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# Federal Aviation Administration Exemption

Petition for Exemption under Section 333 FAA Modernization and Reform Act of 2012 Public 112-95 Feb. 14, 2012, Section 333 Submitted by: Lloyd & Associates

Mike Lloyd

Date: 2/19/2015

Dear Sir or Madam: Attached please find Lloyd & Associates request for an exemption from the listed Federal Aviation Regulations to allow commercial op eration of its Small Unmanned Aircraft Systems ("UAS") for aerial imaging for saf ety, monitoring, inspecting and/or recording of secured and controlled environment con struction sites, proposed development sites, inspections of property and phot ography for realty advertisements. This exemption request is exclusive ly for the use of the UAS manufactured by DJI, DJI Phantom 2. Also please find the link to the DJI Phantom 2 UAS Manual ("Manual"), which outlines the operating requirements, limitations, a nd technical specifications for the DJI Phantom 2 system. http://www.dji.com/produc t/phantom-2/download We have reviewed this Manual and in conjunction with t he requirements outlined in this document we have found it to be acceptable for UAS operations on our project sites.

Thank you for your time and consideration, and plea se let me know if you

have any questions. Sincerely,

Mike Lloyd Lloyd & Associates

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# Table of Contents

Contact Information ...............................

................................................... ..............3

Lloyd & Associates ................................

................................................... .............3

Exemption Applicant ...............................

................................................... ..............3

Mission Statement .................................

................................................... ............4

Intended UAS Use ..................................

................................................... ...........5

Specific Section of 14 CFR ........................

................................................... .....................6-12

Intended Equipment for Exemption ..................

................................................... ...........................13

Aircraft Specifications ...........................

................................................... ..................14

Aircraft Maintenance ..............................

................................................... ...............15

Safety Concerns ...................................

................................................... ........16

Potential Hazards .................................

................................................... .........17

Insurance Policy ..................................

................................................... .........18

Privacy Concerns .................................. ..................................................1 9-20

Operational Conditions ............................

................................................... ..............21

Pilot Qualifications ..............................

................................................... ............22

Pre-Flight Checklist ..............................

................................................... ............23

Active Flight Operations ..........................

................................................... ................23

Additional Resources ..............................

................................................... ............24

Exhibit A

................................................... ..........................................25

Exhibit B

................................................... .................................26

Exhibit C

................................................... ..........................................27

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# Contact Information

Exemption Applicant Lloyd & Associates General Contracting & Design (Lloyd & Associates)

Mike Lloyd Office 760-631-4457, Cell 760-403-5297 MikeLloyd@cox.net
, 2138 Curtis Dr, Vista CA 92084

Lloyd & Associates General Contracting & Design

2138 Curtis Dr

Vista, CA 92084

Phone: 760-631-4457

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# Mission Statement

To exercise, and continue to exercise, operational control of a light weight UAS in order to record vi deo and capture pictures of primarily real estate and properties for the purpose of enhanced public commercial service, worker safety, cost of services efficiency, investigative proficiency and accuracy.

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# Intended UAS Use

To record video and capture pictures of client's ho mes/properties for the use in real estate marketing materials, property development, property investigation and documentation by the use of light weight UASs in the following areas of commerce :

• Realty - Selling properties, enhancing advertising campaigns, and increasing production of marketing materials. Evaluating prope rty value by documenting assets and deficits especially in hard to access ar eas as an alternate to conventional large, heavy, combustible fuel bearing and manned vehicles are currently used.

• Property inspections - Especially roofing inspectio ns, especially tile roofs, are susceptible to added damage from an investigator wa lking on the roof to complete his initial inspection. A UAS could do the work and record the inspection findings without the probability of additional roof damage or personnel injury from falls. This service would be valuable to compa nies like: Roofing contractors, Insurance adjusters, property owners, renters, etc.

