Sections we are seeking relief from

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, 4K Aerial Imaging, LLC requests an exemption from th e following Federal Aviation Regulations (“FARs”): 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 1 4 C.F.R. 91.417(a) and (b).

Public Interest UAV Aeronautics Investigation & Logistics use of UAS for videoing and photographing utility components (e.g., Accident investigation, fire, train track inspection, search and rescue) as well
as survey mapping c an reduce the required manpower as well as the likelihood of inspection related injuries. A small UAS can be used to safely inspect powerlines instead of a large helicopter hovering within a close proximity of powerlines carry ing persons onboard with hundr eds of gallons of combustible fuel. The environmental impact can also be reduced when using small UAS instead of traditional methods of utility inspection. Small UAS can inspect, photograph and collect data in hard to reach areas that otherwise would requi re worker inspection. Manned aircraft have a greater possibility of becoming a threat to the general public through potential catastrophic crashes resulting in loss of life. Our small UAS pose no such threat due to their small size (each weighing less than 10 pounds), no onboard pilot, and lack of combustible fuel. This alleviates a large amount of potential threats to the public. Additionally

, small UAS reduce the environmental impact by dramatically

decreasing the energy

used for aerial imaging.

AI RCRAF T AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein appl y to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or e ven higher level of safet y t o operations under the current regulatory structure because the proposed operations represent a safet y enhancement for current Aerial photograph y services that use conventional, ‘full scale’, piston/jet driven aircraft. These li mitations and conditions to which UAV Aeronautics Investigation & Logistic LLC., the applicant, agrees to be bound when conducting commercial operations under an FAA issued exemption include: 4 Reform Act Section 333 (b).

Regulations from which the exempt ion is requested: 14 C.F.R Part 21 14 C.F.R. 45.23(b) 14 C.F.R 61.113 (a) & (b) 14 C.F.R. 91.7 (a)14 C.F.R 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R 91.151 (a) 14 C.F.R 91.203 (a) & (b) 14 C.F.R 91.405 (a) 14 C.F.R 407 (a) (1) 14 C.F.R 409 (a) (2) 14 C.F.R 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft s ys tems may operate safel y in the national airspace
sy stem (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which ty pes of UASsdo not create a hazard to users of the NAS or the public or pose a threat to national securit y in

light of the following: • The UAS’s size, weight, speed, and operational capability ; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333 (a). Lastly , if the Secretary determines that such vehicles “may operate safel y in the national airspace sy stem, the Secretary shall establish require ments for the safe operation of such aircraft in the national airspace sy stem.” Id. §333(c) . The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authorit y b y its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may

grant an exemption from a requirement of a regulation prescribed under subsec tion (a) or (b) of this section or an y sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

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