From: Norman Melendres 11090 SE 201 st St. Kent, WA 98031 September 1, 2015

Attn: U.S. Department of Transportation, Docket Operation West Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE Washington, DC 20590
To whom it may concern: SKP Lab respectfully requests an exemption from several provisions of Title 14of the Code of Federal Regulations (CFR) to permitthe use of small unmanned aerial systems (UAS) to assist in Surveillance, Agricultural Crop Surveys, Property Inspections, Real-estate marketing, special event coverage, Emergency and Rescue, Disaster Relief, Site Inspection, Electric Transmission & Distribution Line Inspection, Highway Monitoring, Environmental Compliance, and private UAS pilot training. Accordingly, the grant of an exemption is consistent with Congress' intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 (Modernization Act), that safe systems be permitted in the national airspace priorto the issuance of final regulations governing general use of these systems. A summary ofthis request suitable for publication in the Federal Register is provided as AppendixA. Appendix B provides the SKP Lab Operations Manual forflights covered underthis Exemption Request. Initially SKP Lab will be operating a 3DR- SOLO UAS. The manual presents information regarding the design, aircraft Performance, and fail-safe features. The latest version of the User Manual can be downloaded from the manufacturer's website. Initially SKP Lab will be operating a Tarot- 680P UAS. The manual presents information regarding the design, aircraft Performance, and fail-safe features. The latest version ofthe User Manual can be downloaded from the manufacturer's website.

