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, I, David M. Wolnski, hereby ap plies for an exemption from the Federal Aviation Regulations ("FARs") listed in Section I below to allow co mmercial operation of its Small Unmanned Aircraft Systems ("sUASs") for aerial imaging and safety and monitoring of Construction Jobsites so long as such operations are conducted within and under the c onditions outlined herein or as may be established by the FAA as required by Section 333 of the Reform Act. As detailed in this document and the attached Addendum, the requested exemption wou ld permit the operation of sUAS under controlled conditions in airspace that is 1) limited, 2) predeter min ed, 3) controlled as to access, and 4) would enhance quality, reduce environmental impacts, and pro vide safety enhancements to the already best practices safety protocols followed by David M. Wolnski. Approval of this exemption would thereby enhance sa fety and fulfill the Secreta ry of Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) of the Reform Act. The name and add ress of the applicant is: David M. Wolnski 1720 Shades View Lane Birmingham, AL 35216
C. 205.910.6160
W. 205.327.6620 E. dmw0021@auburn.edu

I. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED
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. 4 1 7 ( a ) & ( b )II. STATUATORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certi ficate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702 -44716 of this Title if the Administrator finds the exemption in the public interest.3 Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace System ("NAS") without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:
T h e s U A S ' s s i z e , w e i g h t , s p e e d , a n d o p e r a t i o n a l c a p a b i l i t y W h e t h e r t h e s U A S o p e r a t e s w i t h i n t h e v i s u a l l i n e o f s i g h t o f t h e o p e r a t o r W h e t h e r t h e s U A S o p e r a t e s o u t s i d e o f h i g h l y p o p u l a t e d areas and away from close proximity to airports If the Secretary determines that a sUAS "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system

. David’s proposed sUASs are multi -rotor vehicles, weighing 15 or fewer lbs. including payload. They will operate under normal conditions at a speed of no more than 50 mph and have the capability to hover, and move in the vertical and horizontal plane si multaneously. They will operate only in line of sight and will operate only within the sterile area described in the attached Exemption Request Addendum (hereinafter "the Addendum"). Such operations will ensure that the sUASs will "not create a hazard to u sers of the national airspace system or the public. Given the small size of the sUASs involved and the area within which they will operate, David’s application falls squarely within the zone of safety (an equivalent level of safety) in which Congress

env isioned that the FAA must, by exemption, allow commercial operations of sUASs to commence. Also due to the small size of the sUASs and the low altitudes and limited areas in which David’s sUASs will operate, approval of the application presents no national security issue.Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety and reduced environme nt impacts, the grant of the requested exemptions is in the public interest. Accordingly, I, David M. Wolnski respectfully requests that the FAA grant the requested exemption without delay so an sUAS can be l everaged on several projects that are already in construction.

III. 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 Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely 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's intent of allowing sUASs to operate with significant safety precautions in low risk
environments. The use of sUASs can significantly promote safe and effective Construction Jobsite inspection and tracking. For example, the use of sUASs can reduce the risk to workers while inspecting, surveying, or monitoring installation of work that requires ladders, scaffolds or other potentially hazardous means of elevated access. sUASs can inspect, photograph, video and collect data on inaccessible areas that otherwise would require wo rker inspection, in addition to providing facility security and emergency response reconnaissance. sUASs can also provide high resolution aerial imagery, elevation measurement, mapping, and thermal imagery data. Reducing manned flight and human inspection of such sites through sUAS use for site imaging will reduce risk to workers and ground personnel and create an improved safety operating environment. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The sUAS I, David M. Wolnski will be using carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Additionally, sUASs could reduce the use of fixed -wing aircraft to monitor sites. The sUASs I, David M. Wo lnski proposes to fly in this application weigh less than ten pounds, and carry no

co mbustible material on board, as opposed to much larger conventionally powered aircraft that I, David M. Wolnski currently uses to monitor its facilities. The limited weigh t significantly reduces the potentia lfor harm to participating and nonparticipating individuals or property in the event of an incident or

accident. The risk to an onboard
pilot and crew during an incident or accident is eliminated with the use of a sUAS on Construction Jobsites. Reducing the use of manned aircraft, or supplementing such flights through sUAS operations, presents the potential for a safety increase for David’s workers and the public. Lastly, sUASs reduce the environmental impact by dramatic ally decreasing the energy used for aerial imaging and data collection over a Construction Jobsite. Operation of lightweight sUASs powered by rechargeable lithium ion batteries offers improved efficiencies as compared to the operation of other aircraft and vehicles that consume gasoline and present a significantly louder noise signature. The reduction of fixed -wing aircraft to monitor Construction Jobsites also reduces the risk associated with human involvement and potential injury in aerial flyovers.