• Construction defect investigations - Site investig ation and findings specifically for building exteriors would be greatly enhanced by the use of a UAS. It can be very expensive to safely find and document exterior cons truction defects on multiple story building, a UAS could inspect, find and recor d information that would be otherwise only be accessible by ladders or scaffold ing. Also A UAS would be a much safer way to do this type of high and/or diffi cult access investigation.

• Site investigation - Such as steep hillside or bluf f. Recording the visual condition of existing hillsides or bluffs that would otherwis e be very difficult to access and record. It would also be less intrusive to environm entally sensitive areas.

• Site development - Creating high resolution scalabl e overhead photography of a property would be valuable to engineers, architects , designers and landscape architects in evaluating the best use for developin g a property and the potential effects that such development might have. Developme nt of existing properties for remodeling or renovation especially commercial buil ding where equipment is located on the roof would also benefit from HD phot os that document the equipment and its location. Currently Google Maps are useful for such endeavors but only with a very low resolution overhead photo of such properties.

• Developers and Construction Companies - To record a nd document the overall progress of large developments and to observe and d ocument job site safety.

• Landscape maintenance - To record landscape health and irrigation proficiency on large properties such as condominiums, apartment co mplexes, malls, golf courses or even public parks and recreation areas.

• There are many other areas that a UAS would be a sa fer, accurate and less expensive alternative to current commercial service s but Lloyd & Associates would be specifically interested in the areas mentioned a bove.

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# Specific Section of 14 CFR

Seeking specific exemption from:

Section 333 of the FAA Reform Act and Part 11 of th e 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); 91.20 3(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 ( a) & (b).
Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Lloyd & Associates, a design/bui ld and construction firm, hereby applies for an exemption from the listed Federal Aviation R egulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft Systems (" UAS") for aerial imaging for safety and monitoring of secured and controlled environment co nstruction sites, so long as such operations are conducted within and under the condi tions outlined herein or as may be established by the FAA as required by Section 333. As detailed in this document and the link to Flight Manual, the requested exemption would permit the operation of UAS under controlled condit ions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) wou ld provide safety enhancements to the already best practices safety protocols followed by Lloyd & Associates at each one of its project sites. Approval of this exemption would the reby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) respo nsibilities to "...establish requirements for the safe operation of such aircraft systems in the nati onal airspace system." Section 333(c) of the Reform Act. The name and address of the applicant is: Lloyd & Associates General Contracting & Design Mike Lloyd PH: 760-631-4457 Email: MikeLloyd@cox.net Address: 2138 Curtis Dr, Vista CA 92084

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. 91.203 (a) & (b)

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I. STATUTORY AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA a uthority to issue exemptions. This statutory author ity includes exempting civil aircraft, as the term is d efined under §40101 of the Act, including UAS, from the requirement that all civil aircraft must have a cur rent airworthiness certificate. The Administrator may grant an exemption from a req uirement of a regulation prescribed under subsectio n (a) or (b) of this section or any sections 44702-44 716 of this title if the Administrator finds the ex emption 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). Section 333(b) of the Reform Act assists the Secret ary in determining whether UAS may operate in the National Airspace System (NAS) without creating a h azard to the user, the public, or a threat to natio nal security. In making this determination, the Secreta ry must consider: • The UAS's size, weight, speed, and operational ca pability; • Whether the UAS operates within the visual line o f sight of the operator • Whether the UAS operates outside of highly popula ted areas and away from close proximity to airports Reform Act §333(a). If the Secretary determines tha t a UAS "may operate safely in the national airspac e system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. §333(c). Lloyd & Associates' UASs are multirotor vehicles, w eighting 10 or fewer lbs. including payload. They operate under normal conditions at a speed of no mo re than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultane ously. The UAS will operate only in the pilot's vis ual line of sight at all times and will operate only wi thin the recommendations described in the DJI Fligh t Manual, Such operations will insure that the UAS will "not create a hazard to users of the national airspace s ystem or the public." Reform Act Section 333 (b). Given the small size of the UAS involved and the re stricted and sterile environment within which they will operate, 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 UAS to commence immediately. Also due to the small size of the UASs and the low altitudes and restricted areas in which our UAS wil l operate, approval of the application presents no na tional security issue. Given the clear direction in Section 333 of the Ref orm Act, the authority contained in the Federal Avi ation Act, as amended; the strong equivalent level of saf ety surrounding the proposed operations, and the significant public benefit, including enhanced safe ty, the grant of the requested exemptions is in the public interest. Accordingly, Lloyd & Associates re spectfully requests that the FAA grant the requeste d exemption without delay. 

