Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI May 5 , 2015

Strat Aero International, Inc. 19500 State Highway 249

Suite 655 Houston, TX 77070

U .S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Subject: Exemption Request under Section 333 of the Federal Aviation Administration Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Mod ernization and Reform Act of 20 12 (the “Reform Act”) and Title 14 of the Code of Federal Regulations (CFR) Part 11, Strat Aero International, Inc. (“Strat Aero”), a Texas

- based business providing aviation consulting , aviation software, and UAS training

, s eeks exemptions for the Federal Aviation Regulations (“FARs”) in order to train Strat Aero UAS operators and to provide aerial photography and persistent surveillance of multiple events and facilities . Strat Aero’s limited proposed use of sUASs does not create a hazard to the public or other aircraft in the national air space (NAS), nor does it threaten national security. The small size, low speed, and safety features of the sUASs to be used and operating distance from populated areas ensure the proposed operations would be safer than conducting the same operations with manned aircraft and as such is in the best interest of the public . Strat Aero’s proposed use of sUASs addresses criteria identified in the FAA’s ex emptions granted to Commonwealth Edison (Exemption No. 11185), BNSF Railway Com pany (Exemption No. 11206), Phoenix Air Unmanned (Exemption

No. 11241 )

, State Farm Mutual Automobile Insurance Company (Exemption No. 11188) and the City of Roswell Coalition (E xemption No. 11265)

. Please note that Strat Aero is the operator for the City of Roswell Coalition as
d escrib ed in the City of Roswell Coalition E xemption , and w henever possible, Strat Aero o perations will be similar to those approved the same exemption (No. 11265)

.

The requested exemptions would permit Strat Aero to conduct operations with the Aerialtronics Altura Zenith

ATX8 , the ST R8 (an octocopter with operation al characteristics similar to the Ascending Technologies Falcon 8

sUAS ), the Aeryon Labs S kyRanger , and/or the DJI S1000 for various purposes ( please refer to section 6 for a
detailed list

.

Strat Aero would issue a NOTAM to Air Traffic Control in the area and follow all safety protocols to inspect
these facilitie s with sUASs. Strat Aero believes using sUASs responsibly to conduct these types of inspections is immensely safer than having personnel or manned aircraft conduct the same inspections.Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI The aerial data provided by a UAS will improve the ability of cust omer companies to assess the condition and safety of their equipment in a timely manner, thereby enhancing safety for customer companies and for their
customer bases

.

Strat Aero UAS flying operations under the exemption will be conducted according to str i ct standard operating procedure s and safety guidelines as set forth by the operator and as may be modified by the FAA. Any sUAS system operated by Strat Aero will be flown under controlled conditions by qualified operators. It will be flown
at l ow altitudes in airspace that are limited in scope with the exception of industrial inspections as described in
section 7 below and only under strict conditions . Strat A ero operations with these sUASs will not be conducted in a way that violates established industry privacy guidelines or reasonable expectations of privacy

.

Regarding the Unmanned Aircraft System

1. Safety
Characteristics of the Aerialtronics Altura Zenith

The Altura Zenith ATX8 is an octocopter that can be flown with a tablet or radio controls and can carry a wide array of sensors. The Zenith has a maximum takeoff weight of 8.5 kg (18 lbs ) and measures 23.6
inches square. It can fly for up to 3 5 minutes at a time and has a max imum cruise speed of 20 m/s ( 40 kts ).
This sUAS has software that allows for automatic take

- off and landing, automatic fly home and landing, GPS waypoint navigation, direction lock, and geographic information system (GIS) mapping. The FAA has previously granted exemptions for this model UAS.

Characteristics of the STR8

The STR8 s UAS consists of an unmanned vehicle, a remote control, and a mobile ground station. The aerial
vehicle consists of a small V

- form rotorcraft lifted and propelled by eight rotor s. It is electrically powered by lithium power and therefore presents no fuel spill risk. The STR 8 has enhanced safety features including
constant self

- monitoring, resistance to external magnetic disturbances, two independent data links, three

emergency modes, and battery life monitoring. Each of these features help mitigate the risks inherent in flying

.