liPageBackground Information SKP Lab is in the business ofareal videography, and surveying using UAS. Ouroperations include inspectionsfor agriculture and construction companies, sightsurveillance, real-estate, and other similar activities. We have developed specific SKP Lab Operational Proceduresto insure the safetyof all people, property, and the National Airspace System (NAS). As part ofthis SKP Lab is requesting FAA Exemption for UAS operationsfor safety, inspection andvideo capture usage. Regulatory Basisfor Exemption Request In addition to the waiver authority provided in §333 ofthe Modernization Act, the FAA maygrant an exemption under49 U.S.C. §44701(f) if it has determinedthat such an exemption is in the public interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affectsafety or howthe exemption would provide at least an equivalent level of safety as compliance with the underlying regulation. In this case, approval ofthis exemption would advance the public interest bysignificantly enhancing the safety and efficiency of infrastructure operations and by providing the FAAwith valuable userexperience on UAS in a contextwith appreciable economic and societal benefits. As described more fully below, the requested exemption would permitthe operation of UAS undertightly controlled conditions, thus ensuring that operationswill not have an adverse impacton safety. Tothe contrary, as explained below, SKP Lab operationswill serve to conduct activitiesthatare time consuming, technically difficult, and potentially hazardousfor non-UAS systems. Thus, the use of UAS hasthe potential to improve efficiency, resulting in faster, safer, and more efficient operations. Granting an Exemption will not Adversely Affect Safety SKP Lab notesthatthere is no applicable standard for an equivalency determination. It is clearthat equivalency cannot be established fortraditional, manned civil aircraft because the design and use profiles between traditional aircraft and UAS are simplytoo different. As such, we believe it makes more sense tofocus on whythe contemplated operationswould not adversely affectsafety, which is required by §11.81(e). Operations by SKP Lab will be conducted UAS operations over client owned orcontrolled land, at altitudeswell belowthatwhich would pose a risktothe NAS. In addition SKP Lab will be operating UAS at relatively lowspeeds. Accordingly, the risk of interference with anotheraircraft is minimal. SKP Lab also plansto conduct UAS operations at leastfive (5) milesfrom any airports (including heliports). In the eventan operation needsto be conducted closerto an airport, SKP Labwill contact the airport operatorand airport airtraffic control tower ofthe contemplated operation and will comply with all directions issued by airtraffic control atthat airport. Twoway radio communication will be maintained during the operation at such locations between the UAS operatorand AirTraffic Control (Or CTAF as applicable). Due tothe small size (Under551bs) and lackof combustible fuel the UAS poses little riskto structures, and equipment in the event of an accident. Additionallythe UASwill carry no passengers or crew and, therefore, will not expose them to the risks associatedwith manned aircraftflights. The operation ofsmall UASs, weighing lessthan 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafetysupportingthe grantofthe exemptions requested herein, including 333Aircraft Exemption Status exempting the applicantfrom conventional aircraft requirements and allowing commercial operations. These lightweightaircraftoperate atslowspeeds, ZIPageclose to the ground, and in a controlled environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. The safety ofthose on the ground is protected bythe factthat no one will be allowed into the area withoutthe permission of the UAS operator. Security will be established for the flight area as part of the pre-flight inspection. Each individual within the secure area will be briefed priorto flight and will consentto being in the area. All otherswill be excluded from the area. SKP Lab will use a dedicated stafffor UAS operations, each operatorwill hold holds an FAA Airman Certificate and at least a 3rd class medical. All operations will be within visual line-of-sight. Each PIC will conduct at leastthree take-offs and landings with the UAS on which he orshe is trained every 90 days. PIC'swill establish their qualificationsthru a combination of aeronautical knowledge, UAS airmanship skills, and verification through testing offlight ability before operations have commenced. Depending on the type of operation, additional ground-basedvisual observers may be employed as well. These observerswill be within constantvisual line of sight and in constant contactwith the PIC. The visual observerswill assistthe PIC in avoiding objects nearthe UAS. Minimum requirements for the PIC include: 1) Airline transport, commercial, private, recreational, orsport pilot FAA airman certificate and a Class Ill medical certificate; 2) A minimum of 20 flight cycles and 25 hours oftotal time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilotwith a similar UAS; 3) A minimum of 5 hours as UAS pilotwith the make and model of UASto be utilized for operations underthe exemption and 3 take offs and landings in the preceding 90 days; 4) Have undergone a qualification process as specified in the Flight Operations & Procedures Notes Regarding: 14 C.F.R. Part 21, Subpart H
In accordance with the statutory Criteria provided In Section 333 of PL 112---95 In reference To 49 USC 44704, And in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its operation, we request thatthis aircraft exemption meetsthe Conditions of Section 333. Therefore, if granted Section 333 Relief of 14 CFR Part 21, and any associated noise certification and testing requirements of part 36, is not necessary. Notes Regarding: 14C.F.R. § 45.23 (b). Marking ofthe Aircraft Given the size ofthe UAS, two-inch lettering will be impossible. The UASwill be identified by serial number, registered in accordance with 14CFR part47, and have identification (N---Number) markings in accordance with 14 CFR part45, Subpart C. Markings will be as large as practical. Notes Regarding: 14CFR § 91.7(a) Civil Aircraft Airworthiness SKP Lab request is based on the fact that no airworthiness certificate will be issued forthe UAS. SKP Lab's UAS will not require an airworthiness certificate in accordance with 14CFR part21, Subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from§ 91.7(a) is not necessary.

3IPageNotes Regarding: 14CFR § 91.9Cb)(2) Civil aircraftflight manual, marking & placard Certifications required, the original intent ofthese regulations was to display an aircraft's airworthiness, certification, and registration documents so theywould be easily available to inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014, the requested relief from 14 CFR 

### §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flighttests Small UASs, bytheir design, do not have fully functional dual controls. Flight control is accomplished through the use of a control boxthat communicateswith the aircraftvia radio communications. Aircraft being considered for use by SKP Lab allowthe UAS Instructorto place the aircraft into 'loiter' mode (fixed altitude stationary hold). In the event of the student losing control, the UAS Instructorcan quickly and via alternate equipment (equipment not in the hands of the student) place the aircraft into a mode that then allows the instructorto bring the aircraft back into control and backto the predetermined and/orsafe landing location. SKP Lab does not describe training scenarios in which a dual set of controls would be utilized or required, i.e. dual flight instruction, provided by aflight instructor or other company-designated individual, which would require that individual to have fully functioning dual controls. Rather, SKP Lab evaluates the qualification of its PIGs based on their experience with the UAS to be operated and verifies through testing, in lieu of formalized training. As such, SKP Lab does not seek relief from 14CFR 

### § 91.109. Notes Regarding§ 14CFR91.119(b) Relief from 

### § 14 CFR 91.119(b), operation over congested areas, is not applicable, because the SKP Lab's operationswill only be conducted within the secured area described herein.