### II. PUBLIC INTEREST This exemption application is expressly submitted t o fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether ce rtain 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 o f allowing UAS to operate with significant safety pre cautions in low risk environments. The use of UAS on a construction or inspection site can significantly reduce the risk to workers of fa lls while inspecting, surveying, or monitoring site pro gress. UAS can inspect, photograph, and collect dat a on hard to get to areas that otherwise would require w orker inspection. Falls are the leading source of workplace fatality and injury on construction sites ', and reducing falls through UAS use for site imag ing could save workers lives. Additionally, UAS could replace the use of helicopt ers and small aircraft to monitor sites. The UAS we propose to fly in this application are under five p ounds, and carry no combustible material on board, as opposed to the much larger conventionally powered s mall aircraft. Shifting to UAS from helicopters presents a marked safety increase for our workers a nd the public.

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Lastly, UAS reduce the environmental impact by dram atically decreasing the energy used for aerial imaging and data collection over a construction sit e. Our UAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of smal l aircraft that are many hundreds of times heavier. 

### III. EQUIVALENT LEVEL OF SAFETY Lloyd & Associates proposes that the exemption requ ested herein apply to civil aircraft that have the characteristics and that operate with the limitatio ns listed herein. These limitations provide for at least an equivalent or even higher level of safety to operat ions under the current regulatory structure because the proposed operations represent a safety 1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: https://www.osha.gov/oshstats/commonstats.html enhancement to the already safe protocols followed on construction sites and imaging and surveying ope rations conducted with helicopters and other conventional a ircraft. Lloyd & Associates will be bound by the following l imitations when conducting its UAS operations under an FAA issued exemption: 

### 1. The UAS will be less than 10 pounds. 

### 2. Flights will be operated within visual line of sigh t of a pilot. 

### 3. Maximum total flight time for each operational flig ht will be 30 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% battery power reserve sh ould that occur prior to the 30 minute limit. 

### 4. Flights will be operated at an altitude of 200 feet AGL, never exceeding 400 feet AGL. 

### 5. Crew for each operation will consist of the UAS pil ot who will keep the UAS within his visual line of sight at all times and a spotter. 

### 6. The UAS pilot will be trained in flight, operations , and safety procedures as detailed in this documen t and as detailed in the DJI Manual. 

### 7. The UAS will only operate within a confined areas a s defined in this document. This document and the DJI Manual also requires the establishment of a Security Perimeter for the flight operations area. 

### 8. A briefing will be conducted in regard to the plann ed UAS operations prior to each day's production activities. It will be mandatory that all personnel who will be performing duties within the boundarie s of the safety perimeter be present for this briefing. 

### 9. All onsite personnel will consent to the UAS flyove r on site by waiver, and the operator will obtain additional verbal or written consent of all persons who will be allowed within 100 feet of the flight operation. 

### 10. The pilot will have been trained in operation of UA S generally and received up-to-date information on the particular UAS to be operated as required by th is document. 

### 11. Written and/or oral permission from the relevant pr operty holders will be obtained. 

### 12. All required permissions and permits will be obtain ed from territorial, state, county or city jurisdictions, including local law enforcement, fir e, or other appropriate governmental agencies. 

