### March 24,2015

US Department ofTransportation Docket Operations · West Building, Ground Floor Room·W12-140 1200 New Jersey Ave., SE Washington, DC 20590


### Re: Request for authorization to conduct unmanned aircraft systems operations allowed by 

### Section 333 ofthe FAA Modernization andReform Act of2012 through the _exemption process identified under 

### 14 C.FR. Section 11.81. Dear Sir/Madam;_ Located in the heart ofAmerica's "Ag belt," FlightWink"tLC is a Kansas LLC founded by four members of the business, agriculture, and aviation community, Arman A. 

### Miller, JohnS. Harkness, Cody L. 

### Betsworth, and DeWitt M.Harkness.

. Over the past year and one halfwe, as FlightWink LLC, have amassed many hours ofoperational experience in unmanned aerial systems(UAS). We have conducted many practice non-commercial missions on our 160..:acre rural Wabaunsee County, Kansas, land. F 1 i g h tWink L L C' s

. commitment is unparalleled when it comes to UAS**experi~nce,** 

### study, craft maintenance, safety

practices, and safety instruction. DeWitt M. Harkness, has several decades of experience as a current private pilot with a current Class 3 Medical (please_ see attached) and holds a 

### VSO Line ofSight Operator Certification from the Unmanned Safety Institute (please-see attached). All FlightWink LLC's personnel and all business, agriculture, and aviation activities will be properly and fully insured.

··flightWink LLC is poised to bring safety and experience to the United States civilian UAS

operations industry. Our exemplary business and aviation experience plus our emphasis on the practice and teaching ofUAV safety, we feel, makes us more than worthy for the Secretary to approve our exemption request. 

### Pursuant to Section 333 ofPL 112-95 commonly known as the 

### "FAA Modernization andReform Act of 2012" or 

### "The ReformAct", FlightWink LLC, hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the agriculture, oil and gas, aerial photography and wildlife preservation indtistries, within the United States National Airspace System (NAS) within Class 

### G and occasionally E airspace, along with additional restrictions identified herein.

### We are submitting the attached detailed information specifically outlining why approval of thisrequest is in the best public interest and how this approval will provide a level ofsafety at Ieast equal to that provided by the rules FlightWink LLC seeks exemption from.
In addition, through our continued operational experience in the UAS field, FlightWink LLC will show how the approval ofthis request will facilitate our _ability to ·work with**the~**AA 

### to safely accelerate the integration ofcivil unmrumed aircraft into the national airspace system as 

### directed by Congress. By strictly adhering to the guidelines presented herein, FlightWink LLC will insure a safety level**gr~ater** 

### than that directed by the rules for which we seek exemption.- This is especially true when

· you compare the same operating procedures against a manned aircraft. SUAS are inherently safer

due to the fact that they are much smaller, fly at much lower speeds with no human operators on board, and there is zero fuel to be concerned with in the event ofa crash.
As processes are further refined, FlightWink LLC's operations will only add to an already higher level ofsafety compared to manned flight operations which will serve the best public interest in the FAA's endeavor to integrate UAS into the NAS.

We certainly look forward to gaining approval ofcommercial UAV 

### operations for FlightWink LLC.

7

### Sincer~ly

# tI**~I** ,

# ~4( 'WittM. Harkness, Managing Partner/Pilot Flight Wink LLC 3910 SW Friar Rd. Topeka, KS 6661 0 dewitt2@wolfes.com 785-640-3229Training & Operations


### Section 333 of"The. ReformAcf' 

### states:
"

...the Secretary ofTransportation shall determine 

### if certain unmanned aircraft systems may operate safely in the national airspace system
...ln making the determination under subsection (a), the Secretary shall determine, at a minimum- (I) which types ofunmanned aircraft systems, 

### ifany, as a result of

. their size, weight, speed, operational · capability, proximity to·airports andpopulatedareas, and

operation within visual line of sight do notcreate a hazardto users of the nationalairspace system orthe public orpose a threat to nationalsec:Urity

... " · 

### FlightWink LLC will utilize the 

### Volantex Raptor (fixed. wing) and the 

### Tarot T -1

### 8 (oCtocopter) to conduct operations for the agriculture, oil and gas, aerial photography**·~d** 

### wildlife preservation industries. Both crafts meet the requirements for exemption per the "Performance andSpecifications" 

### section to follow

.