41PageSupportfor Petition for Exemption In accordance with the procedural requirements of 14C.F.R. §11 .81 , SKP Lab provides the following information: Contact Information: Norman Melendres CEO/President, SKP Lab 11090 SE 201 St Kent, WA, 98031 (425) 943-1693 skplab@outlook.com William Grace FAA Consultant, SKP Lab 315 3rd St GoldBar, WA, 98251 (616) 634-5180 GracefuiWingsAviation@gmail.com Regulatory Provisionsfrom which SKP Lab seeks an Exemption SKP Lab believes it may need an exemption from the following provisions to conductthe contemplated operations. In some instances, relief is needed because relief from another provision renders compliance with the regulation at hand infeasible.

• 333Aircraft Exemption Status • 14 CFR §61.113(a) and (b) • 14 CFR §91.119(c) • 14CFR §91 .121 • 14 CFR §91.151 • 14CFR §91.405(a) • 14CFR §91.407(a) • 14 CFR §91.409(a)(1)&(2) • 14 CFR §91.417(a)&(b) SKP Lab believes an exemption is only needed from the above-listed regulatory provisions. Tothe extentthatthe FAA believes that additional relief is required for SKP Lab to conductthe operations described here, we request an exemption from any such regulatory provisions aswell.

SIPageThe Extent of Requested Relief and the Reasons Relief is Needed
14 C.F.R. §61.113(a) and (b) §61.113 Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. SKP Lab anticipates initially using a cadre of speciallytrained staffto conductthe UAS operations. While these individualswill not hold commercial pilot licenses. The UAS will notcarry propertyfor compensation or hire since theywill be used solelyto assist in evaluation of the infrastructure, equipment, right-of-way, assets, bridges, tunnels and out-buildings in furtherance of SKP Lab's client's primary business, the successful operation of a infrastructure; however, the employees' operation of the UASwill not be incidental to their employmentwith SKP Lab, and they will be compensated for such work. Without an exemption, the pilotwould be required to hold a commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations is less than the risk posed by atraditional aircraft. The UAS will fly at altitudeswell belowthe permissible limits for other civil aircraft, eliminating the riskto otheraircraft, and within a geographical envelope underthe sole control of SKP Lab clients. Accordingly, the risk would be limited to SKP Lab personnel, who will be appropriately outfitted in safety gear, and SKP Lab client's property on the ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on SKP Lab. Because the contemplated operations would not comply with §61.113(b)(1) and none ofthe other exceptionsto paragraph (a) apply, relief is needed from both paragraphs (a) and (b).
14 C.F.R. 91.119(c) §91.119 Minimum safe altitudes: General. Exceptwhen necessaryfortakeoff or landing, no person mayoperate an aircraft belowthe following altitudes: (c) Overotherthan congested areas. An altitude of500 feet above the surface, except over open water orsparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, orstructure. SKP Lab submitsthatthe only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinctto be meaningful. Since operations at this altitude also pose a heightened risk of collision with another aircraft, safetycan only be assured through the grantof an exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because an emergency landing ofthe aircraft due to a powerfailure will notcreate an undue hazard to persons or property on the surface. As noted in the explanation ofwhy an exemption will not adversely affectsafety, SKP Lab clients has exclusive use of the land overwhich the UAS will be operated, and public access is restricted. It also has exclusive use of significant portions of land adjacentto the infrastructure and structures that will be the objects of evaluation and analysis. SKP Lab's Clientstightly control accessto land and have the abilityto assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk of injury is
GIPageminimal. SKP Lab does not contemplate conducting operations over congested areas, so relief is not requested from paragraph (b).
14 C.F.R. 91.121 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation of the departure airport oran appropriate altimetersetting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved bythe operator, pursuantto the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Altitude information will be provided to the UAS pilotvia a digitally encoded telemetric datafeed, which downlinks from the aircraftto a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, ordigitally encoded barometric altimeter, or radio altimeter, oranycombination thereof. Priorto each flight, a zero altitude initiation pointwill be established and confirmedfor accuracy by the pilot.
14 C.F.R. 91.151 §91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin aflight in an airplane underVFR conditions unless (consideringwind and forecastweather conditions) there is enough fuel tofly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least30 minutes. (b) No person may begin aflight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least20 minutes. Operating the UAS in a pre-defined area with lessthan 30 minutes of reserve fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it hasto be flown to an alternate airport orcircle the planned airport in the event of unanticipated conditions. SKP Lab does not intend to use the UAS for point-to-pointflights and will notoperate the UAS beyond visual line of sight. Norwill the UAS require an airport in orderto land. Rather, SKP Labwill operate the UAS using pre-planned flight paths (taking into accountweather conditions) designed to allowthe UAS to fly to the point of intended landing. As such, there is no need for a time-based excess fuel requirement. Rather it should be sufficientto require only as much additional excess flight capacity as necessaryto safely land the UAS. We believe that a 25% battery reserve is more than sufficientto meetthis objective.

