Iron Bay Model Company Section 333 UAV Exemption Request

1 February 29 , 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Madam/Sir,

Pursuant to Section 333 of PL 112

- 95 commonly known as the “FAA Modernization and Reform Act of 2012”, Iron Bay Model Company hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the purposes of aerial photography & videography, aerial inspection, mapping, agricultural su rveillance, data collection, real estate marketing , and other non

- recreational

activities

.

Respectfully submitted

,

John Craig

President Iron Bay Model Company

155 Redwood Drive Washington, PA 15301

724

- 554

- 8879 jcraig@iron

- bayIron Bay Model Company Section 333 UAV Exemption Request

2 Table of Contents

I. Operators Name and Address

II. Exemptions Requested and Reasons for Relief

III. Public Interest

IV. Proposed Operation

V. Make and Model, Unmanned Aircraft System (UAS)

VI. Summary

VII. Glossary of AbbreviationsIron Bay Model Company Section 333 UAV Exemption Request

3 I. Operators Name and Address

John Craig Iron Bay Model Company

155 Redwood Drive Washington, PA 15301

724

- 554

- 8879 jcraig@iron

- bay

II. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e), Iron Bay Model Company requests exemption from the following regulations:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.2 03(a) & (b)

 14 C.F.R. § 91.215(b)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

 14 C.F.R. Part 21 Subpart H

– Airworthiness Certificates The procedural requirements for th e issuance of airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1)

.

Given the characteristics of th e UA S and safeguards outline d below, with co nsideration of the size, weight, speed, operational capability of the particular UAS, as well as location of operation, lack of explosive materials, lack of flammable liquid fuels, inability to carry a substantial load, operation exclusively within a secured area , carrying neither a pilot nor passenger, tightly controlled and monitored by both the ope rator and observer ; a greater degree of safety is provided to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Sub part H.

 14 C.F.R. § 45.23(b)

– Aircraft Marking and Identification Requirements When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, theIron Bay Model Company Section 333 UAV Exemption Request

4 operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

Com pliance with § 45.29(f) to meet the intent of the regulation will be achieved by displaying the registration number in the largest practicable lettering.

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101

– Recreational, Private and

Commercial Pil ot Privilege and Limitations 14 C.F.R. § 61.113 (a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for

com pensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection w ith any business or employment 14 C.F.R. § 61.133 : (a) Privileges

– (1) General. A person who holds a commercial pilot certificate may act as pilot in command of an aircraft

– (ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable
parts of this chapter that apply to the operation. 14 C.F.R. § 61.101 : (a) A person who holds a recreational pilot certificate may not act as pilot in command of an aircraft:

T he inherent risks of operatin g a UAS are far less than in commercial activities outli ned in 14 CFR part 61, et seq., due to the size, weight, speed, operational capability, etc. Currently there are no pilot licenses specific to UAS operators

, and no current FAA sanctioned pilot license of any type requires training with and knowledge of U AS equipment greater than the requirements Iron Bay Model Company uses to certify its PICs. Further, a recreational, private, or commercial pilot certificate will not ensure RC piloting ability (necessary for remote control UAS operation) as the psychomot or skills are different. Therefore, the requirement of any available FAA sanctioned pilot license to operate a SUAS does not make a PIC a more competent operator than one meeting the requirements of Iron Bay Model Company. Consequently, the very same

UAS can be legally operated with absolutely no experience, training, license, or certification by the average person in the same NAS as long as the flight is of a non

- commercial (for hire or financial compensation) nature. Therefore the method of operation a nd safeguards imposed provide a greater degree of safety to the public and property owners than conventional operations conducted by a certified PIC

, or for non

- commercial use of UAS. T hus exemption is requested from 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101

– Recreational, Private and Commercial Pilot Privilege and Limitations 14 C.F.R. § 61.113:

 14 C.F.R. 91.7(a)

– Civil Aircraft Airworthiness No person may operate a civil aircraft unless it is in an airworthy condition.

The PIC will conduct daily pre and post flight inspections in accordance with manufacturer’s maintenance manual(s) and guidance.

During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon identification of an in

-

flight emergency or other unsafe condition. By complying with procedures outlined by the manufacturer, an equivalent level of safety will be achieved.

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirementsIron Bay Model Company Section 333 UAV Exemption Request

5 (b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Due to the small size and limited payload capacity of the S UAS, it is not feasible to carry the

relevant materials on

- board the aircraft, therefore to meet the intent of the regulations and achieve an equivalent level of safety, all operating documents, manuals, authorizations and exemptions will be maintained in a binder co

- located with the GCS.

