# Reed Smith

Co u rt ney R. B ate m a n Direct Phone: + 1 202 414 9265 Email: CBateman@ reedsmith.com February 24, 2015

U.S. Department of Tran s portation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Reed Smith LLP 1301 K Street, N

. W. Suite 1100- East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith .com

Re: SkySpecs Requ est for Exemption from Certain Regu lation s per Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11 , SkySp ecs hereby applies for an exemption from the listed Federal Aviation Regulation s (''PARs") to allow business use (commercial operation) of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be estab li shed by the FAA as required by Section 333. 1 

### I. INTROD UCTI ON SkySpecs is an Ann Arbor, Michigan based company born from research out of the University of Michigan College of Engineering. The team 's comb i ned expertise in robotic s enabled them to deve l op sense-an d-avoid technolo gy for Small Unmanned Aircraft Systems (sUAS). SkySpecs is founded on demonstrated success in autonomo us ly navigating pr evio usly unmapped , uninhabited "disaste r zones" through the AUVSI Inte rn ational Aerial Roboti cs Competition, AUVSI Rob oBoat Competition, and DARPA MAGIC competition. SkySpecs has designed its commercial system with a pilot in-the -loop to empower them to become more confident and safe in operations near structures and other obstacles. SkySpecs intends to operate sUAS to conduct visual inspection of vertical s tructures. The sUASs will be equipped to conduct aerial photography, multi -spec tral imagi n g and 

### 30 lase r sc anning for the purpose of structural and/or conditional assessment of large wind turbines , monopole towers and blades, high voltage electrical transmission monopole s and towers, tal l communication monopoles and towers, and flare stacks. SkySpecs has developed a proprietary near-field collision detection and avoidance sys tem called 'Guardian'. The only sUAS(s) that SkySpecs p l ans to operate will be equipped with fully-functioning

1 For cons istency and ease of FAA review, SkySpecs' requ est ge n erally tracks, in format and co ntent , the initial requests for exemption filed by various film industry sUAS operators. SkySpecs grate fully acknowledges their work in this regard.
NEW YORK t LONDON + HONG KONG • CHICAGO • WASHINGTON , D.C. • BEIJING • PARIS t LOS ANGELES t SAN FRANCISCO t PHILADELPHIA t SHANGHAI t PITTSBURGH t HOUSTON S INGAPOR E t MUNICH tABU DHABI t PRINCETON • NORTHERN VIRGINIA • WILMINGTON t SILICON VALLEY t DUBAI t CENTURY CITY t RICHMOND t ATHENS t KAZAKHSTAN US_ACT I VE·121126703

. 1·CRBATEMA 02/241201 5 2 : 27 PMFebruary 24, 2 015 P age 2 

# R e ed Smith

Guardian s y s tems. Once e quipp e d and operat ional, Guardian will enable any sUAS to be knowl edgeab le of it s s urroundin gs a nd will automatically o verri de pi l ot input and sl o w movement toward an obstacle, eventu all y corning to a compl ete stop at a safe di stance. Thi s distance i s kn ow n as the "thresho ld distance, " whic h i s adjus tab l e before every fli ght , until the pilot inputs a command that would d irect the vehicle away from the thre sho ld , reclaimin g full control. Guardian remai ns a fu lly

- aware , yet passive, system for th e duration of th e flight when the pilot d oes not direct the v ehi cle to pe netrate the threshold di stance. Guardian renders any outfitted sUAS unable to fly within the thre s hold distance , even und er t he event that a wind gust pushes it toward the obstacle. Thi s technology allows the pilot to fly close to a target structure removing the risk and associated d anger of getting to o cl ose, while a l so decreasing the pub li c's p erceived ri s k of sUAS fli g ht. Contact: SkySpecs, Inc Attn: D aniel Elli s, CEO Ph : 269.599.1360 Email: danny@sky spec s.c om Address: SkySpecs, Inc. 33 0 East Libe rty, Lower Level Ann Arbor, MI48104 Specific Regulatio ns from which the exemption i s requested: 2 14 CFR 61.113 (a) & (b) 14 CFR 91.7(a) 14 CFR 91.1 1 9(b) & (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 1 4 CFR 407 (a) (1) 14 CFR 409 (a) (1) & (2) 14 CFR 417 (a) & (b) It is ob vio u s that Congress' goal in passing Section 333(a) throu g h (c) of the Reform Act was to provide , in that legi s l ati o n , a mec hani s m for suc h exemption requests. Through the se Section 333 exemption provisions, Congress has directed the Secretary of Transpo rt at

i on to fairly co ns ider whether

2 SkySpecs intends to comply with 14 C.F
. R
. 91.9(b) and I 4 CFR 9 1 .203(a) and (b ) in accordance with the FAA Chief Counsel 's Au gus t 8, 20 1 4 Memorandum , " Interpretation regard i n g whethe r cert ain required documents may be kept at an unmanned aircraft's contro l statio n ."February 24, 2015 Page 3 

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certai n unmanned aircraft systems may operate safely in the national airspace system (NA S ) before completion of the rulemaking required under Section 332 o f the Ref orm Act. In making this determination, the Secretary is required to determine which typ es of UAS s do n ot create a signi ficant hazard to u sers of the NAS, or the public, or pose a threat to national secur it

y i n li ght of the following:
• The UAS's size, weight, speed, and operatio nal capability; • Operation of the UAS in clo se proximity to airports and populated areas; and • Operat ion of the UAS within vi s ual lin e of s i g ht of th e opera tor. Re form Act§ 333 (a) : Lastly , if the Secretary determines th at suc h vehicles "may operate safely in th e national airs pa ce sys tem , the Secretary s h all establis h requir e ments for the safe operation of s uch aircraft in the national airspace system." 

### !d. §333(c) (emp hasis ad ded). Moreover, the Admini s trator may g rant an exem ption f rom a req uirement of a reg ul ation prescribed under subsectio n (a) or (b) of this section or any sections 44702-447 1 6 of this title if th e Administrato r finds the exe mpti on in the public int erest. 49 U.S.C. §447 0 l (f) See also 49 USC § 44 71 1(a); 49 USC §447 04; 14 CFR §91.203 (a) (1). 

### II. SKYSPECS' PR OPOSE D OPE R ATI ONS DO NOT CREATE S I GNIFI CANT HAZA RD S The sUAS's utilized b y SkySpecs are elec tri c multi-rotor craft, weighing less than 12lbs. including payload. They operate at a speed of no mor e than 22 knots and hav e the capability to hover, and/or move in a vertical and hori zontal plane simultaneously. They will only be operated as visual lin e of sight (VLOS), and remain under 400ft. in elevatio n above ground , and will operat e only with permission of the ow ners of the faci lities being in spected (Wind Farm Operators, El ectrica l Utilities, Telecommunication Facilities Own er s, or Fl are Stack Owner s). Additionally, the pr oposed operat ion s involve aerial in s pec tio n o f unoccupied structures, generally built upon right of ways with adequate buff e r to prot ec t the public from phys ica l harm or invasio n of pri vacy during inspection operat i o n s. For example , most utility structures are in the middle of a right of way th at i s between 150-200 ft wide. SkySpecs' operati o ns would re main within th at right of way. Virtu ally all facilities bein g inspected are also generally remote and on land that i s own ed and exclusively operated by the utility co mpan y or s tru c tur e owner. During normal operations the si te will be secured of any by s tanders the s ame way the site i s secured during an inspection and th e inspectors wiJl be the only peopl e on site. They are equipped with hardhats, s tee l toed boots, and in sp ect i o n equipment. SkySpecs' operations would remain verti cally within the s tructur e's footprint. M oreover, the facility 's tow e rs and l a nd are alrea dy subject to obstruction marking, lighting and notification requirements set forth by the FAA, by which SkySpec s and its technology are prepared and able to abide
. Similarly, telecommunications tow ers areFebruary 24, 2015 Page4 

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generally some di stance from dwellings, and even those that are not are generally s ite d within a right of way, and SkySpecs' operatio n s would remain within that ri ght of way. Moreover, as noted above, SkySpecs has de vel oped a proprietary near-field collision detection and avoidance syste m called 'Guardian,' which establishes a thre shold distance the sUAS will operate from the target structure. This tech nology allows the pilot to fly dose to a target structure, while removing the risk and associated danger of getting too clo se, and also decreas i ng the public's perceived risk of sUAS flight. SkySpecs has drafted, and submits confidenti ally, a Fli ght Operation s Manual which di scusses safety considerations, training and genera l operating procedures for the proposed operations. SkySpecs h as also drafted, and s ubmits confidentially, an sUAS Aircraft Flight Manual which sets for the specification s, inspection and setup of the sUAS intended for use in the proposed operations. ill. SKYSPECS' PROPOSED OPERATIONS ARE IN THE PUBLIC INTEREST By the clear language of Section 333, SkySpec ' s proposed operations are in the public inte r est because they advance Congres s's explicit goal of getting commercial sU AS flying in the United States safely and soo n. SkySpec's operations are exac tly the "dul l , dirty [and] dangerous" opera ti ons which the FAA has recognized as perfectly s uited for UAS operations. 

### See, e.g., stateme nt of Jim Williams, Manager , FAA UAS Integration Of fice, contained transcript of "FAA UAS Online Li ste ning Session , April 3, 2013, " (" [I]nsp ecti ng high-tension wire elec trical towers all over the United States [is] high-risk operation s , which are well su ited for a UAS."). Current alternati ves utilized for these inspection s and/or assessments include: ground based inspections (limited in effectiveness); access with high reach man lifts (limit ed in eleva tions that can be reached); physical climbing of the po l es/towers; and in spect i o ns or assessments conducted from conventional aircraft (primarily helic opter s). All are dangerous compared to the safer u se of a sUAS as proposed by SkySpecs. A 2009 "Safety Gu ide fo r Helicopter Operations" published by the Utilities, Patrol and Construction Committee of Heli copter Association Internation al stated that "between 1979 and May 2007 there were 25 helicopter accidents with 4 3 fatalities conducting utility work in the US. Generally
... a collision with wires while conducting these operati ons will result in fatalities and/or serious injuries to the c rews and total lo ss of the airc raft. " 3

3 See, " UPAC Safety Guide for Helicopter Operators ," found online at hllp ://www
. r o tor.eom / A h o ut HAJ /Co mm i tt ees/ Ut i li ti es P atro la ncl Co n stru c ti o n .as p x .F ebruar y 24, 201 5 P age 5 

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Th e AFL

- CIO rev iewed OSHA s tatistic s regarding aerial l ift acc id e nt s between 1992 and 1 999 and conclud e d th at an ave r age of 26 construction workers die eac h ye ar from u sin g aerial lift s , with t he majori ty of death s re s ulting from electrocutions and fall s. 4 A 2 011 ne w s paper article regarding wind and solar-powered in s tallation s noted 78 wind

- turbine relat e d fataliti es s ince the 1970s. 5 Similarly, an investigation of the tel ecommunicatio ns tower indu s try f ound that , b e tween 2003 and 2010, the ave rage fatality rate for th e tower industry was more than 10 times gr e ater th an the construction industry , with 13 w orker de ath s in 2013 al one. 6 SkySp ecs s tro ng ly be li e ves that al l owing it to conduct the s e t yp e s o f o p eration s u s ing an s UAS would s ub s tanti ally re du ce the injur i es and fatalitie s which h ave re s ulte d fro m exi s tin g methods of inspection
. SkySp ecs b e li eves that thi s re du c tion in injurie s and fa tali ties d e mo ns trates bo th that the operati o n s s ub s tanti all y e xceed the eq ui valent l evel of s afety found in th e FAR s, and t h at granting thi s exemption i s in th e publi c i nteres t. 4 9 U SC 4470 1(f)
. See a lso 49 USC § 44 7 11 (a); 49 U SC § 447 04 ; 14 CFR §91. 2 0 3 ( a ) ( I ). A cco rdi n gl y, SkySp ecs re spec tfull y reque s ts that the FAA grant th e r e que s te d e xe mpt i on without del a y. 

### IV. EQUIVALENT LEVEL OF SAFETY SkySp ecs propo ses that the exemption requested herein apply t o c i v il air c raft that have the characteri s tic s and op e rate with the limi tations listed herein
. These limitation s , a s li sted below, provide for at le a s t an equivalent or even higher level of safety to opera t io ns un de r th e current regu l atory stru c tu r e . Th ese limit a ti o ns a nd condition s to which SkySpec s agree s to b e b ound wh e n c onducting commercial op er ati o ns und e r an FAA iss u e d exemption include: Th e sU AS uti li zed b y SkySpecs will weigh le ss than 1 2 1b s . Fli g hts w ill be o perat e d within v is ual line of s ight (VLOS ) of a pil ot in co n s tant co ntrol o f the craft
.

4 Sec , " Deaths fro m Aeria l Li f t s. " f o u nd o nl ine at http://www.clco s h
. org/do c umenc/ 1417 /d000484/Dcaths % 2 B F rom lk 2 B Ac ria i % 2B Li th.htm l '! show text= I

. 5 " M o re Acci d e nts Feared as Wind , S o lar-P o wered In s taJla ti o n s Sp r ead ," 8. 14. 11 Los Ange l es Ti mes arti cl e , f o und o nlin e at htrp: //www. tolcdo hl adc.com/E n c r gy/20 I I /0 8/ 14/M o rc - acc idc nt s- feared

- as - wi n d

- solar

- powe r - i ns t a ll at io n s - s pre ad.ht mi.
6 "Ce ll To we r W o rker Fata lit ies C o ntinue: More than a Do z en D e ath s s in ce 2 0 1 2," I
. 1 6. 14 arti c le f o und online at http: // sc i c n

cc hlo gs.co m/th cp urn phand l c/ 2 0 14/ 0 I I 16/ce l l

- tow c r - w o rk c r - fata lit ics -co nt in u c- m o rc -than -a -doz c n-dcath s - s i nce20 12/.February 24, 2015 Page 6 

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Max imum total flight time for each operational flight will be approximately 25 minutes. Flights will be safely landed when the battery falls below its nominal voltage should that occur prior to the 25 minute limit. SkySpecs has dev e lop ed a multispectral killswitch that is ab l e to safely bring the UAS to the ground in the event of a fai lu re, i nductin g loss of communication with the primary controller, motor failure, or battery failure. V. EXEMPTIONS REQUESTED 14 C.F.R. §61.113(a) and (b): Pri va te 

### vs. Commercial Pilot Certificates Sections 61.113(a) and (b) prohibit private pilots from ope rating an aircraft for compensation or hire. SkySpecs proposes that its pilots will have at least a private pilot's certificate, and a Class II medical. Its operations will be conducted over private property , in a s t erile area as reflected in SkySpecs' Flight Operations Manual. For the reasons set forth in the FAA's grant of an exemption to Astraeus Aerial , SkySpecs does not believe a commerc ial pilot certificate is necessary for the operations it intends to co nduct. See, e.g., In the matter of the petition of Astraeus Aerial, Exemption No. 11062 (issued Sept. 25, 2014). For those re aso ns, SkySpecs requests an exemption from 14 C.F.R. §61.113(a) and (b). 14 C.F.R. § 91.7 (a) : Civil Aircraft Airworthiness Section 91.7 prohibits operation of an unairworthy aircraft, and places responsibility for airworthiness determinations on the pilot in command. The sUAS will not have an airworthine ss certificate, and there is no FAA regulatory standar d for determining airworthiness of the sUAS. Additionally, SkySpecs' operating document s set forth inspection and maintenance procedure s to ensure ai rwo rthin ess. For these reaso n s, and in accordance with the FAA's grant of an exemption from 91.7 to Total Safety U.S ., Inc . • SkySpecs requests an exemption from 1 4 CFR. §91.7(a). See, e.g., In the m att er of the petition of Total Safety U.S., Inc. , Exemption No. 11156 (issu ed Jan. 29, 2015). 14 C.F.R. § 91.119(b ) and (c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(b) prohibits aircraft in congested areas from flying less than 1 ,000 feet above the highe st obstacle within a horizontal radius of 2, 000 feet of the aircraft. To the extent that the struct ures that SkySpec s would be inspecting are considered to be in "congested areas," 7 SkySpe cs' operational procedure s, and the size, weight and speed of the sUAS, provide an e quivalent level of safety s uch that operations at lower altitudes should be allowed.

7 The FAA Office of the Chief Counsel has indicated that whether an area is "co ngested " is determined on a case-by-case basis. See, e.g., June 18 , 2012, Memorandum from Rebec ca B. M acPherson, Assistant Chief Counsel for Regulati ons, to Jam es E. Gardner, Mana ger, Flight Standards Division , re " To what extent an operator can make a co ngested area un co n gested."February 24, 2015 Page 7 

# Reed Smith

As described in 

### its Flight Operations Manual, SkySpecs will establish a 500' buffer/sterile area for its operations that will exclude personnel not associated with the operations. SkySpecs will also exercise additional control over the sterile area as needed, as set forth in the Manual. Consequently, SkySpecs believes these procedures will reduce or eliminate any potential adverse impacts to safety for operations in conge sted areas. SkyS.pecs therefore requests an exemption from 14 CFR § 91.119(b). Section 9 1.11 9 (c) prohibi ts operations in other than congested areas below 500 feet above the smface, or closer than 500 feet to any person, vessel, vehicle or structure. As this exemption is for an sUAS that flies similarly to a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. As discussed above, SkySpecs' Flight Operations Manual provides for establishment of a ster ile area, i nclu ded safety buffers of 500 feet for personnel not associated with the operation. A 100 foot safety buffer will be in place for authorized personne l associated with the operation, unless the PIC determines a reduced buffer is essential to the current operation. SkySpecs therefore requests an exemption from Section 91.119( c) for all authorized personnel associated with the operation. 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
... to the e l evatio n of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric al timeter, but instead a GPS altitude read out, an exemption may be needed
. 14 C.F.R. §91.151(a) : Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a fli ght in an airpl ane under VFR 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- (1) During the day, to fl y after that for at least 30 mi nu tes; or (2) At night, to fly after that for at least 45 min utes." Maximum total flight time for eac h operational flight will be approximately 25 minutes. Flights will be safely landed when the battery falls below its nominal voltage, should that occur prior to t he 25 minute limit. The DJI S900 sUAS has Low Voltage Protection which alerts when the battery reaches pre-set levels. SkySpecs believes that an equivalent level of safety can be achieved by setting the Low Voltage Protection to alert when the aircraft battery reaches its nominal voltage of 22.2 volts. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area .February 24, 2015 Page 8 

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In addition, SkySpec s ha s developed a multi spectra l ki ll switch that is able to safely bring the UAS to the ground in the even t of a failure, including l oss of communication with th e primary co ntrolle r , motor failure, or battery fai lur e. F or the se reason s, SkySpecs requests an exe m ption from 14 C.F.R. §91.15l(a). Similar exemptions have been granted to other operations, includin g Ex e mption s 2689F, 5745, 1067 3, and 10808. 

### 14 C.F.R. §91.405 (a); 407 (a) ( 1); 409 (a) 

### ( 1 ) & (2); 

### 417(a) & 

### (b): Maintenance Inspection s These regu l ations require that an aircraft operator o r ow ner "s hall have that aircr aft inspected as pre scri bed in subpart E o f th is part and s hall between required in specti ons, except as provided in p aragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter
... ," and others s hall inspect or maintain the aircraft in compliance with Part 43. As pro vided in SkySpe cs' Op e rat io n s Manual , th e o per ator will ensure th at th e UAS i s in workin g order prior to initiating flight , p erform required maintenance and inspections, and k eep a l og of any maintenance perf ormed. 

### VI. REGULATIONS FOR WIDCH EXEMPTIONS ARE UNNECESSARY The Federal Aviation Admini stration ju st issued a number of exemptions for UAS operatio n s in filmin g of movies. 

### In tho se exemptions, the agen cy n ote d th at exemptions from certai n regulatio n s were not necessar y , due to " th e size, weight, speed and limi ted operating area associated with [the UAS s ] and its operat io n. " Based upon the FAA 's guidance, an d the fact th at SkySpecs ' UAS is even s ma ll er and sl ower than th ose propo sed b y the film-makin g industry, SkySpecs believes exemptions fro m the following regul ations are not necess ary: 14 C.F.R. Part 21, Subpart H: Airworthine ss Certificate s 14 C.F.R. §45.23 (b). Marking of the Aircraft 14 C.F.R. §9 1. 7(b) : Civil aircraft a irw ort hin ess . 14 C.F.R. §91.109: Flight instruction
. SkySpecs al so believe s th at an exe mption from 14 C.F.R. §91 .1 03: Pr e fli g ht Action , is not n ecessary. Th is regulation requires each pil ot in c ommand to take certain ac tion s before fl ig ht to insure the safety of flight. An FAA ap proved r otorcraft flig h t manual will n ot be provided for th e aircraft. An equivalent le ve l of s afety will be prov ided as s et forth in the operating documents s ubmitted as part of thi s r equest. The FAA has previously fo und that adherence to procedures co ntain ed in an applicant's operati ng documen t s demonstrate co mpliance with §91.1 0 3, a nd therefore an exemption from the regulationFebruary 24, 2 01 5 Page 9 

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wa<; not necessary. See, e.g., In the matter of the petit i on of T o tal Safety U.S., Inc. , Exemption No. J 11 56 (issued Jan. 29, 2015). As detailed in its operatin g documents, SkySpecs ' PIC will take all actions i n cluding reviewing weather, flight battery requirements, l anding and takeoff clearance distances and aircraft performance data before initiation of fl]ght to e n s ure the safety of the flight. Consequ e ntl y, in light of the agency's prior finding in Total Safety U.S., In c., SkySpecs does not beli eve an exemptio n from 14 C.F.R. §9 1.103 is neces sary. P ursuant to 14 C.F.R. Part ll, the fo ll owing summary is provided for pub I icatio n in the Federal Regi ster, should it be determined that publication is needed: SkySpecs seeks an exemption from the following rules: 14 C.P.R. §61.113(a) and (b); 91.7 (a); 91.119(b) an d (c); 91.1 21; 91.l5l(a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2) and 91.417 (a) & (b ) to operate co mmercially a srnalJ unmanned vehicle (12 lb s or l ess) for the purpo se of co ndu cting structural and conditional assessmen t s on high vo l tage electrical tran smissio n monopoles and towers, tall communication monopo l es and towers, large wind tur bine monopole tower s and blades, and flare stacks. Approval of exemptio n s allowing commercia l operat i o n s of sUASs for these applicatio n s wi ll enhance safety by reducing risk. C onventional means fo r perf ormi n g these assessments req uire e ither physi cal l y cl i mbing the pole s or towers , u si ng ropes to rappel down the tower from th e top of the tower, usi ng hig h

- reach man lif ts to access the tower s (limited reach), or u sing conve nti o n al helicopters operatin g at extremely low altitudes over the subject struc ture being photographed. These conventional means al l pose risks to person s and prop erty. In contrast, a sUAS wei ghing fewer than 1 2lbs. and powered by batteries, eliminates virtually al l of that risk given the reduce d m ass and lack of comb u stib le fuel carr i ed on board. Th e sUAS i s carr i ed to th e project site and n ot flown. The sUAS will carry no passengers or crew and, the ref o re, will not expose them to the r is ks associated with manned aircraft flights, gro und-b ased aerial li f t (b uc ket truck ) ope ratio n s, or manu al climbin g an d inspect ion opera tion s. The operation of s mall UASs, weighing le ss than 12lb s., conducted in the stric t conditio n s outlined above, will provide an equivalent l evel of sa fety support i ng the grant of the exemp tions requested herein, including exempting SkySpecs f r om the req u j r

ements o f Part 21 and allowing commerc i al operat i ons. These lig htweig ht aircraft operate at s low speeds, close to the gro und , an d in a low population e n vironmen t and , as a result, are far safer than co nventional alte rn atives.February 24 , 20 15 Page 10

P rivacy 

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ed Smith

A ll flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 --size, weight, speed, operating capabilities, proximity to airports and popula ted areas and operation within vis u al li ne of s i ght and national security

- provide more than adequate justification for the grant of the requested exemptions al l owing commercia l operation of SkySpecs' sUAS in the inspection of electrical, telecommunication wind energy and fl are stack structures pursuant to the Manual appended hereto. Sincerely,

Cou R. Bateman Reed Smith LLP Counsel for SkySpecs 

### /Sig n ed/ John McGraw J ohn McGraw Aerospace Consulting Consultant to SkySpecs CRB:lsj