71Page14 C.F.R. 91.405(a), 91.407(a) (1), 14C.F.R. 91.409(a) (1)&(2) and 14C.F.R. 91.417(a) & (b) §91.405 Maintenance required. Each owneroroperator of an aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, exceptas provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter; §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate anyaircraftthat has undergone maintenance, rebuilding, oralteration unless- (1) It has been approved for return to service bya person authorized under §43.7 ofthis chapter; §91.409 Inspections. (a) Exceptas provided in paragraph (c) ofthis section, no person mayoperate an aircraft unless, within the preceding 12 calendar months, it has had

- (1) An annual inspection in accordance with part43 of this chapterand has been approved for return to service bya person authorized by §43.7 of this chapter; or(2) An inspection forthe issuance of an airworthiness certificate in accordance with part21 ofthis chapter. §91.417 {a) 

### &{b) SKP Lab believes that an exemption from these three maintenance requirements is appropriate because the FAA has notdeveloped maintenance standardsthatwould allow an operatorto meetthe part 91 maintenance requirements. In particular, there are no individuals authorized bythe FAAto approve a UASfor return to service under§91.407(a) orto conductthe initial airworthiness and annual return to service inspections required by§91.409(a). SKP Lab will maintain the aircraft as instructed in the owner's manual and ASTM F2909, where applicable, andwill notoperate the aircraft until it has reasonably determinedthat any needed repairs have been made. However, because of the technical impossibilityof meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate. Please do not hesitateto contact me atthe phone numberorviathe e-mail address provided above shouldyou have any questions orconcerns. ubmitted,

N.6rma elendres CEO/Pre ident, SKP Lab

SIPageAppendix A - Afor Federal Register

Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determine that publication is needed. Petitioner: Drone Fleet & Aerospace Management, Inc. (SKP Lab) Sections of 14 C.F.R. Affected:

• 333Aircraft Exemption Status • 14 C.F.R. §61.113(a) and (b) • 14C.F.R.§91.119(c) • 14C.F.R.§91.121 • 14C.F.R.§91.151 • 14 C.F.R. §91.405(a) • 14 C.F.R. §91.407(a) • 14 C.F.R. §91.409(a) • 14 C.F.R. §91.417(a)&(b) Description of Relief Sought: Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct UAS operations over SKP Lab Client's owned or controlled land, to assist in the safe evaluation and analysis of infrastructure and operations. In general, UAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature of operations anticipated by SKP Lab requires thatthe UAS be flown at relatively low altitudes. SKP Lab expects that in most instances, the UAS will be flown less than 75 feet from the highest structure along the path of the UAS and in no instanceswill be flown higherthan 400 feet above the ground. Accordingly, the risk of interference with otheraircraft is minimal.