### 13. If the UAS loses communications or loses its GPS si gnal, it will have capability to return to a predetermined location within the Security Perimeter a nd land. IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR Part 21, Subpart H: Airworthiness Certificat es 14 C.F.R. §91203(a)(1) Subpart H, entitled Airworthiness Certificates, est ablishes the procedural requirements for the issuan ce of airworthiness certificates as required by FAR §9 1.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Lloyd & Associates, an exemption from Part 21 Subpart H meets the requirements of an equivalent l evel of safety under Part 11 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 requi rement for an airworthiness certificate, upon consideration of the size, weight, speed, operation al capability, and proximity to airports and popula ted 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 and more than thre e miles from any city or densely populated area.

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An analysis 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 a conventional aircraft (fixed wing or helicopter) op erating with an airworthiness certificate without t he restrictions and conditions proposed. The UAS to be operated hereunder is less than 10 lb s. fully loaded, carries neither a pilot nor passen ger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured ar ea as set out in this document and the DJI manual . Li ke other civil aircraft, operations under this exem ption will be tightly controlled and monitored by the ope rator, pursuant to this document and the DJI Manual 's requirements, and under the requirements and in com pliance with local public safety requirements, to provide security for the area of operation as is cu rrently done on active construction sites. These safety enhancements, which already apply to c ivil aircraft operated in connection with construct ion sites, provide a greater degree of safety to the pu blic and property owners than conventional operatio ns conducted with airworthiness certificates issued un der 14 C.F.R. Part 21, Subpart H. Lastly, applicati on of these same criteria demonstrates that there is n o credible threat to national security posed by the UAS, due to its size, speed of operation, location of op eration, lack of explosive materials or flammable l iquid fuels, and ability to carry an external load no gre ater than two lbs. 14 C.F.R. 45.23(b): Marking of the Aircraft This regulation requires certain experimental, prov isionally certificated aircraft, or light-sport cat egory aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light- sport," "experimental," or "provisional," near each entranc e to a cabin, cockpit, or pilot station. Even though the UAS will have no airworthiness cert ificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilo t station on which the word "Experimental" can be placed. Given the size of the UAS, two-inch letteri ng will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working wi th the UAS will see the identification of the UAS as "Expe rimental." The FAA has issued the following exempti ons to this regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilo t in command Sections 61.113 (a) & (b) limit private pilots to n on-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the air craft to have completed a UAS flight training cours e of 10 hours before flying a UAS. Unlike a conventional aircraft that carries the pilot and passengers, th e UAS is remotely controlled with no living thing or cargo o n board. The area of operation is controlled and re stricted, and all flights are planned and coordinated in adva nce as set forth in this document. The risks associ ated with the operation of the UAS are so diminished fro m the level of risk associated with commercial operations contemplated by Part 61 when drafted, th at allowing operations of the UAS as requested with a pilot who has met the minimum requirements of thi s document exceeds the present level of safety achieved by 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 conditio n. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airw orthiness. Given the size of the aircraft and the requirements contained in the DJI Manual for mainte nance and use of safety checklists prior to each flight, as set forth in this document, an equivalen t level of safety will be provided. 14 CFR 91.9 (b)(2): Civil aircraft flight manual, m arking, and placard requirements The UAS, given its size and configuration has no ab ility or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but be cause there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained b y keeping the flight manual at the ground control