 14 C.F.R. 91.109(a)

– Flight Instruction No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The majority of S UAS by design are developed with single operational control through the use of

pre

- determined GPS enabled waypoints programmed before or during flight in addition to the use of a single hand held transmitter or control station controlled by the PIC. The design does not allow for dual controls during flight training and th erefore the exemption is requested to train operators, build experience, and maintain proficiency. An equal level of safety will be achieved by conducting all training in sterile environments. Training sessions will be accomplished separately from flights conducted for compensation or hire.

 14 C.F.R. 91.119 (c)

– Minimum Safe Altitudes Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (b) Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically

pr escribed for helicopters by the FAA.

Commercial UAS operations will be conducted at or below the maximum altitude authorized by COA. Given the size, weight and lack of fuel; combined with operation limitations listed below, the operation will be conducte d with a greater level of safety than exists with current manned aviation operations.

 14 C.F.R. 91.121

– Altimeter Settings Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating...

SUAS are equipped with Global Positioning System (GPS), which provide altitude and geolocation data to the operator without utilizing an altimeter. Due to this fact, an exemption is required. GPS are precise within a few feet and combined with fail

- safes and a visual observer

the operation will meet an equivalent level of safety.Iron Bay Model Company Section 333 UAV Exemption Request

6  14 C.F.R. 91.151(a)

– Fuel Requirements for Flight in VFR Conditions No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly af ter that for at least 30 minutes;

This regulation is written based on the capabilities of a traditional aircraft, which have flight times of several hours or greater; t herefore, with the majority of S UAS which h ave flight times of an hour or less, this r egulation would effectively deny the ability of the air vehicle to operate. The PIC will achieve an equivalent level of safety by complying with all manufacturer guidelines including a low battery failsafe system.

 14 C.F.R. § 91.203 (a) & (b)

- Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (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 airwor thiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit

entrance so that it i s legible to passengers or crew.

Due to the small size and limited payload capacity of the SUAS, it is not feasible to carry the

relevant materials on

- board the aircraft, therefore to meet the intent of the regulations and achieve an equivalent level of safety, the certification and registration documents, will be

maintained in a binder co

- located with the GCS.

 14 C.F.R. 91.215(b)

– ATC Transponder and Altitude Reporting Equipment and Use All airspace. Unless otherwise authorized or directed by ATC, n o person may operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to

Mode 3 /A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C

- 112, and th at aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100

- foot increments. This requirement applies

— (1) All aircraft. In Class A, Class B, and Class C airspace areas; (2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL; (3) Notwithstanding paragraph ( b)(2) of this section, any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are

conducted

— (i) Outside any Class A, Class B, or Class C airspace area; and (ii) Below the altitude of the ceiling of a Class B or Class C airspace area d esignated for an airport or 10,000 feet MSL, whichever is lower; and (4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and (5) All aircraft except any aircraft which was not originally certificated with an engine

- driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider

— (i) In all airspace of the 48 contiguous states and t he District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and (ii) In the airspace from the surface to 10,000 feet MSL

within a 10

- nautical

- mile radius of any airport listed in appendix D, secti on 2 of this part, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace de signatedIron Bay Model Company Section 333 UAV Exemption Request

7 for that airport. The S UAS to be used in the proposed operation does not come equipped with a transponder. No transp onder exists for the S UAS, which can be installed.

The petitioner requests relief from the exemption to the extent required to operate in areas in which a transponder is required according the applicable regulations in this part. The PIC will

achieve an equivalent level of safety by complying with all provisions of the COA under which operations are to be conducted. By ATO coordination and issuing appropriate prior NOTAMS

, an equivalent level of safety can be achieved as other manned aircraft, which receive authorization to fly in airspace where a transponder is required but not operable. In order to give proper notice to the ATO, the PIC will comply with the provisions of 91.215(d)(3). The S UAS flown under this exemption will comply with all altitude limits and airport standoff distances required by COA, which mitigate hazards to aircraft controlled by the ATO in congested airspace.

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)

– Maintenance Inspections 91.405(a) States : Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescri bed in part 43 of this chapter 91.407(a)(1) States : (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by

a person authorized under § 43.7 of th is chapter o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (2) An inspection for the issuance of an airworthiness certificate in a ccordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ‘‘annual’’ inspection in the required maintenance records. o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i

– vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1

– 3)

The PIC will conduct Pre/Post flight inspections and maintenance in accorda nce with the manufacturer’s guidance as stated in the operations manual. If maintenance is required, the PIC will conduct a dedicated test flight to ensure safety before resuming commercial operations. All inspection, maintenance and alterations will be do cumented and maintained in a record. These actions will meet the intent of the regulations from which exemption is being requested and lead to an equivalent level of safety.