9IPage

### Appendix 8- Operating Procedures
The following is SKP Labs operating instructions and procedures:

Technology Considerations: Best-in-class, tried and proven technologies that are in advanced iterations. Software from highlyreputable industry partners will include features

- 1. Auto descent (landing) if communication signal were to be severed. If the UAS loses communications, the UAS will have capabilityto return to a pre-determined location within the Security Perimeter and land.
2. Auto descent (landing) if batterywere to drop lowerthan nominal level. 3. Flights will be terminated at 25% battery power reserve. 4. Live video foroperator gives real-time positioning feedback. In otherwords, we can monitor the scene from the vehicle's perspective for collision avoidance, and to maintain spatial orientation.
5. The UAS will have the capabilityto abort aflight in case of unpredicted obstacles or emergencies. 6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all times: speed, altitude, numberof GPS satellites (when available), heading and voltage.
7. GPS locksuppliesfor return-to-home (RTH). Should Command and Control (C2) linkfailures occur (highly improbable), vehicle returns automaticallyto the point of launch. 8. Altitude information will be provided tothe UAS pilotvia a digitallyencoded telemetric data feed, which downlinksfrom the aircraftto a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, ordigitally encoded barometric altimeter, or radio altimeter, oranycombination thereof. Priorto each flight, a zero altitude initiation pointwill be established and confirmed for accuracy bythe pilot. Mechanical/Physical:
1. Wewill fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminating the concern of signal severance (flying behind objects/walls).
2. The UAS will weigh less than 55 lbs. and travel at lessthan 50 knots. 3. Batteries should far exceed the capacity required for actual flight time. 4. Flights will be operated at an altitude of no more than 400 feet AGL.

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### I Page5. UAS operated underthis Exemption will be marked in accordance with 14 CFR part45, or as otherwise authorized by the FAA. Personnel: 1. Spotters ensure safe operation and act as a redundant setof eyesfor operators (pilot, gimbal operator, director)
2. A briefing will be conducted in regard to the planned UAS operations priorto each day's activities. Itwill be mandatorythat all personnel who will be performing dutieswithin the boundaries of the safety perimeter be presentfor this briefing. 3. The operatorwill obtain the consent of all persons involved in the UAS operations and ensure that only consenting persons will be allowed within 100feet ofthe flight operations.
4. Observer and pilotwill at all times be able to communicate byvoice.
5. Written and/or oral permission from the relevant property holderswill be obtained. 6. Pilot and observerwill have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated.
7. Additional precautionswill be applied during UAS operations as being prudentto put operational signs to properly control and secure operations perimeter, informing close by residents, emergency and response crews, police/paramedics, et. al, who are in proximity during operation.

111PageOperations: 1. The UAS mustweigh less than 55 pounds, including energy source(s) and equipment. Operations authorized bythis petition of exemption are limited to the following aircraft described in Appendix B. Proposed operations of any otheraircraftwill require a new petition or a petition amendmentto this request. 2. The UAS may not be flown at a ground speed exceeding 50 knots. 3. Flights must be operated atan altitude of no more than 400 feet above ground level (AGL), as indicated bythe procedures specified in the operator's manual. All altitudes reported to ATC mustbe in feetAGL.
4. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC atall times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued medical certificate.
5. All operations must utilize a visual observer (VO). The VO may be used to satisfythe VLOS requirement as long asthe PIC always maintains VLOS capability. The VO and PIC mustbe able to communicate verbally atall times. The operator may update or revise its operator's manual. It is the operator's responsibilityto track such revisions and present updated and revised documentstothe Administrator upon request. The operator mustalso present updated and revised documents if it petitionsfor extension oramendment. Ifthe operatordeterminesthat any update or revision would affect the basisforwhich the FAA grants this petition for exemption, then the operator must petition for amendmentto theirexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions tothe operator's manual. 6. Priorto each flight the PIC must inspectthe UAS to ensure it is in a condition forsafe flight. If the inspection reveals a condition that affectsthe safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safeflight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraft records.
7. Any UAS that has undergone maintenance oralterations that affectthe UAS operation orflight characteristics, e.g. replacement of aflight critical component, must undergo afunctional test flight in accordance with the operator's manual. The PIC who conductsthe functional testflight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for afunctional testflight and aircraft record entry must be added to the operator's manual.
8. Aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be in accordance with the manufacturers manual:

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### I Page a. Actuators 

### I Servos; b. Transmission (single rotor); c. Motors; d. Propellers; e. Electronicspeed controller; f. Batteries; g. Mechanical dynamiccomponents (single rotor);h. Remote command and control; i. Ground control station (if used); and j. Any other components as determined by the operator; 9. The Pilot In Command (PIC) must possess at least an airline transport, commercial, private, recreational, orsport pilot FAA airman certificate and at least a current third-class medical certificate. The PIC must also meetthe flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
1

0. Priorto operations conducted, the PIC must have accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51 (b), a minimum of 20flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 1 0 hours logged as a UAS pilotwith a similar UAS type (single blade or multirotor). Prior documented flight experience thatwas obtained in compliance with applicable regulations may satisfythis requirement. Training, proficiency, and experience-building flights can also be conducted underthis petition of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential forflight operations are considered nonparticipants, and the PIC mustoperate the UAwith appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119 11. Prior to operations, the PIC must have accumulated and logged, in a mannerconsistentwith 14 CFR 

### § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations underthe exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience building, and take-off and landing currency flights can be conducted underthis petition of exemption to accomplish the required flight time and 90 daycurrency. During training, proficiency, experience-building, and take-off and landing currency flights all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119. 12. Priorto anyflight operations authorized by this petition of exemption, the PIC and VO must have successfully completed a qualification process. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated atthe sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request. 13. Priorto operations, aflight demonstration, administered by an operator-approved and

- qualified pilot must be successfully completed and documented. This documentation must be available for review upon request bythe Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standardsthat support ajurisdictional FAA FSDO evaluation and approval of company designated examiners.
14.The UAS may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardousto persons or property on the surface in the event of a UAS failure or emergency. 15. Regarding the distance from participating persons, the operator's manual has safety mitigationsfor authorized and consenting personnel. At all times, those persons must be essential to the operations. 13 

### I Page16. Regarding distance from nonparticipating persons, the operator mustensure that no persons are allowed within 500feet ofthe area exceptthose consenting to be involved and necessary forthe infrastructure inspection operations. This provision may be reduced to no less than 200 feet if itwould not adversely affectsafety and the Administrator has approved it. For example, an equivalent level ofsafety may be determined by an aviation safety inspector's evaluation of the infrastructure inspection areato note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an accident. 17.1fthe UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeterand land orbe recovered. 18.The UAS mustabortthe flight in the event of unpredicted obstacles oremergencies. 19. Each UAS operation must be completed with 15% battery power remaining. 20.All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part47, and have identification (N-Number) markings in accordance with 14CFR part45, Subpart C. Markings must be as large as practical.
21.The operator must develop proceduresto documentand maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service ofthe UAS.
22. Each UAS operated underthis exemption mustcomplywith all manufacturer Safety Bulletins.

23.The preflight inspection must accountfor all discrepancies, i.e. inoperable components, items, orequipment, not covered in the relevant preflight inspection sections ofthe manufacturer's manual.
24.The documents required under 14 CFR 

### §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS anytime the aircraft is operating. These documents must be made available tothe Administrator orany lawenforcementofficial upon request. 25.The UAS must remain clearand yield the right ofwayto all other manned operations and activities atall times (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, hang gliders, etc.). 26. UAS operations may not be conducted during night, as defined in 14CFR 

### § 1.1. All operations mustbe conducted undervisual meteorological conditions (VMC). Flights underspecial visual flight rules (SVFR) are notauthorized.
27.The UAS may not be operated lessthan 500feet below or less than 2,000feet horizontally from a cloud orwhen visibility is less than 3 statute milesfrom the PIC. 28.The UAS may not operate in Class B, C, or D airspace withoutwritten approval from the FAA. The UAS may notoperate within 5 nautical miles ofthe geographic centerof an airport as denoted on a current FAA-published aeronautical chart unless a letterof agreementwith that 14 

### I Pageairport's management is obtained, and the operation is conducted in accordance with a NOT AM as required bythe operator's COA. The letterof agreementwith the airport management must be made available to the Administrator upon request. 29.Any incident, accident, orflight operation thattransgresses the lateral orvertical boundaries of the operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSBWeb site: www.ntsb.gov. Furtherflight operations may not be conducted until the incident, accident, or transgression is reviewed byAFS-80 and authorization to resume operations is provided.

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