.**~** .. . 

### Operating within visual line ofsight (VLOS) and remaining**belo~** 

### 400 feet AGL are standard operating procedures-for·FlightWink LLC, and will remain so until.further advances in safety offlight are introduced to the market and regulated by the FAA. · ·As described below, all operationswill be confined to those areas no closer than 5 statue miles ofany airfield and the proper authorities will be notified with any operations within five statUe miles

.

.Safety is ofthe utmost priority in_any and all FlightWinkLLC operations.

. 

### .

### The Airctaft;

. Design: Both ·crafts are built from a variety of durable, lightweight, and modular

components that aid intheir capability to safely conduct flights in a variety ofconditions. The modularity of construction allows. for easy exchange of structural, propulsion, and sensor components in the field as per each manufacturer's specifications and repair/maintenance instruction manuals. · 

### Aircraft Performance/Specifications:



### • •

• 

### • • Cnift Composition: Raptor--

### Thermoplastic; Tarot--Carbon 

### Fiber Flight Controls: (both craft) o Primary: GPS Guided Autopilot (Ground Control Station) o Backup: Standard Flight Controls (RC Transmitter) Power Supply: (both craft) Electric Motor/Next-Gen Battery Technology Wingspan: Raptor--72"/6 

### ft

. Diameter: Taroi--Q0"/5 

### ft. with Sea. IS" props. • ·Speed in knots: Raptor-- 

### Max: 45/Cruise: 25/Stall: 1 0; Tarot-Max: 

### 25 Empty Weight: Raptor--5.5 

### lbs.; Tarot-IS 

### lbs

. 

### •

· • .Max Payload: Raptor--5 

### lbs.; Tarot-15 

### lbs.



### • 

### • Launch (Take Oft): Raptor--Hand-launch or catapult; Tarot"--(}round 

### launch Recovery (Landing): ·Raptor--Skid 

### Recoverable (belly landing); Tarot"--(}round 

### landing 

### Opetator Training: All**initi~l** 

### flight operations and maintenance training will be conducted in accordance with each manufacturer's training manuals. Opct: operator candidates have met.FlightWink LLC's management's requirements, they wilrenter into FlightWink LLC's qualification training program· which includes FAA authorized ground school training and a.

### Class III medical examination. Upon successful completion, the operator will earn their Co-Operator/Observer rating. Co-Operators/Observers will be required to conduct 50 operational hours 

### aiid complete the Visual Line ofSight Operator's course through the

. ·Unmanned Safety Institute to be considered for Operator in Command qualification testing. The operator candidate will then be required to complete an o r a l test and "check ride" upon successful completion ofwhich, the operator will receive their Operator in Command rating.

· NOTE: KingSchools will conduct Groundschool training on-line. DeWitt M Harkness will, in the future, conduct the VSO training. · · 

### Initial certification training requirements instructed by 

### each include: Pre-Flight Training: • Unpacking artd assembly • Power requirements, set-up arid connectivity • System end-to-end set-up and test inspections • Preflight, run-up and system .checks 

### Flight Operations Training: • · Proper Handling • Motor Operations

### • GCS Flight Programming and Test 

### • Launch 

### • Basic Flight (climb, cruise, descent, landing) 

### • Maneuvering 

### • Airspace and Landing Zone OJ?erations 

### • Flight Reprogramming 

### • Flight Monitoring 

### • In-Flight Em_ergency Procedures



### .Post Flight:

### • Shut Down Procedures 

### • Data Retrieval and Storage 

### •
.End-to-End Test and MaintenanceLogs 

### • Disassembly

. 