II I . Public Interest

Traditionally, aerial filming for the television and film industries has relied primarily on the use of traditional aircraft. These larger combustible

- fueled aircraft pose significant risk to the crew, passengers and the public in general due to their inherent dangers and the proximity of use to participants. S mall unmanned aircraft are ideal for the television and film industries, as well as industrial and commercial applications because they reduce and/or eliminate much of the inherent danger. SUAS do not carry combustible fuel, they have a significantly less er impact on the environment, are less disruptive, smaller, more maneuverable and safer than conventional video and photographic aircraft. When operated responsibly, a SUAS utilizes lower altitudes within visual line of sight of the PIC in a predetermined airspace

, and are piloted with aid of high resolution positioning sensors for very high accuracy andIron Bay Model Company Section 333 UAV Exemption Request

8 repeatability . These protocols and methods further reduce the risk of personal injury or property damage. Since SUASs are unmanned, risk to pilots and crew are practically impossible. In many ways SUASs are ideal for the film and television industries and they will likely be responsible for enhanc ing production value in unexpected ways. Granting a 333 exemption to Iron Bay Model Company will reduce the reliance on traditional large aircraft for aerial video work and advance safe integration of additional SUASs into the NAS, further reducing risk a nd enhancing public safety. The exemptions requested have already been granted to other entities for the same and/or similar purposes, i.e., Exemption No’s.: 11062,
11109, 11112, 11213, 12645, 13696, 13987, 13999, and 14001

. G iven the stated evidence, pr ocedures, and precautions operating UAS commercially , t hese operations, when executed with prudence, will exceed the current level of safety as the regulations from which exemption is sought. The low expense of operation compared to cost prohibitive manned aviation alternatives allow a greater economic benefit to businesses. UAS technology used for commercial purposes benefit the public interest by reducing the collateral damage risks to life and property and noise associated with low altitude fixed wing an d helicopter operations, increased economic well

- being to local businesses via cost reductions, and enabling aerial business solutions to be available to a larger market. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest.

IV

. Proposed Operation:

Iron Bay Model Company is seeking 333 exemption for use of a SUAS for closed

- set film operations for

film and television production , on

- location film or television operations

, aerial video support for films and commercials in controlled environments; augmentation of real

- estate listing videos, creation of visual and topographical layout videos for state and local agencies, academic activities

, special event coverage,

emergency and first responder situations, agricultural inspections, building and construction zone inspections , and other commercial applications

. The SUAS will be flown via a combi nation of RC control and tablet, laptop, or smart phone based GCS. This SUAS type is a GPS/Autopilot e quipped, multirotor helicopter, utilizing electric m otors and l ithiu m

- polymer batteries . The SUAS has several fail

safes for loss of RC signa l, loss of GPS, and low battery . The SUAS display s visual

, and emit s an audible low battery alert . If the SUAS loses communication with the PIC or loses its GPS signal, the SUAS automatically returns to a pre

- determined location within the Security Perimeter and lands autonomously. The SUAS also has the ability to perform an emergency abort in case of unpredicted obstacles, weather, or other situations which may compromise safety.

Operating Standards

1. All operating documents, flight logs, manuals, authorizations, certifications, exemptions, etc.,

will be maintained and co

- located with the GCS to prov ide full transparency to the FAA, State, and Local authorities.

2. The PIC designated for any operation will have at least a Class 2 medical certificate or valid
Driver’s License.

3. Minimum crew for each operation will consist of the PIC, and the Visual Observe r. 4. PIC and Visual Observer will have been trained in the operation of the specific SUAS equipment used and have up

- to

- date information on the particular SUAS to be operated.

5. P otential obstructions or other hazards to safe operation will be identified by th e crew at each

location.

6. A comprehensive worksite inspection and analysis, identifying limits of customer property or

authorized access areas will be conducted

. 7. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200

f eet above an elevated platform from which filming is planned. If a structure being filmed orIron Bay Model Company Section 333 UAV Exemption Request

9 photographed has a height which exceeds 400 feet AGL, the UAS will not exceed 100 feet in height above the h ighest point on that structure.

8. Flights will be opera ted at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation.

9. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation. This radius may be reduced for specific circumstances based upon an equivalen t level of safety

determination.

10. The PIC will coordinate all activity with the controlling air traffic organization to issue appropriate prior NOTAM , and advise the appropriate FSDO with relevant details of the intended activity

. 11. The PIC w ill conduct a preflight safety briefing with all personnel invo lved with the operational duties of the flight.

12. The PIC w ill operate in those areas only with the consent of the landowner or designated representative.

13. The PIC w ill at all times yield to manned air traffic.

14. The PIC w ill operate within VLOS of both PIC and VO during daylight hours only.

15. The PIC w ill maintain voice communications with VO and participating persons.

16. The PIC w ill operate under visual flight rules, in visual meteorological conditions, for the airspace in which the flight is conducted.

17. The PIC w i ll not exceed the maximum altitude as defined in the COA under which flight authorized, as determined by the installed GPS.