The aerial vehicle can hold a pre

- planned position

. All systems monitor their operational status and battery
life

. An enhanced contingency detection system automatically notifies the pilot when error statuses are
detected. There are three emergency modes from which the pilot can choose should the data links be lost

– the pilot can direct an immediate landing or that t he system return to base at its current height or at maximum mission height (whichever is the safest option).Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI Airworthiness of the Aeryon SkyRanger

The Aeryon SkyRan ger provides two semiautonomous flight modes using a point

- and

- click map and video

i nterface. The user clicks on a map to direct the SkyRanger to fly to the point on the map where the operator is pointing, or programmed flight plans may be entered for a series of waypoints or grid

- based

area. Additional navigation aids including landing zones and flight areas may be designated to ensure the SkyRanger operates o nly within user

- specified flight parameters ( geo

- fencing)

. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the high stability and reliability in challenging weather conditions. During flight operations, the operator can intervene with a programmed flight and take immediate control. The SkyRanger also has a significant set of
automated features to ensure safe takeoff, flight and landing in many conditions, further details of operation can be found in Attachment 3

.

As a result of the considerable number of s afety features identified above, the SkyRanger has received multiple approvals for previous operations. Aeryon Labs believes it has shown compliance through its history of successful flight operations which includ e cooperation with several public agencies

. The list of organizations who have used SkyRanger includes: Michigan State Police, US Navy SPAWAR, Mass Development (Joint Base Cape Cod), Unmanned Experts (NIJ Partnership), Western Washington University, Aetos (via Northwest Michigan College), Univer sity of Alaska Fairbanks, University of New Mexico, Kansas

State University, and Virginia Tech University. The SkyRanger has also successfully completed the Department of Homeland Security RAPS Trial in 2013. In Canada, Aeryon has obtained 19 Special Fli ght Operations Certificates (SFOCs) from Transport Canada over 5 years and its customers have received multiple certificates to perform demonstration, research and development, public and commercial operations. The criteria set forth in the certificates g ranted specify the substantive showings of the device’s safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the a ircraft’s safety.

Airworthiness of the DJI Spreading Wings S1000

The DJI S1000 has been approved in over 20 granted Section 333 exemptions to date. This is an octocopter with a maximum takeoff weight of 11 kg ( 24 lbs.) and a 15 minute flight time. The S1000 has numerous built

- in safety measures. It can adjust automat ically should an engine fail and alerts the PIC to the possibility of a lost link before it occurs. If the control link is broken, the UAS will return to a pre

programmed location for landing.

2. Procedures Ensuring UAS in Condition for Safe Flight

The pilot will manually inspect the sUAS according to manufacturer’s instructions prior to each operation (refer to page 11 in Attachment 2 for the STR8, page 20 in Attachment 3 for the SkyRanger, and page 5 in Attachment 4 for the DJI S1000). The PIC wil l ensure all visible parts are in good working condition, a goodStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI signal connection exists between the device used to operate the system and the vehicle itself, and will run any available diagnostics to further ascertain the overall status of the sUAS.

Risk to National Airspace System (NAS)

Strat Aero will issue a NOTAM no later than 24 hours prior to any operation

, and will notify any additional applicable agencies to en hance traffic de

- confliction and safe operation in airspace. W hen
authorized for f lying above the FAA blanket AGL altitude , Strat Aero will remain within a 50 f oo t radius (hori zontally and/or vertically) of any protruding structure that is the object of our inspection . These structures have been previously identified by the FAA on aero nautical charts

. In consideration of the 50
foo t radius limitation, the risk of interference with another aircraft is minimal.

The risk posed by using manned aircraft to conduct these operations is higher than with sUAS s , and in
some cases manned aircraft cannot duplicate the UAV capabilities . These smaller, lightweight
unmanned systems have much less kinetic energy than higher mass manned aircraft , thus much less impact effect . Also, they do not carry fuel and as such do not pose the explosion h azard compared to
manned aircraft.