### • Packing, Storage and Transportation**Co-Oper~tor/Observer** 

### qualification training requirements instructed by FlightWink LLC:


### • 

### • • • 

### • • • Understanding FAA Rules 

### I Regulations Collection Requirements Operational Planning Flight Planning Area ofOperations

- Hazard Mitigation Daily Flight and Inspection Log Completion Proper Authority Notification Process 

### Operator in Command qualification testing**require~ents** 

### instructed by FlightWink LLC:


### •



# .. Visual Line ofSight VSO written e xarn consisting of 30 questions with a pass rate of 80% following the**guideline~** set forth by the Unmanned Safety Institute "Check Ride" and Oral exam consisting of: o Airport Operations o Maintenance Inspections o Flight Plan Development o Area ofOperations Hazard Mitigation o Weather Hazard Mitigation o Emergency Procedures o Pre-Flight Operations o Flight Operations o Post-Flight Oper:ations

### FlightWinkLLC's Operations Execution:· Given the fact commercial UAS operations are restricted due to the lack ofregulations, a

. logical and safe solution is to utilize the safety guidance provided for hobbyist use of

sUAS and other model aircraft as identified by 

### Advisory Circular 91-57 and Section 336 of the "Reform Act". FlightWink LLC operations will be conducted in a methodical, efficient, and most importantly, safe manner adhering_to strict guidelines· which addresses safety concerns with proximity to airports arid populated areas in the interim of official guidance from the FAA as the rules and regulations are being further · developed. The following list provides specific rules and guidelines all FlightWink LLC operations will adhere to ensuring at least an equivalent or higher level of safety when compared to manned aircraft performing the same functions as outlined within 14 C.P.R.

. 

### All FlightWinkLLC's crews will: Be comprised ofa minimum oftwo certified operators with one serving as Operator in Command (OIC) and the other(s) as Co-Operator/Observer(s).
Consist ofone certified air vehicle maintenance techniciag:;to conduct pre and post flight inspections.
NOTE: 0/C/Observermay also jillthe role of the maintenance technician Attend pre and post flight mission briefs which will consist of**~eather** information, flight information to include operational area and mission objectives, hazard mitigation actions and most importantly emergency and abort procedures; also included will be any NOTAMs or improvements to standard operating procedures through further refinements in operations. Sign applicable documentation verifying their attendance to ·mandatory briefs as well as produce daily pre and post flight inspections and flight logs. 

### All FlightWink LLC's operations will: At no time fly within 5 statute miles ofany operational airfield.
Provide prior notification to airfield operator and airfield air traffic control tower (when applicable) when operating within five statute miles ofany active airfield no later than 24 hours prior to air ·operations. Provide prior written notification to local/county sheriff and fire departments in the event·assistance is require<;{ to include: flight plans, type and capabilities ofair vehicle(s) operated and operator's contact information no later than 24 hours prior to operations. Be conducted using sUAS as defiried by the FAA weighing less than 55 lbs. All operations authorized through this exemption request will be done with our 

### Raptor and/or 

### Tarot with all future aircraft presented to FAA for approval prior to operational use. Be conducted in Class G and**·o~casionally** E airspace and shall not exceed 400 feet above ground level (AGL). 

# ..Be conducted within visual line ofsight (VLOS) ofthe qualified OIC and Co-· Operator/Observers.
Give right-of-way to and avoid flying near manned aircraft at all times.
Be conducted in rural environments and outside ofcity limits.
Be conducted with prior written consent from landowner. Ensure air vehicles do not encroach within 250 feet of any improved road, person, vehicle or structure that is not associated with operations.
Abort/Cancel in the event of detrimental weather to include wind speeds exceeding the allowable limits as defmed within operations manuals. 