18. The PIC w ill terminate flight, in the safest manner possible, when unable to comply with these limitations or any other limitations granted as part of this exemption.

19. The PIC w ill terminate flight, in the safest manner possible, when safety to persons or property become compromised.

20. All required permissions and permits will be obtained from territorial, stat e, county or city jurisdicti ons including local law enforcement, fire or other appropriate government agencies

. 21. If the SUAS loses communication with the PIC or loses its GPS signal, the SUAS will have the capability to return to a pre

- determined location within the Security Perimet er and land autonomously.

22. The SUAS will have the capability to perform an emergency abort in case of unpredicted obstacles, weather, or other situations which may compromise safety.

By following these operating standards, the commercial operation will meet an equivalent level of safety to the regulation in which relief is sought.

V. Make and Model Unmanned Aircraft System (UAS)

The petitioner seeks exemption to operate a commercially produced Arris M1100 UAS. The Arris M1100 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing a conventional R/C Transmitter, and electronic tablet, laptop computer system, or smart phone. The ARRIS M1100 has a maximum gross weight of approximately 12 lbs., a diagonal dimension of 1100mm, and maximum speed of approximately 16 fps. The Arris M1100 is equipped with eight rotors positioned equidistant around the perimeter; driven by Lithium Polymer battery powered electric

motors. Octoco pters such as the Arris M1100 are typically safer than comparable quadcopters due to the reduced effect that a motor failure causes. Octocopters can remain aloft and controllable even with the loss of two motors, while a single motor failure will immediat ely ground a quadcopter. The Arris M1100

utiliz es the popular ArduPilot APM UAV controller and Mission Planner software. The controller is aIron Bay Model Company Section 333 UAV Exemption Request

10 mature, commercially produced, full

- featured, open source multicopter UAV controller capable of a full range of flight requirements including multiple fail

- safes which can be programmed through one of the ground station systems described. For instance: s afety functions such as auto

- return to launch point, emergency hover, emergency stop etc., can be programmed through any one of these systems.

Controller Specifications

 14 PWM/servo outputs (8 with failsafe and manual override, 6 auxiliary, high

- power compatible)

 Abundant connectivity options for additional peripherals (UA RT, I 2 C, CAN)

 Integrated backup system for in

- flight recovery and manual override with dedicated processor and

stand

- alone power supply

 Backup system integrates mixing, providing consistent autopilot and manual override mixing

modes

 Redundant power supply inputs and automatic failover

 External safety button for easy motor activation

 Multicolor LED indicator

 High

- power, multi

- tone piezo audio indicator

 microSD card for long

- time high

- rate logging

Microprocessor s (2)

 ATMEGA2560

 ATMEGA32U

- 2

Sensors

 ST Micro L3GD20 3

- axis 16

- bit gyroscope

 ST Micro LSM303D 3

- axis 14

- bit accelerometer / magnetometer

 Invensense MPU 6000 3

- axis accelerometer/gyroscope

 MEAS MS5611

- 01BA03 barometer

 Neo

- 6M GPS module with compass ic

Programming of the autopilot is accomplished through Mission Planner software. Mission Planner is a

full

- featured ground station application for the ArduPilot family of open source autopilot projects. Rather than rely on a traditional printed Operation M anual

, extensive documentation and resources in the form of video tutorials, operation manuals, discussion groups etc., are available on the internet for the ArduPilot family of products, software, and development tools.

Mission Planner features:

 Poi nt

- and

- click waypoint entry, using Google Maps/Bing/Open street maps/Custom WMS.

 Select mission commands from drop

- down menus

 Download mission log files and analyze them

 Configure APM settings for your airframe

 Interface with a PC flight simulator to creat e a full hardware

- in

- the

- loop UAV simulator.

 Output can be seen through APM’s serial terminal

V I . Summary

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:Iron Bay Model Company Section 333 UAV Exemption Request

11 Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii); 91.7 (a); 91.9 (b); 91.103 ; 91.109 (a) ; 9 1.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 9 1.407 (a)(1); 91.409 (a)(2); and 91.417 (a) & (b) to operate commercially a small unmanned aircraft (55 lbs

. or less) for airborne activities including video and inspection services. The SUASs wil l 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 55 lbs., conducted in the strict conditions outlined 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. 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 opera tion of applicant’s SUAS equipment for commercial purposes

.

VII. Glossary of Abbreviations :

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control ATO Air Traffic Organization

AV Aerial Vehicle CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration FAR Federal Aviation Regulation

FMRA Section 333 FAA Modernization and Reform Act of 2012

GCS Ground Control Station GPS Global Positioning System

LOL Loss of Link NAS National Airspace System

NOTAM Notice to Airma n PIC Pilot In Command SO Safety Observer SOP Standard Operating Procedures

SUAS Small Unmanned Aircraft System

UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules

VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing