October 26 , 2015

L2 AEROSPACE, LLC 215 Baytree Drive, Suite B Melbourne, FL 32940
Phone: 321

- 806

- 3532
Phone: 321

- 604

- 8866
Email: jroyston@l2aerospace.com
Email: sderiso@l2aerospace.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1. Aero

- M

- Spec

- Sheet

- v3 .pdf

References:
1. FAA Exemption No. 11345 , Regulatory Docket No. F AA−2015−0048 in the matter of the petition of MS. M. ANNE SWANSON for PRECISIONHAWK, INC.
2. FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU
3. FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC
4. FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the petition of FLYI NG CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under
section 333 of the FAA Modernization and Reform Act of 2012

, L2 Aerospace, LLC

, referred to hereafter as the petitioner, requests exemptio n from the following sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) ; 91.409(a)(2); 91.417(a) & (b)

In order to operate small unmanned aircraft systems (UAS’s) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography,cinematography, videography, mapping, crop surveying, inspections and other flight operations

that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorizati on and permission of clients or their authorized agents in order to facilitate commerce and ra ise awareness of the beneficial uses of small unmanned air systems. So long as such operat ions are conducted within and
under the conditions outlined herein or as may be establ ished by the FAA as required by Section 333. The conditions identified and proposed b y the petitioner are drawn from
references 1

- 3.

The Federal Aviation Regulations (FARs) The petitioner seeks exemption from the above mentioned FARs for the following reasons;

Section 61.113(a); 61.113(b) The petitioner requests relief in order to facilitate the utilizatio n of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fa shion to the previously granted exemptions.

Section 91.119(c) As referenced in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted clo ser than 500 feet to the ground may require that the UA b e operated cl oser than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests waiver for this condition to allow reasonable and respon sible operations in areas of subdivisions and neighborhoo ds if required.

Section 91.121 As referenced in Exemption 11138 (DOUGLAS TRUDEAU) is inap plicable since the UAS does not
have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude
information.

Section 91.151(a)

As referenced in Exemption 11136 (ADVANCED AVIATION SOLUT IONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- s pecific relief has been granted in Exemption numbers 8811, 10808, and 10673 for daytime, V FR conditions. The UAS provides battery power remaining in percent to the PIC. The UA bat teries provide approximately 20 to 60 minutes of powered flight. Information provided in th e operating documents discusses procedures regarding remaining battery power manage ment. Those documents contain a condition in which the PIC will initiate a landing procedure w hen battery remaining reaches a specified level. Given the limitations on propo sed opera tions and the location of those proposed operations, the FAA found that a reduced mini mum power reserve for flight in daytime VFR conditions was reasonable.Section 91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409(a)(2); 91.417(a); 91.417(b)

As refe renced in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’ s operating documents and t he conditions and limitations specified, describing the requiremen ts for maintenance, inspection, and record keeping, were sufficient to ensure that safety would not be adversely affected.

UAS’s : 3drobotics ’ Aero/Aero

- M, P recision H awk ’s Lancaster, and L2 Aerospace Experimental Fixed Wing Unmanned Aircraft (drones) The requested exemption would permit commercial operation of L2 Aerospace, LLC ’s UA S's, which weigh between 5 and 2 5 lbs. and perform precision services that consist of high quality
still photographs and videography taken by onboard cameras. UAS’s for aerial services reduce the need to utilize conventional manned aircrafts for the same purpose at a fraction of the cost; additionally, UAS’s services can provide an increase in efficiency and productivity for the affected activities and a decrease in fuel emissions providing environmental benefits. Operations under the exemption will be subject to strict operating requirements and conditions to ensure, at minimum, an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section

333.

The L2 Aerospace experimental fixed wing drone is similar in performance and specifications to
the 3DR obotic ’ s Aero /A ero

- M and PrecisionHawk’s Lancaster fixed wing drones. Exemption No.

11345 , Regulatory Docket No. F AA−2015−0048 is referenced as an approved exemption covering PrecisionHawk’s Lancaster aircraft. The specification for the 3DR obotic ’ s Aero

- M is
included as a reference.

The referenced unmanned aircraft websites are:

1. https://3drobotics.com/kb/aero

2. https://3drobotics.com/kb/aero

- m 3. http://www.precisionhawk.com

4. http://www.l2agsolutions.com (L2 Aerospace, LLC)

The UAS's will be operated under controlled conditions at low altitude in airspace that is limited in scope , as described herein; it will have automated control features, as described in the attached manuals. The UAS’s also will be operated by an individual who possesses an FAA Private Pilot Certificate and valid US Driver’s License. Finally, the airspace in wh ich the UAS will operate will be Class G airspace or airspace approved by the FAA in advance. Approval of these exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 3 33(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”The petitioner has reviewed FAA exemptions references 1

- 3 Conditions and Limitations

section and agrees that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAS’s airworthiness will be verified prior to each
launc h. The petitioner request that in a manner similar as described in reference 3, he be allowed to operate within 5 miles of an airport provided that:

“ The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordanc e with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request .”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

Public interest
Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircrafts. Additionally, use of the UAS’s in order to facilitate commerce could lead to economic growth. Operation s for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography or videography. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor; a visual observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request for exemption. Data may be submitted to FAA by traditional means, e.g. COA Monthly Reports, or other means as required or requested.

Conclusion The petitioner is requesting this exemption for the purposes of “aerial photography, cinematograp hy, videography, mapping, crop surveying, inspections and other flight operations”. The petitioner's business model is of the idea of offering ad hoc small UAS’s services to individuals or business entities who wish to employ these services as a safe,
effe ctive, and legal option to enhance their business or hobby.

Currently, many other UAS operators are conducting business in exactly as described above without FAA authorization. The petitioner has refrained from engaging in commercial use of the
UAS’s. The primary purpose of seeking this exemption is to obtain the capability to offer thoseservices while remaining in compliance. The petitioner employs personnel with private pilot

licenses or higher with significant flight experience

.

Respectfully submitt ed,

Sam C. Deriso, Jr
L2 Aerospace, LLC Director, ISR & Flight Systems