### FlightWinkLLC's Emergency Procedures:
• lri the event the air vehicle losses GPS**signal~** automated landing will immediately commence. The flight plan is built in such a way that hazards are identified prior to launch and an immediate landing within the flight plan will ensure all hazards are avoided. (This safety feature is inherent to sUASand no further assistancefrom the 0/C is necessary; however, the 0/C will retain option for manual control at all times.) • In the event the OIC loses signal with the air vehicle, automated landing will immediately commence._The flight plan is built in such a way that hazards are identified prior to launch and an immediate landing within the flight plan**\\~II** ensure all hazards are avoided. (This safety feature is inherent to the sUAS and with operations being conducted in the rural environment aspreviously stated, there are no concerns to personnel, vehicles or structures with an autonomous landing.) • In the event hazardous weather unexpectedly approaches and may affect operations, the OIC will immediately abort the operation and conduct landing activities. 

### •

• In the event an in:-flight emergency occurs, (ie. air vehicle maintenance issues), the OIC will immediately abort flight and conduct landing activities; air vehicle inspection will immediately be achieved and the air vehicle will not return to service without proper authorization from certified maintenance technicians. In a "significant" event (ie. air vehicle crashes and outside assistance is needed), OIC will conduct notification procedures to include county sheriff and fire departments, airfield operator/tower ifapplicable and any other authority required to mitigate situation. o A "significant" event report will be generated by the OIC, verified by the Co/Observer and maintenance technician and immediately provided to the OIC and FlightWink LLC management.
NOTE: Notification can be made to the FAA to assist in futureprevention techniquesAs stated in the cover letter, FlightWink LLC, by following our many strict self-imposed guidelines, will achieve a safety level greater than that directed by the rules from which we seek exemption. T h i s w i II b e especially true when you compare the same operating · procedures against a manned aircraft. Again, sUAS are inherently safer due tothe fact that they are much smaller, fly at much lower speeds with no human operators on board, and there is zero fuel to be concerned with in the event ofa crash. As processes are further refined, FlightWink LLC's continued extremely conscientious operations will only add to an already higher level of safety compared to manned flight. FlightWink LLC's operations will serve the public's best · interests as they relate to the FAA's endeavor to integrate VAS i.nto the NAS.**Re~latiOns-** Exemption Requested 

### by FlightWink LLC;
Pursuant to 

### 14 C.FR. § 

### 11.81(e), FlightWink LLC seeks exemption from the below mentioned regulations and provides reason as to why the exemption should be approved based on the level ofsafety at least equal to that ofwhich the rules require·.



### • 14 C.FR. Part 21 Subpart H- Ainvorthiness Certificates:**-~** Establishes: The procedural requirements for the issuance ofainvorthiness certificates as requiredby 14 C.F.R. § 91.203(a)(l) Given the small size ofthe UAS, the limited operating areas and meticulous procedures defined within the training and operations section, an exemption from 

### Part 21 Subpart H meets the requirements ofan equivalent level of safety under 

### Part 11 and Section 333 of the "Reform Act" with consideration "of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS."

NOTE: The FAA has recently setprecedence to this regulation within likegivenparametersandan exemption shouldbeapprovedon this basis. See exemption approvals for Blue Chip, AstraeusAerial, AerialMOB, HeliVideo Productions, RCPro Productions, Snapro/1 Media, andPictorvision.

### • 14 CF.R. § 45.23(b)- Aircraft Marking and Identification Requirements:


### >- 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: 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, the operator must also display on that aircraft near each entrance to the cabin, cockpit, orpilot 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. · Flight\yink LLC will ensure compliance with§ 

### 45.29(/) to meenhe intent ofthe

. regulation by placing the word 

### "Experimental," for all to see, on each craft plus a unique ·FlightWink LLC identification number in the event several craft ofthe identical like and type are acquired.

NOTE: The FAA has setprecedence to this regulation within likegivenparameters andan exemption shouldbe approvedon this basis along withprevious exemptions: Nos. 10700, 10167and 10167 A. Also, seemost recent exemption approvals for Blue Chip, AstraeusAerial, AerialMOB, HeliVideo Productions, RCPro Productions, Snapro/1Media, andPictorvisionfor forther justification of approval.



### • 14 CF.R. 61.113 (a)(b) and 61.133(a)(l)(ii)- Private**a~d** Commercial Pilot Privilege and Limitations:**~-** 14 C.F.R. § 61.113: "(a) Except as provided in paragraphs (b) through (g) ofthis section, no· person who holds a private pilot certificate may act as pilot in command of an aircraft that is carryingpassengers orproperty for compensation or hire; nor maythatperson,for compensation· or hire, act aspilot in command of an aircraft. (b) Aprivatepilot may,for compensation or hire, act aspilot in commandof an aircraft in connection with any business or employment 

### if


### >- 14 C.F.R. § 61.133: (a) Privileges

- (1) General. A person who holds a**commercia~** pilot certificate may act as pilot in command of an aircraft- (ii) ·For compensation or hire, provided iheperson is qualified in accordance with thispart andwith the applicableparts of this chapter that applyto the operation. Currently, there are no applicable areas identified for sUAS in either the private or commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations Will be conducted in a restricted environment as described in the operations section, these strict guidelines will achieve an equivalent level of safety for. each individual flight especially when compared to commercial flights identified in 

### Part 61 when originally developed

.. In addition, each craft's primary control system will utilize GPS waypoints for guidance and control, FlightWink LLC's flight operations will be conducted by qualified 0 perators with ground school certification, a Class III medical, and a VSO Operator's Certification.
NOTE: Operators may or maynot holdaprivatepilot license.

Due to the fact not all operators will be rated pilots, all flight operations will be overseen and directed by, DeWitt M. Harkness, a current FAA certified private pilot with current FAA ground school certification. a current Class 3 medical, and holding a**~** 

### . current VSO Operator's certification from the Unmanned Safety Institute. This wi!I give all FlightWink LLC's operations an equivalent level ofsafety.• 14 C.F.R. 91. l(a)- 

### Civil Aircraft Ainvorthiness:



### • 

### > States: Nopersonmayoperate a civilaircraft unless it is in an airworthy condition. Currently there is no airworthiness certificate for either ofthe craft. FlightWink LLC will submit same to the FAA as soon as the manufacturer's supply one. In the interim, daily pre and post flight inspections will be accomplished in accordance with manufactures maintenance martual(s) and guidance. During flight, the OIC will adhere 

### to§ 

### 9I. 7(b) and abort air operations immediately upon identification of an in flight emergency. A II ·maintenance performed will be conducted by our maintenance technicians and/or by the manufacturer's themselves. By applying the prescribed operations, inspection, and maintenance procedures within the operations section, an equivalent level of safety will be achieved.

. . NOTE: The FAA has setprecedent bypreviously issuing exemptions for§ 91.7(a): Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, /0167, 10167A, 10602, 32827, and 10700. Also, seemost recent exemption approvalsfor Blue Chip, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, SnaprollMedia andPictorvisionfor forther justification of approval. I4 C.F.R. 

### 9I.I03-PreflightAction: 

### > States: Eachpilot in commandshall, before beginning a flight, become familiar with all available information concerningthat flight. This information must include- (paragraphs a, b, I and2) A 

### "Pre-flight Mission" brief must be attended by all crewrnembers. This "PMB" will contain weather and all flight information including emergency and abort procedures. A signature will be required by all crew members indicating they have received the PMB and have read any NOTAMs or other procedural updates which may have an impact on standard operating procedures. In addition, the OIC will verify the craft is ready for flight by coordinating with the maintenance technician during pre-flight inspection. The exemption requested for this section is specifically addressed toward the requirements that do. not apply to sUAS operations such as runways and air traffic control integration.
NOTE: Aspreviouslystated, air traffic. control andairport operator will benotified prior to any operations beingexecutedwithin[lvestatute miles
NOTE: The FAA has recentlysetprecedence to this regulation within likegivenparameters and an exemptionshouldbe approvedon this basis. See exemption approvals for Blue Chip, Astraeus Aerial, AerialMOB, HeliVideo Productions, RCPro Productions, SnaprollMedia, and Pictorvision.

• I4 C.F.R. 9I. I09(a) ._ 

### FlightJnstruction: 

### > States: Noperson may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircrafthas folly fUnctioning dual controls. The majority of sUAS by design are developed with single operational control through the use ofpre-determined GPS enabled waypoints programmed before or during flight in addition to.the use ofa single hand held transmitter or control station controlled by theOIC. The design does not allow for dual controls during flight training and therefore the exemption is requested to qualify/certify operators as required by the manufacturer along with specific operations training and**proce~ures** identified above within section II.·
An equivalent level of safety will be ensured during training operations by utilizing the same flight planning process for normal operations. As identified in the flightplanning document, all ground hazards will be identified and mitigation·techniques will be enacted to ensure flights stay outside of 250 feet of any improved roads; · vehicles,_ persons or structures. Training operations will be conducted within a confined space-on our 160-acre private land ·in rural Wabaunsee County, Kansas.
NOTE: The FAA hassetprecedent bypreviously issuingexemptions for§ 91.109( a): Exemption Nos. 5778Kand9862A. Also, seemostrecent exemption approvals for Blue Chip, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RCPro Productions,·Snapro/1 Media, and Pictorvisionfor fUrther justification of approval.

• 14 C:F.R. 91.119 (c)- 

### Minimum Safe Altitudes:



### • );> States: Except when necessary for takeoff or landing, noperson may operate an aircraft below thefollowing altitudes: (c) Over other than congested areas. An altitude of 400feet above the surface, except over open water or sparselypopulatedareas. In those cases, the aircraft may not be operatedcloser than 400 feet to anyperson, vessel, vehicle, orstructure. FlightWink LLC operations will be conducted at 400 feet AGL or below in uncontrolled Class G and occasionally. E airspace. As sUAS are inherently safet tha,n traditional aircraft**d~e** to their small size, light weight, battery operated vice fuel and no human onboard; FlightWink LLC will not operate within 250 feet to any improved roads, vehicles persons or structures (other than those being inspected as part ofthe flight

· operation). In addition, objects/hazards will be identified and geo-located prior to

flight.
NOTE: See Flight PlanningDocument 14 C.F.R. 91.121- 

### Altimeter Settings:

. );> States: Each person operating an aircraft shall maintain the cruising altitude orflight level of that aircraft, as the case maybe, byreference to an altimeter that isset, when operating

... SUAS are equipped with Global Positioning System (GPS), which provide altitude and geo-location data to the operator. Due to this fact, an exemption is required for this system to be utilized in flight. GPS's are precise within a few feet and therefore meet a safety level equal to if_not higher than regulatory guidance.
As described in the emergency procedures section, in the event the air vehicle losses GPS signal, automated landing will immediately commence. The flight plan is built in such a way that hazards are identified prior to launch and an immediate landing within the flight plan will ensure all hazards are avoided.

---------**-~----** ---

### •

• NOTE: The FAA hasrecentlysetprecedenceto this regulation within likegivenparameters and an exemptionshouldbeapprovedon this basis. See exemption approvals for Blue Chip, AstraeusAerial, AerialMOB, HeliVideo Productions, RCPro Productions, SnaprollMedia, andPictorvision. · 

### 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions:**~** States: No person may begin aflight in ·an airplane under VFR conditions unless (considering

. wind and forecast weather conditions) there is enoughfuel tofly to thefirst point ofintended landing and, assuming normal cruising speed- (1) During the day, to fly after that for atleast30 minutes; This regulation is written based on the capabilities of

# atraditional aircraft which have flight times ofseveral hours or greater. Since our crafts have flight times ofonly an hour. or less, this regulation would**effectiv~ly** deny the ability of the air vehicle to oper_ate. Using our Cessna 172 as an example, approximately 8% remaining fuel is required to meet the 30-minute flight time. To meet this regulation's intent, FlightWink LLC will operate its air vehjcles to no less than 10% remaining battery power to ensure safe landing and retrieval. This 10% buffer is greater than the Cessna 172. Our ability to quickly and safely land our crafts in non-traditional environments ensures atleast an equal level ofsafety.
NOTE: The FAA has setprecedent bypreviously issuing exemptions for§ 91.151(a): Exemption Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption approvals for Blue· Chip, AstraeusAerial, AerialMOB, HeliVideo Productions,

### RCPro Productions, Snapro/1 Media and Pictorvisionfor further justification of approval. · . 

### 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 inspectedas prescribed in subpart E of thispart andshall between required inspections, except asprovidedin paragraph (c) of this section, havediscrepancies repairedasprescribedinpart 43 of this chapter.**~** 9/.407(a)(l) States: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-(/) It has been approved for return to service byaperson authorizedunder§43.7 of this chapter.**~** 91.409(a)(2) States: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within thepreceding 12 calendar months, it has had-(2)An inspection

. for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. No inspectionperformed underparagraph (b) ofthis section may be substituted for any inspection required by this paragraph unless it is performed by a· person authorized to perform annual inspections andis enteredas an ''annual'' inspection in the requiredmaintenance records.**~** 91.417(a) & (b) States:( a) Except for workperformedin accordance with§§91.411 and91.413, each registered owner or operator shall keep thefollowing recordsfor theperiods specified in paragraph (b) of this section: (paragraphs I (i- iii), 2 (i- vi)); (b) The owner or operator shall retain the following records for theperiodsprescribed: (paragraphs I

- 3).Due to the fact our crafts at present do not have an airworthiness certificates, these regulations do not apply and therefore an exemption is required. Pre/Post and routine inspections·(not to exceed 50 flight hours) and maintenance will be conducted in accordance with the manufacturer's guidance as stated in the operations manual. In addition, to meet the intent ofthese regulations, FlightWink LLC, will maintain daily logs of pre and post flight inspections and have maintenance performed by certified technicians and/or the manufacturer themselves. In the event maintenance is required, certified technicians will verify the air vehicle is in flight readiness status prior to

.releasing to OIC for use in operation.s. · Unscheduled maintenance will be accomplished inthe event ofa mechanical or structural failure during flight. Upon completion of unscheduled maintenance, documentation will be provided to the OIC to sign offand verify that the air vehicle is once again ready for flight and accept the level ofrisk associated with returning the air vehicle to flight status. ·At no time will there be changes made to any craft that would impact the structurai integrity of the airframe without the. manufacturer making such changes and verifying the craft is airworthy. · All inspection and maintenance will be documented and maintained in-house. These actions will meet the intent ofthe regulation exemption is being requested and lead to an equivalent level ofsafety.

Public Interest: NOTE: The FAA has recently setprecedence to this regulation within likegivenparameters and an exemptionshouldbe approvedon this basis. See exemption approvals for Blue Chip, AstraeusAerial, AerialMOB, HeliVideo Productions, RCPro Productions, Snapro/1 Media and Pictorvision.

The public's best interest is achieved by the safe integration of UAS into the NAS. With the ongoing exemption process, the FAA has to identify those exemption requests with the public's best interest in mind and select the companies who· will be able to achieve this in a safe and responsible manner. Two ofthe main problems the public has with UAS are the fear ofwhat they will be used for and whether or not they are safe to fly within the same airspace as commercial airliners. FlightWink LLC is more than willing to help with public education and that starts with conducting operations within strict operating environmentS and then providing the results to the public to start to sway opinion in a positive light.
With the U A V experience this team has built over the past year and one half, the FAA will provide a great service to the American public by approving FlightWink LLC's exemption · request. FlightWink LLC will provide any additional information.requested and will diligently work with to make this approval a reality as it is in the best interests ofand safety ofthe public as directed by Congress.

### Privacy Concerns;
Another concern the. public has with the integration of UAS into the NAS is privacy and spying especially recently with the disclosure of the NSA's communication programs.
The media has also placed a negative light on UAS when it comes to privacy by showing how the military has used this technology to conduct combat operations through the use ofthe

. . visual and infrared sensors they carry. Fortunately with this matter, FlightWink LLC is well versed in the privacy and oversight concerns which are addressed by federal government regulations: 

### Executive Order 12333, DOD Directive 5240.1-R and AFI 14-104. Although the regulations do not apply to private c_ommercial entities, our knowledge and experience in working within these regulations will assist and ensure any and all privacy concerns will be minimal and immediately mitigated.
In addition, the most efficient and successful avenue to combat these concerns is to educate the public in how UAS technology will be used to exponentially improve all ofotir lives and place emphasize on how we should embrace the technology instead offearing it.
With this constantly in mind, FlightWink LLC will look at actions we can take to move forward with this endeavor and assist the FAA and all UAS employment companies as a whole to better public perception and create a cohesive environment we all can operate in safely.-



### FAA Collaboration:

FlightWink LLC is and will always be committed to the safe integration ofUAS into the NAS and will provide any requested information on its flight operations to the FAA to assist in the rules making process.
As stated in the operations· section, post flight logs will be required to be completed to produce monthly flight summaries which will include both positive and negative reporting placing emphasize on any issues which may arise during any segment ofthe operations.

### Federal Register:
Pursuant to 

### Section 333 of PL 112-95 commonly known as the "FAA Modernization and Reform Act of20 12" or "The Reform Act", FlightWink LLC hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the agriculture, oil and gas, aerial photography and wildlife preservation industries, within the United States National Airspace System (NAS); within Class G and occasionally·E airspace.
Rules from which FlightWink LLC 

### seeks exemption:



### • 14 C.P.R. Part 21·subpart H • 14C.F.R.§91.7(a) • 14 C.P.R.§ 45.23(b) • 14 C.P.R. §.61.113 and61.133(a)(l)(i_i) • 14 C.P.R.§ 91. l(a) • 14 C.P.R.§ 91.103 • 14 C.P.R.§ 91.109(a)- • 14 C.P.R.§ 91.119 • 14 

### C.F.R. § 91.121 • 14 C.F.R. § 91.151(a) • 14 C.P.R.§91.405(a) • 14 c_.FR. §**9~.407(a)(1)** 

### • 14 C.P.R.§ 91.409(a)(2) • 14 C.P.R.§ 91.417(a) & 

### (b) Throughout this exemption request, FlightWink LLC has shown how our expertise and knowledge witJ:l UAS safety and technology will ensure the public's best interest is always strictly adhered to. We wi11 assist the FAA with their charge to 

### "safo/y accelerate the integration of civil unmannedaircraft systems into the national airspace system" as directed

·by**Cong~ess.**

We have also shown how the approval ofour request will meet and exceed the FAA's requirement for. 

### "at least an equivalent/eve/of safoty" from the regulations we seek exemption.
At each level through process refinement, FlightWink LLC, will.capture and document the best practices to develop proven tactics, techniques, and procedures for each and every UAS operation

..

. . When it comes to· the public and what is in their best interest, yo·u will be hard pressed to find a tearri more qualified for an exemption under Section 333 than FlightWink LLC. 

### It will be a great service to the country and in ·the 

### ''public's best interest" to include our team in the UAS integration endeavor.')_/.;,C()(X)-·UNMANNEDSAFETYINSTITUTEtMVISUALLINEOFSIGI-ITDeWittM.HarknessJr.Nossuccessjidlycompletedt11/andIshr.1rbybytheUmnal'med.lnstllute'1'MasaJ'llsualOpera/or'I'Monthisthe2'"1dayof.lr:muttry201.5.m/c,.MlrotPresidentUnmtm1wdSo.fotylnstllute'I'MI$..00.,432S8-,-::;:--::_;··-;.;1r./.i,'!!\\·-t\I'.:,:,;;fI'I,\'f!·•:lI·,·ril,I1.-i.'.·.,·ii\I..<I'·h•.