June 3, 2015

U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington DC 20590 Dear Sir or Madam: Attached please find Sean M. Shortall’s (V2 Flow Controls, LL C)request for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Sy stems (“sUASs”) for Commercial Inspections and Surveying. Thank y ou for y our time and consideration, and please let me know if y ou have an y questions. Sincerely , Sean M. Shortall V2 Flow Controls, LL C. President June 3, 2015 U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).
Dear S ir or Madam: The aircraft being used for UAS operation s is: Make/Model: DJ I Inspire 1, multi

- rotor SN#W13DCC23020438. Payload: 6.46 lbs. Power: 22.2V L iPo 6S high voltage battery

. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (th e Reform Act) and 14 C.F.R Part 11, Sean M. Shortall, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned Aircraft Sy stems (“sUASs”) for commercial inspections and surveying , so long as such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333. As detailed in this document the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already best practices safet y protocols followed b y Sean M. Shortall. Approval of this exemption would thereb y enh ance safet y and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “..establish requirements for the safe operation of such aircraft s ys tems in the national airspace s ys tem.” Section 333 (c) of the Reform Act.The name and address of the applicant is: Sean M. Shortall

PHONE # 630

- 962

- 6870 Email: sshortall@v2flowcontrols.com Address: 1333 Burr Ridge Parkway Suite 200, Burr Ridge, IL 60527

Regulations from which the exemption 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. 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)
1. STATUTORY AUTHORI TY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authorit y includes exempting civil aircraft, as the term is defined under 40101 of the Act, includ ing 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 subsection (a) or (b) of this section or an y s ections 44702

- 44716 of this title if the Administrator finds the exemption ion the public interest. 49 U.S.C. 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace Sy stem (NAS) without creating a hazard to the user, the public, or a threat to national securit y. In making this determination, the Secretary must consider:

  The sUAS’s size, weight, speed, and operational capability ;

  Whether the sUAS operates within the visual line of sight of the operator

  Whether the sUAS operated outside of highl y populated areas and away from close proximity

to airports. Reform Act 333(a). If the Secretary determines that a sUAS “may operate safel yin the national airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace s ys tem.” Id. 333(c). Sean M. Shortall’s sUASs are multirotator vehicles, weighing 10 or fewer lbs. includin g payload. He operate under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously . The sUASs will operate only in the pilot’s visual line of sight at all times. Such operations will insure that the sUASs will “not create a hazard to users of the national airspace system or the public. “Reform Act Section 333 (b). Given the small size of the sUASs involved and the restricted environment within which they

will oper ate, our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence immediately

. Also due to the small size of the sUASs and the low altitudes and restricted areas in which our sUASs will operate, approval of the application presents no national securit y issue. Given the clear direction in Section 333 of the Reform Act, the authorit y contained in the Federal Aviation Act, as amended; the strong equivalent level of safet y surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public interest. Accordingl y, Sean M. Shortall respe ctfull y requests that the FAA grant the requested exemption without delay

. II. PUBLIC INTEREST 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 Secre tary of Transportation to consider whether certain unmanned aircraft s ys tems may operate safel y in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. By

granting an exemption the FAA will fulfill Congress’ intent of a llowing UAS to operate with significant safet y precautions in low risk environments. The use of sUASs have numerous applications and benefits where we will no longer need to risk human lives to complete basic tasks at high altitudes, environmentally frien dl y as there are no combustible fuels to exhaust. Additionally , sUASs could replace the use of helicopters and small aircraft to inspect/survey sites. The sUASs we propose to fl y in this application are under five pounds, as opposed to the much larger conv entionally powered small aircraft. Shifting to sUASs from helicopters presents a marked safet y increase for workers and the public.Lastl y, sUASs reduce the environmental impact by dramaticall y reducing the energy used

for aerial imaging and data collecti on over a construction site. Our sUASs use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are man y hundreds of times heavier. III. EQUIVALENT LEVELOF SAFETY Sean M. Shortall proposes that the ex emption 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 even higher level of safet y t o operations under the current regulato ry structure because the proposed operations represent a safet y enhancement to the already safe protocols followed on construction sites and imaging and surveying operations conducted with helicopters and other conventional aircraft. Sean M. Shortall will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption:
1. The sUAS will be less than 10 pounds. 2. Flights will be operated within visual line of sight of a pilot. 3. Maximum total flight time for each operation al flight will be less than 30 minutes. The UAS calculates the battery reserve in real time and will return with at least 25% of battery

charge remaining.
4. Flights will be operated at an altitude of 300 feet AGL, never exceeding 4 00 feet AGL. 5. Crew for each operation will consist of the sUAS pilot who will keep the sUAS within his visual line of sight at all times. 6. The sUAS pilot will be trained in flight, operations, and safet y procedures. 7. The sUAS will only

operate within a confined area. 8. A briefing/scope of operation will be conducted in regard to the planned sUAS operations prior to each flight. 9. All onsite personnel will consent to the UAS fl yover on site b y waiver, and the operator will obtain additional written consent of all pers ons who will be allowed within 50 feet of the flight operation. 10. The pilot will have been trained in operation of UASs generall y and received up

to

- date information on the particular UAS to be operated. 11. Written and/or oral permission from the relevant propert y h olders will be obtained. 12. All required permissions and permits will be obtained from territorial, state, county , or city

officials including but not limited to: L aw Enforcement and other Government Agencies. 13. If the sUAS loses communications or loses its GP S signal, it will have the capability to return to a pre