IV. EQUIVALENT LEVEL OF SAFETY I, David M. Wolnski proposes that the exemption requested herein apply 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 safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe protocols followed at our Construction Jobsites and imaging and surveying operations conducte d with other conventional aircraft. I, David M. Wolnski will be bound by the following limitations when conducting its sUAS operations under this FAA issued exemption: 1. The sUAS will weigh less than 15 pounds. 2. Flights will be operated within visual line of sight of a pilot and/or observer. 3. The sUAS will operate during daylight -only times (official sunrise to official sunset, local
time. 4. The sUAS will yield right -of-way to other aircraft at all times. 5. The sUAS will be registered with the FAA and will include appropriate markings and labels on the body of the sUAS. 6. Maximum total flight time for each operational flight will be 30 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% batterypower reserve should that occur prior to the 30 minute limit.

7. Flights will be operated at an altitude of no more than 400 feet AGL. 8. Minimum crew for each operation will consist of the trained sUAS Pilot who will keep the sUAS within his v isual line of sight (VLOS) at all times and one visual observer (VO). The VO and PIC will be able to communicate verbally at all times. 9. The sUAS Pilot will be trained in flight, operations, and safety procedures as detailed in the The Addendum.
10. sUAS Pilot will be Pilot in Command (PIC). 11. The sUAS will only operate within a confined "Sterile Area" as defined in The Addendum to limit the ability of the sUAS to leave the Construction Jobsite. 12. Notification of flight operations to personnel at the facility will be made through posted signs and onsite Job Safety meetings. 13. Notification of flight operations to the operator of David’s manned aerial patrol flights prior to flight commencement. 14. The sUAS will not be operated at a distance f rom clouds less than 500' below or 2000' horizontal, or when visibility is less than 3 statute miles. 15. I, David M. Wolnski will notify the FAA’s Air Traffic Organization (ATO) or local regulating authority of proposed flight plans. If necessary, the o perator will obtain a Certificate of Waiver or Authorization (COA) from the FAA's Air Traffic Organization (ATO) prior to conducting any operations. 16. I, David M. Wolnski will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, repla cement, inspection, and life limit requirements. 17. Pilot will have been trained in operation of the sUAS and receive up -to-date information on the particular sUAS to be operated should updates become available. 18. Operations will be limited to I, Davi d M. Wolnski Construction Jobsites (Including Joint Venture Projects) at which third party access is controlled. A ‘Sterile Area’ will be provided as described in the Addendum. 19. Operations will be limited to I, David M. Wolnski Construction Jobsites ( Including Joint Venture Projects) at which full Owner approval and authorization to leverage the sUAS has been granted.20. If the sUAS loses communications or loses its GPS signal, it will have the capability to

automatically and safely return to a prec -c oordinated, pre -determined location within the Security Perimeter and land with a predictable, automated flight maneuver. 21. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. The sUAS can host an on -boa rd parachute that will be deployed in the event of motor loss or emergency. 22. The radio frequency spectrum used for operation and control of the UAS will comply with the rules and regulations of the Federal Communications Commission (FCC).

V. DESCRIPTION OF SPECIFIC REGULATIONS A. 14 C.F.R. §61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command Sections 61.113 (a) & (b) limit private pilots to non -commercial operations. I, David M. Wolnski proposes that its sUAS PIC wil l have completed a minimum 2 -Day Training Program and at least 25-Hours of flight time in a safe and controlled environment prior to operating the sUAS on a Construction Jobsite as outlined in The Addendum. The airmanship skills necessary to operate the sU AS do not correlate significantly to the airmanship skills necessary for piloting manned aircraft and, thus, exemption from the need for the PIC to hold a commercial pilot certificate is also requested. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The areas of operation will be restricted to I, David M. Wolnski Construction Jobsites (Including Joint Venture Projects) at which third party access is controlled, and all fli ghts are planned and coordinated in advance as set forth in The Addendum. The level of safety provided by the requirements included in The Addendum exceeds that provided by a single individual holding a commercial pilot's certificate operating a convention al aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). In addition, the PIC will undergo all necessary security screenings by the Department of Homeland Security that certificated airmen undergo.B. 14 C.F.R. §91.103: Prefligh t action

This regulation requires each pilot in command take certain actions before flight to insure the safety of flight. An exemption is needed from this requirement as the PIC will take separate preflight actions, including checking for weather condi tions, checking flight battery requirements, checking takeoff and landing distances, etc. They are outlined in The Addendum. These actions will provide an equivalent level of safety. C. 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 any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multi -rotor craft that flies similarly to a helicopter, with vertical take-off and vertical landing, which will operate at altitudes up to 400' AGL, so an exemption may be needed to allow such operations. As described in the Ma nual, the sUAS will never operate at altitude higher than 400' AGL and will be limited to the area with the security perimeter, where buildings and people will not be exposed to operations without their notification as described herein. The equivalent leve l of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. Flights will be over I, David M. Wolnski properties at which third party access is controlled and Owner authorization is approved. Because of the advance notice to onsite personnel as outlined in The Addendum, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 15 lbs. proposed he rein and flammable fuel, any risk associated with David’s operations is far less than those presently presented with conventional aircraft. In addition, the low -altitude operations of the sUAS will ensure separation between these sUAS operations and the op erations of conventional aircraft that must comply with Section 91.119. Notification of flight operations will be provided to the operator of David’s manned aerial patrol flights, which have a low altitude waiver allowing for flight below 500' AGL.
D. 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 elevation of the departure airportor an appropriate altimeter setting availa ble before departure." As the sUAS may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to The Addendum and Safety Check list, confirm ing the altitude of the launch site shown on the GPS altitude indicator before flight. E. 14 C.F.R. §91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. David’s sUAS is limited to operations in sterile and controlled environments as outlined in The Addendum, and has a limited range and flight time which require an exemption from 14 C.F.R. 91.151(a). The battery powering the sUAS provides approximately 35 minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. §91.151, sUAS flights would be limited to approximately 5 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operat ions within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. I, David M. Wolnski believes that an exemption from 14 C.F.R. §91.151(a) falls within the scope of prior exemptions. Operating the sUAS, i n a controlled area with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Additionally, limiting sUAS flights to 5 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 det ermined by the onboard monitoring system and PIC), whichever happens first. Because of the limited operating area under which sUAS flights will be conducted, this restriction will be more than adequate to ensure return of the sUAS to its planned landing zo ne. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. F. 14 C.F.R. §91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections These regulations require that an aircraft op erator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except asprovided in paragraph (c) 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 section and Part 43 apply only to aircraft with an Airworthiness Certificate, these sections will not apply to Holder. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in The Addendum. An equivalent level of safety will be achieved because these sUASs are very limited in size and will carry a small payload and operate only in authorized ar eas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in The Addendum, the operator will ensure that the sUAS is in working order prior to initiating fl ight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safe ty.

******** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §§ 61.113( a) & (b); 91.103(b); 91.119; 91.121; 91.151(a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 ; (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (15 lbs. or less) for aerial imaging and monitoring of Construction Jobsites

. Approval of exemptions allowing commercial operations of sUASs to monitor, inspect and improve quality on Construction Jobsites will enhance safety by reducing risk. Conventional aerial monitoring by aircraft impacts the environment. In contrast, a sUA S weighing fewer than 15 lbs. and powered by batteries eliminates virtually all of that risk and environmental impact given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not e xpose them to the risks associated with manned aircraft flights. Although I, David M. Wolnski does not foresee completely replacing its manned flight operations with sUASs at this time, I, David M. Wolnski hopes, that overtime, sUASs may reduce or suppleme nt such manned programs. The operation of sUASs, weighing less than 15 lbs., conducted in the strict conditions outlinedabove, will provide an equivalent level of safety supporting the grant of the exemptions

requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are safer than convention al operations conducted with fixed -wing aircraft operating in close proximity to the ground and people.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

— size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant's sUASs on Construction Jobsites pursuant to Th e Addendum appended hereto.