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 liftequipment around the site. The unique perspective ofthe sUAS also gives superintendents an abilityto routinely monitorand 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 asaferworking environmentfor all workers on the site. Currently, many projects are required to produce periodic aerial photographs ofthe site to document progress. This is accomplished withthe use of helicopters orfixed wing aircraft. These aircraft are hundreds oftimes largerthan the sUAS's Joeris proposes to fly in this application. They also carry large amounts ofcombustible 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 performingthis role musttake offat airports and fly over populated areas. Allowing sUAS's tofulfill this role offers a marked safety increase

### tothe general public by eliminatingflights of larger aircraft over populated areas and keeping pilots on the ground instead of in the air. The sUAS's proposed for use byJoeris use rechargeable lithium ion batteries, as opposed to the aviation fuel necessary for larger, manned aircraft. By allowingJoeris to utilize the proposed sUAS's to fulfill the site documentation role currentlyfilled by manned aircraft, the FAA could decrease the burning offossil fuels used by such manned aircraft and greatly reduce the environmental impact of these activities.



### Ill. 

### Equivalent Level of Safety Joeris proposesthatthe exemption we are requesting apply to civil aircraftthat have the characteristics and that operate within the limitations described in our request. The operation ofthese aircraft underthe limitations provides an equivalent or higher level ofsafetyto operations underthe current regulatory structure because the proposed operations are an enhancement tothe existing safety policies and procedures in place on constructionjob sites, as well as existing imaging and surveying operations conducted by manned helicopters and fixed wing aircraft. Joeris will notexceed the following limitationswhen 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 notcarry any load or equipmentthat is not approved by the sUAS manufacturerordesigned specifically for use with the sUAS. 2. Any rotary wing sUAS used byJoeris will be equipped with manufacturer approved rotor guards, ifavailable, to minimize the risk posed by its propellersto people and property in the event ofa malfunction orcollision. 3. All flights will be conducted within visual line ofsight ofthe pilot orsecond observer 4. The maximum total flighttime for any individual flight will notexceed 20 minutes. a. Joeris will only use sUAS'S that calculate their remaining battery percentage and flighttime in real time. b. Joeris will only use sUAS's that will return totheirground station automatically with at least a20% reserve battery level should that occur priortothe 20 minute limit. c. The return to home altitude ofany sUAS used by Joeris will be set higherthan all buildings and equipment within 2000feet ofthe operatorto prevent collisions in the eventthatthe aircraft returns to home at a critical battery level, but never more than 375 feet AGL. 5. Flights will be conducted at an altitude ofapproximately 200 feet AGL, and never more than 400 feetAGL. 6. The crew for each flight will consist ofa pilot and observer. 7. The sUAS pilotwill be trained in flight, operations, and safety procedures as outlined in the User Manuals. 8. The sUAS will only operate within the boundaries ofconstruction sites underJoeris' control, and will not be flown beyond these boundaries overadjacent property. Written and/ororal permission will be obtained from the relevant property owners. 9. The sUAS will notoperate within Class A, B, C, D, or Eairspace.10. Only the pilot and observer will be allowed within 40feet ofthetakeoffand landing area used forthe sUAS duringthese operations. 11. All onsite personnel will consent to the sUAS flyover by signed waiver 12. The pilotwill have been trained in the general operation ofsUAS's and demonstrated proficiency in takeoff, flight, and landing over an unoccupied area at an altitude notto exceed 100feet 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 abilityto return to its ground control station or land immediately in a controlled manner ifthe sUAS loses its control signal.


### 111. Description of Specific Regulations
14CFR Part 21, Subpart H: Airworthiness Certificates FAR §91.203 (a) 

### (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated withthe aircraftto be used by Joeris, an exemption from Part 21 Subpart H meetsthe requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. Both the Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 ofthe Reform Act authorize the FAA to exempt aircraftfor an airworthiness certificate upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe 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 ofthese criteria demonstratesthatthe sUAS operated without an airworthiness certificate, underthe proposed restrictions and restricted environment, will be at least as safe as or safer than a manned helicopter orfixed wing aircraft operating with an airworthiness certificate withoutthe restrictions and conditions proposed. Any sUAS operated byJoeris underthe proposed restrictions and conditionswill weigh no morethan 10 pounds when fully loaded, carries no explosive orflammable liquids or materials, and will be operated only over restricted access areas. Like othercivil aircraft, operations underthis exemption will be tightly controlled and monitored bythe operator, pursuantto the User Manual's requirements, and in compliance with all local public safety requirementsto provide securityforthe area ofoperation as is currently done on construction sites.
These safety enhancements, which already apply to civil aircraft operated in connection with construction sites, provide agreater degree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application ofthese same criteria demonstratethatthere is no credible threatto national security posed bythe sUAS due to its size, speed ofoperation, location ofoperation, lack ofexplosive or flammable materials or liquid fuels, and abilityto carry an external load less than two pounds. 

### 14CFR 45.23 (b): Marking ofthe 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," "lightsport," 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 ofthese words can be placed. Given the size ofthe 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 ofsafety will be provided by having the sUAS marked on itsfuselage as required by §45.29 (f) where the pilot, observer, and any others working withthe sUAS will see the identification of the sUAS as "Experimental." The FAA has issued thefollowing exemptions to this regulation: Exemption Nos. 10700, 8738, 10167 and 10167A. 

### 14CFR 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 ofsafety ofcurrent operations by requiring the pilot operatingthe aircraftto have demonstratedfamiliarization with the aircraft and its operations, as well as proficiency in takeoff, flight, and landing. This familiarization and proficiency would be proven through awritten examination on the aircraft's controls, preflight checklist, and safety requirements, as well as completion of 10 hours oflogged flight time and 20 unassisted takeoffs and landings. Unlike a manned aircraftthat carries a crew and passengers, the sUAS is remotely controlled with no livingthing or cargo on board. The area ofoperation 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 ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated in Part 61 when drafted,that allowing operations ofthe sUAS as requested with a pilotwho has demonstrated familiarity with the aircraft and its operation, as well as proficiency in flight, takeoff, and landing, exceeds the present level ofsafety achieved by 14CFR §61.113 (a) 

### & (b).



### 14CFR 91.7 (a): Civil Aircraft Airworthiness
This regulation statesthat 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 fordetermining airworthiness. Given the size ofthe aircraft and the requirements contained in the User Manualsfor maintenance and safety checklists priorto each flight, an equivalent level ofsafety will be provided. 

### 14CFR 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 aflight 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 safetywill be maintained by keeping the flight manual; atthe ground control pointwhere the pilotflying 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.

### 14CFR 91.103: Preflight Action
This regulation requires the pilot in command totake certain actions before flightto ensure the safety of theflight. An exemption is needed from this requirement as the pilotwill take separate preflight actions, including checking forweather conditions, checking flight battery requirements, checking takeoffand landing locations, and all other actions in the Preflight Checklist in the User Manuals. These actions will provide an equivalent level ofsafety.


### 14CFR 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 forflight instruction unless that aircraft has fullyfunctioning dual controls. By design, sUAS's and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates withthe aircraftvia radio communications.The FAA has previously approved exemptionsfor aircraft withoutfullyfunctional dual controls. See Exemption Nos. 5778K and 9862A. The equivalent level ofsafety is provided by the fact that neither a pilot nor passengers will be carried on the aircraft, the abilityto control the sUAS via radio signals from the controller, and by the size and speed ofthe aircraft.


### 14CFR 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes foroperation ofcivil aircraft. Section 91.119 (d) allows helicopters and be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route oraltitudes prescribed for helicopters by the FAA. This exemption is for a multirotorcraft thatflies similarlyto a helicopter, withvertical takeoffand vertical landing, which will typically operate at 200ftAGL, so an exemption may be needed to allow such operations. The sUAS will never operate above 400ftAGL and will be above 

### a restricted access area, where people and propertywill not be exposed to operations without prior consent. The equivalent level ofsafety will be achieved given the size weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or applicable local officials. Compared to flight operations with manned aircraft or rotorcraft weighing far morethan 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 500ftAGL in the construction industry. In addition, the low altitude operations of the UAS will ensure separation between these sUAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 

### 14CFR 91.121: Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead aGPS altitude readout, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator by confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.

# .....**--------------~**

14CFR 91.151 (a): Fuel Requirements for flight in VFR Conditions Section 91.151 (a) outlines fuel requirementsfor 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 poweringthe sUAS provides approximately 23 minutes offlight time. This is already below 30 minute reserve requirement in 14CFR 91.151. Given the limitations on the sUAS's proposed flight area and range, the fact that itwill not be carrying people or property, the proposed restriction to flight only during daylightVFR conditions, and the location of proposed operationswithin a predetermined 

### area, a shorter reserve time is reasonable.
Joeris believes that an exemption from 14 CFR 91.151 (a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate withoutcompliance with 14CFR 91.151 (a)). Operating the sUAS, in atightly controlled area where only people and propertyowners or official representatives who have signed waivers will be allowed, with less than the required 30 minutes of reserve fuel, does not presentthe risks that Section 91.151 (a) was intended to alleviate given the size, speed, and range of radio control ofthe sUAS. Additionally, requiring a 30 minute reserve when the aircraft's battery provides only 30 minutes offlighttime would nullifythe utilityofthe proposed exemption ifgranted.
An equivalent level ofsafety can be achieved by limitingflights to 20 minutes, or enough battery reserve to ensure thatthe sUAS lands atthe ground station with at least 20% ofbattery power in reserve (as determined by the onboard monitoring system and the pilot), whichever happens first. This restriction would be morethan 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. 

### 14CFR 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 itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe 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 documentsorto display them on the sUAS.
An equivalent level ofsafety will be established by keeping these documents atthe ground flight control pointwhere the pilotflying the sUAS will have immediate access to them, to the extentthey are

# --------------------

applicable tothe sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofotherexemptions 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 orowner :shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between require inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and othersshall inspect or maintainthe aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will notapplyto Joeris. Maintenance will be accomplished by the operator pursuant tothe flight manual and operating handbook as referenced in the manual. An equivalent level ofsafety 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 oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from an altitude no higherthan 400 feet AGL. As provided in the Manual, the operatorwill endure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany 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 ofsafety.

Pursuant to 14CFR 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:
14CFR Part 21, Subpart H: Airworthiness Certificates FAR §91.203 (a) (1) 14 CFR 45.23 (b): Marking ofthe Aircraft 14 CFR 61.113 (a) 

### & (b): Private Pilot Privileges and Limitations: Pilot In Command 14CFR 91.7 (a): Civil Aircraft Airworthiness 14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 14CFR 91.103: Preflight Action 14CFR 91.109: Flight Instruction 14CFR 91.119: Minimum Safe Altitudes 14CFR 91.121: Altimeter Settings 14CFR 91.151 (a): Fuel Requirements forflight in VFR Conditions 14 CFR 91.203 (a) 

### & (b): Carrying Civil Aircraft Certification and Registration 14CFR 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 ofexemptions allowing commercial operations ofsUAS's in the construction industry enhances safetywhile reducing risk. Manned aircraft monitoringand surveying create agreater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, asUAS weighing fewerthan 10 lbs and powered by batteries eliminates virtuallyall ofthe risk he reduced mass

# ------------------

and lack ofcombustible fuel on board. The sUAS will carry no passengers orcrew and, therefore, will not expose them tothe risks associated with manned aircraft flights.
The operation ofsmall UAS's, weighing less than lOibs, conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, and in a sterile environment and, as a result, are saferthan conventional operations conducted with turbine helicopters operating in close proximitytothe ground and people. 

### Privacy
All flights will occurover private or controlled access propertywith the property owner's priorconsent and knowledge. Images taken will be ofindividuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012
- size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide morethan adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant'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 StrategicTechnologies 

### & Integration

Michelle Seward-Davis Joeris General Contractors Chief Financial Officer