Risk to Persons and Property on the Ground

Each of the four sUAS ’ s Strat Aero requests to use commercially has software

- based fail

- safes that minimize the risk of catastrophic system failure. When these features are co upled with the strict safety procedures to which Strat Aero operators will adhere, Strat Aero sUAS operations will achieve at least an equivalent level of safety to those achieved in manned aircraft operations. For inspection operations, these areas are o ften access

- controlled by the company and/or individuals owning the structures, further ensuring safety of the operational area and reducing risk to people and property.

Please reference attachments to further review operational characteristics of these s ystems.

3. Radio Frequency (RF) spectrum

Aerialtronics Altura Zenith Radio Frequencies: 868/900 MHz, 2.1

- 2.9 GHz, 5.8 GHz

STR8 Control Link: 2.4 GHz , 5.8 GHz , 10

- 100Mw Aeryon SkyRanger Radio Frequencies: 900 MHz, 2.4 GHz, 5.8 GHz, Custom DJI Spreading Wings S1000 Signal Frequency: 30 Hz

– 450 M Hz , 8KHzStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI Regarding the Unmanned Aircraft PIC

4. Qualifications Required of PIC(s)

Strat Aero PICs will comply with FAA minimum guidelines for sUAS pilot certification and training standards

. T he current minim um requirement is to possess a sport pilot’s license. In addition, Strat Aero will ensure that pilots complete manufacturer and company

- developed training and will also require currency training at regular intervals.

5. Medical Standards a nd Certification of the PIC

Per guidance in Exemption No. 11265, at a minimum, the PIC and VO will each possess a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal
government.

Regarding the Operation of Unmanned Aircraft

6. Intended UAS Operation(s)

Strat Aero proposed operations include but are not limited to:

 Utility infrastructure monitoring and inspection ( e.g. electricity generation facilities (wind, water, solar, gas, and coal) , water manag e ment, and gas and oil production and transportation facilities);

 UAS operator training and curriculum development;

 Contingency site surveillance for emergency management;

 Aerial mapping and su rveying;

 Wildlife monitoring; mining, forestry, and other agricultural applications;

 Transportation analytics;

 Intelligence, surveillance, and reconnaissance support to commercial and governmental agencies (to include military and/or law enforcement /EMS applications);

 Still photography;

 A nd aerial data collection to aid in research and development initiatives.

7. Proposed Flight Parameters

Strat Aero expects to be subject to the following mandatory conditions contained in similar recent exemptions:

 Operations to be condu cted over private or controlled access property.

 Permission from land owner/controller required before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI  Aircraft to remain within Vi sual Line of Sight (VLOS).

 Operations to occur during daylight hours.

 Above Ground Level (AGL) altitu de to be restricted to 400 feet with the possible exception of certain industrial inspections as described below

.

 All operations conducted in vicinity of a irport to remain within the boundaries of the authorized location and so as to adhere to any conditions set forth in that authorization.

 Operator will file a NOTAM and/or no tify ATC prior to each flight per conditions of authorization.

 All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

 All operations will include one pilot for flight control and one observer for VLOS enhancemen t

.

The requested exemption would especially assist with inspections of industrial and utility infrastructure that can be dangerous and difficult to conduct either manually or with manned aircraft. Strat Aero requests permission to inspect those types of structures that extend above 200 feet above ground level (AGL). 1 Standard operating procedures would be adhered to that restrict any exceedance of 200 feet AGL to inspection activities within a radius of 50 feet of the structure being insp ected. A great er than equivalent level of safety would be achieved by the PIC /Observer focused on inspection activities and avoiding UAV contact with the nearby structure beyond that achieved now using helicopters or people to conduct these inspections. Per the OSHA website, there were 11 fatalities in 2014 and 13 fatalities in 2013 attributed to
accidents on or near communications towers. 2

 Some example structure types follow:

o Wind turbines

– Up to 54 0 ft

. alti tude (495 turbine height plus 5 0 feet max imum vertical allowance). Per the 2011 Wind Energy Industry Manufacturing Supplier Handbook, some wind turbine towers are as tall as 330 feet, and blades can be as large as 165 feet. 3 If power to the turbine is shut down (as would be the case in prepara tion for inspection), a blade could come to rest in its apex position, rendering the maximum height of the entire structure 495 feet.

o Radio, television, and cell phone communications towers

.