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point where the pilot flying the UAS will have imme diate access to it. The FAA has issued the followin g exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. 91.103: Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requiremen t 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 Pre flight Checklist in this document and the DJI Manua l. These actions will provide an equivalent level of s afety. 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) tha t is being used for flight instruction unless that aircr aft has fully functioning dual controls. By design, UAS and remotely piloted aircraft do not have fully functional dual controls. Flight contro l is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has previously approved exe mptions for aircraft without fully functional dual controls. See Exemption Nos.5778K & 9862A. The equi valent level of safety provided by the fact that neither a pilot nor passengers will be carried in t he aircraft, the ability to control the UAS via rad io signals from the controller, and by the size and sp eed of the aircraft. 14 C.F. R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Section 91.119 (d) allows h elicopters 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 multirotor craft that flies similarly to a helicopt er, with vertical take off and vertical landing, wh ich will typically operate at altitudes of 200 AGL, so an ex emption may be needed to allow such operations. The UAS will never operate at altitude higher than 400 AGL and will be in a restricted area with secur ity perimeter, where buildings and people will not be e xposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved giv en the size, weight, speed of the UAS as well as th e location where it is operated. No flight will be ta ken without the permission of the property owner or local officials. Because of the advance notice to the pro perty owner and any onsite personnel as outlined in the Manual, all affected individuals will be aware of t he planned flight operations. Compared to flight op erations with aircraft or rotorcraft weighting far more than the maximum 10 lbs. proposed herein and carrying flammable fuel, any risk associated with our operat ions is far less than those presently presented wit h helicopters and other conventional aircraft operati ng at or below 500 AGL in the construction industry . In addition, the low-altitude operations of the UAS wi ll ensure separation between these small- UAS operations and the operations of conventional aircr aft that must comply with Section 91.119. 14 C.F.R. 91.121: Altimeter Settings This regulation requires each person operating an a ircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the d eparture airport or an appropriate altimeter settin g available before departure." As the UAS may not have a barome tric 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 t o the Manual and Safety Check list, confirming the al titude of the launch site shown on the GPS altitude indicator before flight. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for b eginning a flight in VFR conditions. Our UAS is lim ited to operations in sterile and controlled environment s as outlined in the Manual, and has a limited rang e and flight time which require an exemption from 14 CFR 91.151( a). The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to 0 minutes in length. Given the limitations on the UAS's proposed flight area and t he location of its proposed operations within a

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predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Lloyd & Associates believes that an exemption from 14 CFR §91.151(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 ar ea where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks t hat Section 91.151(a) was intended to alleviate giv en the size and speed of the small UAS. Additionally, limi ting UAS 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 li miting flights to 25 minutes, or enough battery res erve to ensure that the UAS lands at the ground station wit h at least 20% of battery power (as determined by t he onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing z one from anywhere in its limited operating area. Similar exemptions have been granted to other opera tions, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and regi stration The regulation provides in part: (a) Except as provided in § 91.715, no person may o perate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certif icate.... (b) No person may operate a civil aircraft unless t he airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued un der §91.715 is displayed at the cabin or cockpit en trance 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 t he UAS. An equivalent level of safety will be achieved by k eeping these documents at the ground flight control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable t o the UAS. 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 betw een required inspections, except as provided in paragraph (c) of this section, have discrepancies r epaired as prescribed in part 43 of this chapter... ," and others shall inspect or maintain the aircraft in co mpliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Lloyd & Associates. Main tenance will be accomplished by the operator pursua nt to the flight manual and operating handbook as refe renced in this Document and the DJI Manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricte d areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be oper ating from no higher than 400 feet AGL. As provided in the DJI Manual and this document , the operator wil l ensure that the UAS is in working order prior to initiating flight, perform required maintenance, an d keep a log of any maintenance performed. Moreover , the operator is the person most familiar with the aircr aft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. ******* Pursuant to 14 C.F.R. Part 11, the following summar y is provided for publication in the Federal Regist er, should it be determined that publication is needed: Applicant seeks an exemption from the following rul es: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. § § 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a);

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91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (551bs or less) in construction op erations. Approval of exemptions allowing commercial operatio ns of UASs in the construction industry enhances safety while reducing risk. Manned aircraft monitor ing and surveying creates a greater risk because the craft are much larger, have combustible fuel, a nd carry an onboard human pilot. In contrast, a UAS weighing fewer than 10 lbs. and powered by batt eries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weighting less than 10 lbs., conducted in the strict conditions outlined above, 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 a ircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a r esult, are far safer than conventional operations conducted with turbine helicopters operating in clo se proximity to the ground and people.

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# Intended Equipment for Exemption

Aircraft: DJI Phantom 2 v2 with H3-3D Gimbal and Go Pro Camera Radio Frequency: 2.4GHz ISM Radio Sensitivity: -97d Bm Manufactures Website: http://www.dji.com/
Cameras: GoPro Hero, GoPro Hero 2 1 

## GoPro Hero 3+, and GoPro Hero 4 Manufactures Website: http://gopro.com/

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# Aircraft Performance

- 

## Altitude: 1640 ft. (500m)

- 

## Operational Range: 3,280 ft. (1,000m)

- 

## Hover Accuracy: (Ready to Fly) Vertical: 0.8m; Hor izontal: 2.5m Precision Flight and Stable Hovering

- 

## Flight Time: 25 Minutes

- 

## Battery Life Quadcopter: 25 Minutes
Remote Control: Over 2 Hours of Continuous Use

- 

## Weight (Battery & Propellers included): 1000g

- 

## Max Yaw Angular Velocity: 200/s

- 

## Max Tilt Angle: 35 0

- 

## Max Ascent Speed: 6m/s

- 

## Max Descent Speed: 2m/s

- 

## Max Flight Speed: 15m/s(Not Recommended)

- 

## Take-off Weight: !

~ 

## 1300g

- 

## Operating Temperature: -10°C 50°C Self-Tightening Propellers For in-depth info see http://www.dji.com/product/ph antom-2/spec

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# Maintenance

To ensure safe operational control a maintenance sc hedule will be followed, a personal tailored maintenance manual has been creat ed, and quality replacement part will be used.

Inspection : Before and after every flight, the quadcopter's o perational condition will be inspected for damage and deterior ation, paying attention to the props for damage, cracks or ware a nd the UASs fuselage for damage . If damage, cracks or unusual ware is detected the flight will be suspended until proper repairs h ave been made.

Maintenance

o Simon Newton's Maintenance Videos https://www.youtube.com/watch?v=7Jum34eU4W8

o Also http://www.phantompilots.com/viewtopic.php?f=7&t=51 48

o Other tutorials and how-to videos Hypervision Australia Tutorials https://www.youtube.com/watch?v=fKIAfjtdPgI&list=PL X7- 5smcu-Vw38bmfMnunAESCTiNgbt8S Replacement Parts o Dji (manufacturer) o Reputable After Market Companies

There is no intention in modifying aircraft beyond factory specifications.

• The UAS will be in compliance with the FAA airworth iness regulations.

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# Safety Concerns

Prop guards: Prop guards such as the DJI manufactures guards li sted here https://store.dji.com/product/phantom-2-series-prop eller-guard will always be in use during commercial flights.

Hazards Spotter : To ensure safety, either the listing agent, selle r, contractor, owner or another party, will be on site to review and observ e hazards before and during the flight.

Population of Intended Areas : To ensure safety, all non-essential personnel wil l be removed from the area. There will be no flight over heavily populated areas like stadiums, schools, malls, casinos, and the like during operat ing hours.

Airports: According FAA rules and to ensure pilot(s) safety, there will no flight in or around airports unless explicit permission is grant ed according to current FAA regulations.

Weather: To ensure safety of spotter, agents, property owne rs, pet and wildlife flights will be conducted in optimal weather conditions. Fl ights will not be conducted in winds above 20 mph.

Return-to-Home Feature: In the event the DJI Phantom 2 v2 H3-3D loses sign al or runs critically low on battery the UAS has a GPS co ntrolled return to home feature. The "home" is set upon flight startup.

- Auto Return-to-Home & Landing -See Pre-Flight Checklist Exhibit A

Flying in Confined Areas: There is a high probability of flying in confined spaces, around residential properties. Pilot and spotter wi ll be in constant communication by two way radio, or cell phone, or other approved FAA communications device when geographically separated during flight to ensure aw areness of obstacles, hazards and UAS location.

Line of Site: The UAS will always be within the line of site of t he pilot and spotter. If the UAS cannot be seen the return home failsafe will be used to regain visual control.

Height : Fights will not exceed 400 ft AGL above subject p roperties at any time.

### 17 

# Potential Hazards

The following are potential hazards that may, or ma y not be, present during flight operations. The Pilot and Spo tter will be aware of : -Other UASs -Houses, Commercial Buildings, Shops, and Out Build ings -Power Lines, Low Voltage Lines, High Voltage Lines , Cable Lines -Trees, Shrubs, and Hedges - Automobiles and RVs -Wildlife, both Land and Air -Rivers, Lakes, Ponds, Sounds, Straits, and Other B odies of Water -Unaccounted for People -Unaccounted for Pets -Conditions as set forth in the DJI Manual

### 18 

# Insurance Coverage

Commercial UAS insurance coverage is not currently available through private insurers or through AMA (Academy of Model A eronautics).

### 19 

# Privacy Concerns

During flight operations privacy concerns are of hi gh priority. With each commercial flight a signed agreement, wil l be in place.
Seller/property owner, contractor, engineer or auth orized agent will sign a letter authorizing the Lloyd & Associates UAS's u se for marketing purposes. -

Exhibit B

Neighboring parcels or properties: During each flig ht operation, the UAS pilot will be extremely mindful of neighboring parc els to not film, record, or take pictures of people and property wit hout their written & signed consent.

All neighboring properties will be cropped from pho tos unless authorization to use such photos is granted in writ ing.

Suburban Homes & Properties Homes that are within residential neighborhoods, it is easy for the camera's field of view to record and take pictures of homes and properties that are not intended to be advertised f or sale. As the UAS increases altitude, so does the risk of inadvertent ly filming a home or property that hasn't given written permission to do so. Where privacy is a concern images will be cropped t o omit neighboring properties

.

### 20 

# Privacy Concerns Cont.

Properties with Acreage
Homes and properties with acreage have a higher deg ree of uncertainty when trying to determine lot lines, bou ndaries, and proximity to neighboring properties than a suburban home. Also, people looking to purchase a home with acreage, or a larger lot, have a higher degree of interest on knowing were the appro ximate lot lines are and an aerial perspective affords them such informa tion. The use of an UAS would be the most effeminate means to provid e such
information.

Homes with View & Waterfront People looking to purchase and/or sell a home, or a property, with a view, or on waterfront, want to see the home or pro perty from an aerial perspective and to be showcased in this format. Thi s is part of property owner profile. In addition, even though neighboring parcels might be shown in the picture and video, the neighboring pro perties will only be included if is necessary to the subject property's marketing materials.

* All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Image s taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography w ill take place. Satisfaction of the criteria provided in Section 33 3 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 applica nt's UAS in the construction, realty industry pursuant to the DJI M anual and this document appended hereto.*

### 21 

# Operational Conditions

To capture high resolution images and video operati onal conditions will be closely monitored because showcasing a property in the best light is and image quality is the utmost client priority.

Day Time o Sunny Weather is Highly Preferred

o Little to No Cloud Cover
o Zero to Low Wind Speeds

o High Visibility Conditions

*No night-time operations are permitted.

### 22 

# Pilot Qualifications

Training Sessions for a Lloyd & Associates certifie d pilot(s).

Current Pilot: Mike Lloyd

Pilot's Flight Log; Exhibit C

• The Pilot in command will be familiar with current FAA regulations regarding UAS commercial usage.

• The Pilot in command will have sufficient eye sight (with or without corrective lenses and without the aid of binoculars) to see and opera te the UAS at the distances necessary for the purpose of the flight.

• Pilot will be in good health.

• New Pilots in training will shadow and act as the P ilot in Command Spotter for 3 Months or for a minimum of 20 hours P rior to First Flight Operations

• New Pilots will demonstrate a workable knowledge or the UAS and proficiency in operational control at all times.

• Pilots in training will Watch Online Training Video s.

• Pilots will watch Online Training Videos for Specif ic Type of Filming Needs

• Pilots will attend Upcoming, and Local, UAS Courses (This is Part of Pilot's Continuing Education)

• Pilots will attend Local Courses Hosted by Dji (Thi s is Part of Pilot's Continuing Education)

• Every Pilot Will Follow the Flight Plans and Schedu les Set Forth in this Document and current FAA regulations.

### 23 

# Pre-Flight Checklist

Prior to every flight, the pilot will go through a pre-flight checklist. The checklist will then be filed with every property's file in th e event of an audit.

Preflight Checklist: SEE Exhibit A


# Active Flight Operations

Exercise continuous control of UAS, monitor potenti al hazards, be aware of changing environments that may present hazards. UAS will always be in view of Pilot and spotter. There will be a strict flight ce iling of 400 ft AGL. All flight will be
done in accordance with current FAA rules and the c onditions set forth in this
document.

### 24 

# Additional Resources

-http://knowbeforeyoufly.org/ -http://www.dji.com/newpilot https://www.lioutube.com/channel/UC R io W t W R 9 BPVZK8 YxMrH2Zw-http://www.modelaircraft.org/

- http://www.dji.com/product/phantom-2/download - htt://www.dji.com/product/phantom-2/sec - http://www.dji.com/support -http://wiki.dji.com/en/index.php/Phantom 2 -htt://wiki.dii.com/en/index.php/Phantom 2 Vision%2 13 Flight Limits -http://www.dji.com/newpilot

### 25

Exhibit A 

# Pre-Flight Checklist

Flight Operation Location: ________________________

Pilot:_________________________

Date:_________________________

 Conduct Walk Around of Flight Area

 Identify Potential Hazards with Spotter

 Locate Safe Launch & Landing Area

 Set Spotter (Spotter May Change Location due to Fil ming Angle) Secure all Pets

 Request on Non-Essential Personnel to Remain Behind Pilot

 Unpack All Equipment from Transportation Case

 Inspect UAS for damage, ware and proper flight setu p according to the DJI manual. If no damage or unusual ware is detected pr oceed to the next step. If damage is detected the flight will be aborted until proper repairs are completed.

 If the UAS is deemed flight worthy - Power Up Remot e

 Power Up GoPro

 Initiate Video Recording

 Power Up DJI Phantom 2

 Launch DJI Phantom 2

 Conduct Flight Operations

 Land DJI Phantom 2 in Designated Landing Area

 Power Down DJI Phantom 2

 Turn Off Video Recording

 Power Down GoPro

 Power Down Remote

 Inspect UAS for damage and ware

 Put All Equipment Back into Transportation Case



### Pilot Signature____________________________________

_______

### 26

Exhibit B

RE: Authorization to Record Video & Photograph Prop erty



### I, , legal seller and/or representative, authorize and give permission to Lloyd & Associates to record video and photograp h the property commonly
known as:

___________________________________________________ _____________________

___________________________________________________ _____________________

___________________________________________________ _____________________

The recorded video and photography is to be used in a manner consistent with the clients interests, current real estate marketin g strategies and advertising techniques, property development, investigation and observation.
Sincerely,

Signature Date

Signature Date

### 27

Exhibit C


## UAS Flight log

Pilot; Mike Lloyd

Date

9-10-14

9-11-14

9-12-14

9-14-14

9-18-14

9-20-14

9-21-14

9-23-14

9-25-14

9-26-14

9-28-14 Hours

2

1

1

2

1

2

2

1

2

1

1 Location

Home-213Curtis Dr Vista CA Home

Home

Home

Vista Sports Park Vista Sports Park Home

Home

Home

Home

Home Project

personal

Personal

Personal

Personal

Personal

Personal

Personal

Filming tests

Filming tests

Filming

Filming

Estimated Hours Between 10-1-14 and 2-19-15 = 24-3 0 hrs