- determined location within the security p erimeter and land.14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.
IV . DESCRI PTION OF SPECIFIC REGULATIONS 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a)(1). Given the size and limited operating area associated with the aircraft to be utilized by Sean M. Shortall , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety

under Part II and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C 44701 (f) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operationa l capability , and proximity to airports and populated areas of the particular UAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from an airport or densely populated area. An anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft (fixed wing or helicopter) operating with an airworthiness cert ificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, and under the requirements and in compliance with local public safet y requirements, to provide security for the area of o peration as is currentl y done on active construction sites. The FAA will have advance notice of all operations. These safet y enhancements, which alread y appl y to civil aircraft operated in connection with construction sites, provide a greater degree of sa fet y to the public and propert y owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly , application of these same criteria demonstrates that there is no credible threat to national se curit y posed b y the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry and external load no greater than two lbs. 14 C.F.R. 45.23(b): Marking of the Aircraft This r egulation requires certain experimental, provisionally certified aircraft, or light

sport category

aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted”, “light

- sport”, “experimental”, or “provisional”, near each entrance to a cabin, cockpit, or pilot station.Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. Gi ven the size of the sUAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with 45.29(f). The equivalent level of safet y will be provided b y having the sUAS marked on its fuselage as required b y 4 5.29(f) where the pilot, observers and others working with the sUAS will see the identification of the UAS as “Experimental” The FAA has issued the following exemptions to this regulation. Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry

a pilot or passengers, the proposed operations can achieve the equivalent level of safet y of current operations by requiring the pilot operating the aircraft to have completed a UAS flight training course of 100 hours before flying a UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controll ed with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with commercial operations contemplated b y Part 61 when drafted, that allowing operations of the sUAS as requested with a pilot who has met the minimum requirements exceeds the present level of safet y achieved b y 14 C.F.R. 61.113 (a) & (b). 14 C.F.R. 91.7 (a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there is no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraf

t and the use of safet y checklists prior to each flight, as set forth in Section B and Section G, an equivalent level of safety will be provided. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements The sUAS, given its s ize and configuration has no ability or place to carry

such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacit y to carry such an item on the aircraft. The equivalent level of safet y will b e maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565 B, 10167, 10167A, 10602, 32827, and 10700.14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before a flight to ensure the safet y of flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual. These actions will provide an eq uivalent level of safet y. 14 C.F.R. 91.109 Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. By design, sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has previousl y approved exemptions for aircraft without fully

functional dual controls. See Exemption Nos. 5778K & 9862A. The equivalent level of safet y provided b y the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the uUAS via r adio signals from the controller, and b y the size and speed of the aircraft. 14 C.F.R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with an y route or altitudes prescribed for helicopters b y the FAA. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which will ty p icall y operate at altitudes of 3 00 AGL, so an exemption may be needed to allow such operations. The UAS will never operate at a ltitude higher than 5 00 AGL and will be in a restricted area with security

perimeter, where build ings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safet y will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the propert y owner or local officials. Because of the advance notice to the propert y owner and an y onsite personnel, all affected individuals will b e aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more that the maximum 10 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F.R. 91:121: Altimeter SettingsThis regulation requires each person operating an aircraft to maintain cruising altitude b y

reference to an altimeter that is set “..to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be ne eded. An equivalent level of safety will be achieved by

the operator, pursuant to the Safet y Checklist, confirming the altitude of the launch site shown on the GPS altitude indication before flight. 14 C.F.R. 91.151 (a): Fuel requirements for flight in VF R conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our UAS is limited to operations in sterile and controlled environments as outlined above and has a limited range and flight time which require an exempti on from 14 CFR 91.151 (a). The battery

powering the sUAS provides approximately 35 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS flights would be limited to approximately

5 minutes in length. Given the limitat ions on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Sean M. Shortall believes that an exemption from 14 CFR 91.15 1 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly

controlled area where onl y people and propert y owners or o fficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the t ype of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. Additionally , limit ing sUAS flights to 10 minutes would greatly reduce the utility

for which the exemption will be granted. An equivalent level of safety can be achieved by

limiting flights to 30 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring s ys tem and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from any where in its limited op erating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration. The regulation provided in part:

1. (a) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it the following:(1) An appropriate and current airworthiness certificate....

2. (b) No person may

operate a civil aircraft unless he airworthiness certificate required b y paragraph (a) of this section or a special flight authorization issued under 91.715 is display ed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully

loaded weighs no more than 10 lbs and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display

them on the sUAS. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they

are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph © of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to Sean M

. Shortall. Maintenance will be accomplished b y the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An equi valent level of safet y will be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately

and will be o perating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of an y m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition to provide the equivalent level of safet y.
Thank y ou for y our time and consideration on this matter. Respectfully ,

Sean M. Shortall