8. Area of Intended Operation(s)

Strat Aero customers and corporate partners are dispersed throughout the United States . As such, Strat Aero requests that approval be granted nationwide. Strat Aero will comply with all notice filing and any other
operational requirements specified by the FAA . Strat

- Aero w ill describe a finite and limited area of operation

for each mission. Any structure to be inspected that protrudes above the 200’AGL plane will be

___________________________________________________________________________________________

1 Source: FAA W ebsite

- http://www.faa.gov/news/updates/?newsId=82245

2 Source: OSHA website

- https://www.osha.gov/doc/topics/co mmunicationtower/index.html

3 Source: From the American Wind Energy Association (AWEA) website

- http://awea.files.cms

plus.com/FileDownloads/pdfs/Supplier

- Handbook.pdfStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI specifically identified. All other flight activity will be conducted below the FAA specified blanket altitude, including transit between take

- off/landing spot and the target of our in spection. Such structures have already been identified and met FAA criteria. Staying within a 50’ radius of these structures should not present a measureable increase of risk nor jeopardize the safety of the public.

9. Proximity to Airports

Strat Aero will adhere to FAA

- issued restrictions with regards to flying in close proximity to airports. The company will not operate sUASs within :

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport having a published instrument flight procedure, but not having an operational control tower; or

 2 NM from an airport not having a published instrument flight procedure or an operational control
tower; or

 2 NM from a heliport

unless a lette r of agreement wit h that facility ’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of a greement with the facility or airport management must be
made available to the Administrator or any law enforcement official upon request.

10. Compliance with VLOS Requirement

Both the PIC and VO will ensure operations are conducted within VLOS only. T he PIC and VO will use vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical

c ertificate or U.S. driver’s license.

11. Pre

- flight Safety Risk Assessment

PIC and VO will conduct a thorough visual sweep of the area of intended operations and a safety briefing before commencing operations. In addition, PIC will ensure all manufacturer and Strat Aero pre

- flight inspection procedures are complete including pre

- set of minimum and maximum altitudes (see user manuals for specific checklists)

.

12. Coordination with Flight Standards District Offices (FSDOs)

St rat Aero will coordinate our flight activities with the local FSDO as required and will submit monthly flight reports as directed.Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI 13. Certificate of Authorization (COA) Application Requirement

Strat Aero will apply for new COAs or COA amendments as required by the FAA or as is necessary based on changes in standard operating procedures, aircraft and equipment, and/or other operational considerations
that would affect the basis upon which the FAA granted this exemption

.

The name and address of the ap plicant is as follows:

Strat Aero International, Inc.

Attn: Jonathan Adams, Chief Operating Officer 19500 State Highway 249
Suite 655 Houston, TX 77070
Phone: 518

- 224

- 5759

Fax: 832

- 553

- 7975

E

- mail: jon@strat

- aero.com

Attachments

1) Aerialtronics Altura Zenith ATX8 Manual

- (this document is being sent to Strat

- Aero by the OEM , but is the same document as submitted in conjunction with Public Docket No. FAA

- 2014

- 0856 by State Farm Mutual Automobile Insurance Company) will be sent to FAA e

- mail upon receipt 2) STR8 Operating Manual

– submitted to FAA e

- mail as directed 3) Aeryon SkyRan ger User Guide

– submitted to FAA e

- mail as directed 4) DJI S1000 User Manual

– submitted to FAA e

- mail as directedStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI Exemptions Sought

Section No. (§) Description Reasoning and/or Mitigation

14 C FR Part 21
& 14 C FR § 91.203 (a) Airworthiness Certificates Given the size of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed

c urrent safety levels. It will no t carry a pilot or passenger, will not carry f lammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with
conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both
the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have

a dvance notice of all operations through the filing of

N OTAMs. Receipt of the prior permission of the land owner,
the size of the aircraft, the lack of flammable fuel, and the
fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety.
14 CFR §61.23 Medical certificates:

Requirement and duration Per previously

- granted exemptions, both t he PIC and VO will possess a valid U.S. driver’s license issued by a state, territory, or the federal government. Medical certification should not be required as these s UAS s are lightweight, not manned, do not carry liquid fuel, and have built

- in software ensuring automatic responses to potential safety issues. In addition, to further mitigate safety concerns, t he on

- site lead will pre

- brief personnel on safety procedures, and any personnel can initiate the cessation of operations for any safety

- related r eason. 14 CFR §61.101 Recreational pilot

privileges and limitations The PIC will u ndergo manufacturer and company

- specific training in order to achieve a level of safety at least equivalent to that of a recreational pilot operating manned
aircraft pursuant to this section. Strat Aero requests an exemption to this section based on the similarities of our petition with that of the reliefs granted under Exemption No.

11241.
14 CFR §61.113 Private pilot privileges and

limitations The PIC would possess at least a sport pilot license per guidance in previous exempt ions (i.e. Exemption No. 1126 5)

. Strat Aero can achieve an equivalent level of safety to those achieved by current regulations because the sUAS s are unmanned and will only be flown with missio n

- essential personnel in the area. In addition, The Strat Aero operatorStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI will successfully complete manufacturer and petitioner

developed training.

14 C FR § 61.133 (a) Commercial pilot privileges

and limitations Strat Aero operators will be trained with manufacturer

developed and company specific training that will provide adequate safety training. Completion of thi s training and
adherence to Strat Aero SOPs and manufacturer guidelines will guarantee a level of safety equivalent to those required
of lar ger manned aircraft.
14 CFR §61.315 Sport pilot privileges and

limitations The PIC will undergo manufacturer and Strat Aero

- specific training in order to achieve a level of safety at least equivalent to that of a pilot with a sport license operating manned aircraft pursuant to this section. Strat Aero requests an exemption to this section based on the similarities of our petition with that of the reliefs granted under Exemption

No s . 11241 and 11265

. 14 CFR § 91.7 (a) Civil aircraft airworthiness The PIC will comply with standards outlined in the appropriate operator’s manual to ensure the rotorcraft is in an airworthy condition prior to every operation. Pre

- flight inspections will ensure the craft is safe for operating and will
meet the intent of this section without requiring a certificate.
14 CFR § 91.9 (b) (2) & (c) Civil Aircraft Fight Manual

in the Aircraft sUAS vehicles cannot carry a manual due to their small size, but a manual will be available at the ground control station where the pilot flying the sUAS will have immediate access to it. The FAA has granted this to others in the following exemptions: 8607, 8737, 8738, 9299, 9565, 10167, 10602, 10700, and 11265.
14 CFR §91.103 (b) (2) Pre

- flight action While the FAA has not approved a flight manual for rotorcraft, the PIC will achieve an equivalent level of safety by following the manufacturer’s pre

- flight checklists

. Reference page numbers described in section 2 for these
checklists.
14 CFR §91.105 Flight crewmembers at

stations As t he sUASs are unmanned, crew cannot be at stations aboard the aircraft, but the pilot, visual observer, and any
other mission

- essential personnel will be at their appropriate stations prior to take

- off.
14 CFR §91.109 Flight instruction;

simulated instrument flight and certain flight tests Neither t he Falcon 8 nor the SkyRanger have fully functioning dual controls, but the pilot will attend manufacturer

developed training. After successful completion of the training, the pilot will be fully compete nt with the aircraft and able to meet safety requirements as outlined by the FAAStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI and per the operating instructions set forth in the manufacturer’s guidance.
14 CFR §91.119 (b) and (c) Minimum safe altitudes The sUAS will remain below 400 feet above ground level (AGL) at all times unless during brief periods of industrial inspections as describ ed on page 4 of this exemption request
letter

. The PIC will ensure the sUAS is flown in accordance with manufacturer’s safety guidelines and in such a way that
achieve s a level of safety equivalent to those allowed for helicopters operating at similar altitudes.
14 CFR §91.121 Altimeter settings The above

- referenced sUASs do not have a traditional altimeter. The onboard data systems monitor altitude, all flig ht data is monitored by the operator, and readings are stored on an SD card onboard. All operations will be conducted within line of sight, out of the airspace used by most manned aircraft, and below 400 feet AGL.
14 CFR §91.151 Fuel requirements for

fli ghts in VFR conditions Each of the sUASs identified in this petition indicate low

power status to the pilot when there is still sufficient power to conduct a safe landing (up to five minutes left in batter y

power ) . Warnings continue and increase in intens ity and frequency after the first indication of the battery charge being low.

14 CFR § 91.203 (a) & (b) Civil aircraft: Certifications

required The request for exemption from 14 CFR §91.203 (a) is coupled with the request for relief from 14 CFR Part 21 (see top of page 5). With regards to §91.203 (b), the sUASs are too small to carry COAs onboard , but the document(s) will be available at the ground station. This will ensure the pilot has
access to these documents at all time.
14 CFR §91.405 Maintenanc e required The PIC will conduct pre

- flight checks to include any visible need for maintenance prior to operations. If a problem is present but not visible to the pilot, the issue will still be
corrected

– both sUASs notif y the PIC of maintenance issues

on startup and continue to monitor status after takeoff.
When the PIC or other qualified maintainer is alerted to maintenance issues, he or she will conduct maintenance as
directed in the sUAS

- specific operating manual. Strat Aero will also ensure the syst em s are periodically inspected for any issues to further prevent in

- flight errors or failures. A maintenance log will be maintained for reference and will be available to regulatory officials upon request

. 14 CFR §91.407 Operation after

maintenance Due t o the se systems ’ consistent self

- monitoring and Strat Aero’s compliance with manufacturer’s pre

- flight inspectionStrat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI checklists, the PIC or other trained technician is qualified to ascertain the suitability of the sUAS for continued operations.

14 CFR §91.409 Inspections Inspections will be conducted before and after each flight as well as at periodic intervals. These regular inspections ensure a level of safety equivalent to that of inspecting manned aircraft annually is achieved.
14 CFR §91.417 (a ) and (b) Maintenance record s The PIC or other similarly

- qualified technician will perform any maintenance and will make note of any maintenance work. Strat Aero seeks exemption from the specified time periods, however, as the sUAS conducts self

- inspection throughout the operation.Strat Aero International
Ph: 1.832.912.4273

Fax: 1.832.553.7975

www.strat

- aero.com

LONDON NEW YORK HOUSTON DENVER SEATTLE SINGAPORE DUBAI Conclusion

The planned uses for the Aerialtronics Altura Zenith ATX8, STR8, Aeryon SkyRanger , and DJI S1000 system s satisf y the criteria set forth in Section 333 of the Reform Act. Strat Aero ’s proposed sUAS operations, subject to the conditions listed above, do not create a hazard to users of the national air space (NAS) or the public or threaten national security . The s mall size, low weight , low speed, safety features, and operating distance from airports and populated areas mitigate these safety issues

.

The operation of the sUAS for aerial data collection in accordance with the strict conditions outlined herein will provide more than an equivalent level of safety, supporting the grant of th e exemptions requested. Approval of the exemption s allowing operations of the aforementioned systems for aerial photography and surveillance will enhance safety by reducing the risks inherent in the same services when conducted manually or with manned

airc raft

. Other a erial inspection op tions available to Strat Aero customers using conventional rotary aircraft, present risks associated with vehicles that often weigh several thousand pounds and carry large quantities of fuel, passengers, and cargo. Such ai rcraft must fly to and from the inspection locations

. While these sUASs will operate at similar speeds and altitudes of manned aircraft, the heaviest weighs approximately 6 pou nds ( 89 % less weight than the 55 pound maximum established by the FAA ), is powered by batteries, and will be carried to the inspection location. The sUA Ss will not fly over residences and will not expose any individuals to the risks associated with manned aircraft flights. All of these factors greatly reduce the risks associate d with conventional operations.

Given their reduced size, speed, load capacity, and lack of fuel spill risk, the Aerialtronics Altura Zenith ATX8,

DJI S1000

, STR8, and Aeryon SkyRanger sUASs p ose no threat to national security. Further, the operating

ca pabilities, avoidance of airspace used by other aircraft, operation within visual line of sight, and use of licensed pilots provide adequate justification to grant the requested exemptions.

Best regards,

//signed, rc, 05 May 15// Renae Compton Project Manager

– Administration Strat Aero International, Inc.