December 4, 2015

Federal Aviation Administration: On behalf of Scopes LLC, we would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow our operation of unmanned aircraft systems (UAS) for the purpose of UAV based thermography, photo, video, LiDAR and integrated software systems to conduct inspections of solar cell installations, power lines, multi

- story buildings and agriculture areas. We will operate a UAS, the DJI Phantom 3 Advanced , which is comprised of an unmanned aircraft, an attached HD camera , an attached thermal camera FLIR VUE PRO 640 or LiDAR camera and a transportable ground station. The DJI Phantom 3 Advanced is a quad copter with a maximum gross weight of about 2 .82 pounds. It is equipped with four rotors that are driven by electric motors pow ered by batteries. The UA has a maximum airspeed of approximately 52.4 ft/s

. **UAS Operating Parameters** We will abide by the following additional operating conditions under this exemption: • operate UAS within a 100

-foot envelope of the target being inspect ed or below 400 feet AGL, whichever is greater, and within radius distance of 1000 feet from the controller to aid in direct line of sight visual observation; • obtain permission from the owner/controller of any vessels, vehicles and structures when operat ions may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard; • operate the UAS for 10

- 20 minutes per flight; • land UAS prior to the manufacturer’s recommended minimum level of battery power; • operate UAS within visual line of sight (VLOS); • use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; • contact respective airports if operations will be within 5 m iles to advise them of his esti mated flight time, flight duration, elevation of flight and other pertinent information; • always obtain all necessary permissions prior to operation; • have procedures in place to abort flights in the event of safety breaches or potential danger (reference “DJI Phantom 3 Advanced User Manual ” provided); • conduct extensive preflight inspections and prot ocols, during which safety carries pri mary importance (reference “DJI Phantom 3 Advanced User Manual” provided ).**UAS Pilot in Command (PIC)**

The PIC will hold either an airline transport, commercial, private, recreational or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid US driver’s license. All PICs will demonstrate the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the requested exemption, including evasi ve and emergency maneuvers and maintaining appropri ate distances from persons, ves sels, vehicles and structures. **Specific Exemptions Requested** Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption from 14 CF R part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 3 33 of P.L. 112

- 95 (Section 333). We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that anyone wil l see the markings. We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable. We request a n exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we will perform a preflight inspection of the UAS b efore each flight as outlined in the attached operating documents. We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. We request an exemption from § 91.119 which prescrib es safe altitudes for the opera tion of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We wi ll operate the UAS within a 100

-foot en velope of the target being as sessed, or below 400 feet AGL, whichever is greater. We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. We request an exemption from § 91.151(a) Fuel requi rements for flight in VFR condi tions. The UAV is 100% electric and two low battery ale rts are issue d

- per the operat ing documents, the UAV will be landed at the first alert. Also, our flights will last only 5

- 20 minutes each, and the UAS has an automated function which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless (consider ing wind and forecast weather conditions) there is enough power to fly to the firstpoint of intended landing and, assuming normal cruising speed, land the UA with 30% battery power

remaining. **Business and Public Interest** Traditionally commercial scale solar power plants use truck

- mount camera, airplane/ helicopter fly

-over to perform thermography of the solar panels. T hermography using truck mount camera is restricted by the types of terrain, poor accessibility, vehicle’s vibration and overall energy consumption. The cost of fly

- over thermography often times exceeds the value of the inspection. In both cases, the overall fossil fuel consumption tarnishes the benefits of solar power generation. Also g round and suspended sc affold based photo, video , thermography and LiDAR assess ments have been around for some time, but can be c ost

- prohibitive and time consum ing. In the case of operations from suspended scaffold stages and Boatswains' chairs are inherently risky and governed by OSHA Fall Protection regulations. By granting this exemption , you would en able us to provide this service at a much lower risk profile, both for inspectors and the public, lower cost and with greater energy efficiency. Further, our small UAS will pose n o threat to the public given its small size, automatic emergency recovery system and lack of combustible fuel when compared to larger manned aircraft. **Summary** We will comply with all of the following conditions and limitations should this grant of ex

- empti on be provided: 1) Operations will be limited to the following aircraft described in the operatin g documents which is a quad copte r aircraft weighing less than 3 pounds: DJI Phantom 3 Advanced Un

- manned Aircraft System.
2 ) The UA will not be flown at an airspeed exceeding 31 knots.
3 ) The UA will be operated within a 100

-foot envelope of the target being assessed or below 400 feet AGL, whichever is greater, and within radius distance of 1000 feet from the controller to aid in direct line of sight visual obse rvation.
4 ) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times.
5 ) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to com municate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribe d in the operating documents.
6 ) The operating documents will be accessible during UAS operations and made availa ble to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.
7 ) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed an d the UAS is found to be in a condition for safeflight. The Ground Control Station will be in cluded in the preflight inspection. All maintenance and

al terations will be properly docu mented in the aircraft records.
8 ) Any UAS maintenance or alterations that affect the UAS operation or flight character istics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records.
9 ) The pre

-flight i nspection section in the operating doc uments will account for all dis crepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.
1 0 ) We will follow the UAS manufacturer’s aircraft/co mponent, maintenance, overhaul, replacement, inspection, and life limit requirements.
11 ) We will carry out maintenance, inspections, and rec ord keeping requirements, in ac cordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.
12 ) Each UAS operated will comply with all manufacturer Safety Bulletins.
13 ) An aut horized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 15) UAS operations will be conducted by a PIC possessing a t least a sports pilot certifi cate and at least a
curren t third

- class medical certificate or a valid US driver’s license. 16) Prior to operations conducted for the purpose of this exempt ion, the PIC will demon strate then ability to safely operate the UAS, includ ing evasive and emergency maneu vers and maintainin g appropriate distances from perso ns, vessels, vehicles and structures. 17) The UA will not operate within 5 nautical miles of an airport reference point as de

- noted on a current FAA

- published aeronautical chart, unless a letter of agreement with that airp ort’s management is obtained or otherwise permitted by a COA issued. 18) The UA will not be operated less than 500 feet below o r less than 2,000 feet hori zontally from a cloud or when visibility is less than 3 statute miles from the PIC. 19) If a UA loses communications or loses its GPS signa l, it will return to a predeter mined location within the planned operating area and land or be recovered in accord ance with the operating documents. 20) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 21) The PIC will not begin a flight unless (considering wind and forecast weather condi tions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA wit h 30% battery power remaining. 22) Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirement s.23) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground

Control Station of the UAS any time t he UAS is operating. These docu ments will be made available to the Administrator or any law enforcement official upon request. 24) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 25) The UAS will not be operated by the PIC from any moving device or vehicle. 26) The UA will not be operated over congested or densely populated areas without an inspected, armed and operational emergency recovery system rated for the maximum gross weight of the UAS. 27) Flight operations will be conducted at least 500 fee t from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. We will ensure that nonparticipat ing persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to t hose objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 28) All operations will be conducted over private or cont rolled

- access property with per mission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions co ntained on the NTSB Web site: www.ntsb.gov.