Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR 

EXEMPTION OF: NEEDMORE TOWERS, INC. 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 

OF TITLE 14 OF THE CODE OF FEDERAL REGULATION 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) 

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF 

THE DJI INNOVATIONS SPREADING WINGS S1000+ UNMANNED AIRCRAFT 

SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

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Submitted on June 8, 2015 

MarkA. Ekse 

Hagen, Wilka & Archer, LLP 

Attorneys for Petitioner 
Page 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTERESTS OF PETITIONER 4 

BACKGROUND 5 

BASIS FOR PETITION 6 

NAME AND ADDRESS OF PETITIONER 8 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NEEDMORE 

TOWERS, INC. SEEKS EXEMPTION 9 

THE EXTENT OF RELIEF NEEDMORE TOWERS, INC. SEEKS AND THE 

REASON NEEDMORE TOWERS, INC. SEEKS THE RELIEF 13 

SPECIFIC SECTIONS OF 14 C.F.R. WHICH THE FAA HAS PREVIOUSLY 17 

DETERMINED RELIEF/EXEMPTION IS NOT NECESSARY 

THE REASONS WHY GRANTING NEEDMORE TOWERS, INC.'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST 20 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY 23 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 38 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT NEEDMORE TOWERS, INC.'S REQUEST 39 

CONCLUSION 39 

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ATO 

AV 

C.F.R. 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

vo 

VTOL 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Visual Observer 

Vertical Takeoff and Landing 

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(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will 

permit NEEDMORE TOWERS, INC. to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of capturing still imagery, video acquisition and digital 3D data 

capture (hereinafter referred to as "aerial data acquisition"). 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Needmore Towers, Inc. (hereinafter referred to as "NTI") is a tower construction and 

inspection firm, incorporated in 2011 to meet the highly specialized needs of the 

communication industry. 

NTI' s long record of technical achievements is enhanced by their reputation for 

effective management and personal service. NTI's clients benefit from the resources of an 

industry recognized organization while receiving personal service and experienced 

communication tower audit expertise. NTI continues to looks for new technology that will 

enhance the quality of service, improve the data collected from such audits, and reduce the 

risk associated with communications tower audits. 

Needmore Towers, Inc. has recently acquired a DJI Innovations Spreading Wings 

S 1 000+ unmanned aircraft system (hereinafter "S 1 000+"). NTI has historically used human 

surveyors to assess communication towers and equipment. With the advent of unmanned 

systems (drones) in recent years, NTI has found great value in the services provided, 

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traditional manned aerial photography. As set forth in this Petition, Needmore Towers, 

Inc. seeks to commercially operate its S 1 000+ over certain areas of the United States 

for the purpose of capturing aerial imagery, video acquisition and 3D data collection. 

BACKGROUND 

Unmanned Aircraft System: DJI Innovations Spreading Wings S 1 000+ 

Needmore Towers, Inc. seeks an exemption to operate the DJI Innovations 

Spreading Wings S 1 000+ multi-rotor rotorcraft for compensation or hire within the 

NAS. The S1000+ is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA). 

The S 1 000+ U A has a maximum gross take-off weight of approximately 25 pounds 

[Typical Operating Payload: S1000+ (9.7LB) + 21,000mAh 6S Battery (5.3 LB) + 

Canon 5D Mark iii camera (1.9 LB) + Canon CA2428ISEF Lens (0.6LB) + Zenmuse 

Z15 Gimbal (3.4LB) + Flight Electronics (1 LB)] while having a diameter of 41.1 

inches, height of20 inches, a maximum speed of60 mph (52.14 knots) and a wind 

tolerance of 25 mph. The S 1 000+ U A is equipped with eight high strength performance 

plastic propellers, each of which is driven by a 500w brushless electric motor and 

40amp Electronic Speed Control (ESC) unit. The S 1 000+ is powered by a single 6S 

(22.2V) 40C 21 ,OOOmah Lithium Polymer battery. 

Flight times range between 13 minutes and 25 minutes depending on payloads. 

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BASIS FOR PETITION 

Petitioner, NEEDMORE TOWERS, INC., by and through undersigned counsel, 

pursuant to the provisions of the Federal Aviation Regulations (14 C.P.R. § 11.61) and 

the FAA Modernization and Reform Act of2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to operate the S 1 000+ in 

the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, NTI' s operation of the S 1 000+ meets the 

conditions of Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F .R. Part 21, Subpart H. 

Accordingly, NTI requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

for maintenance that only apply to aircraft with an airworthiness certificate. 

NTI submits that the requested relief is proper since an equivalent level of safety 

will be ensured. NTI will use its authorized technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the manufacturer's maintenance manual. Furthermore, NTI will 

document and maintain all maintenance records for the S 1 000+ U A. 

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current FAA airman medical certificate or a valid U.S. driver's license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government, and who has completed UAS training and currency requirements, to 

conduct the proposed UAS flight operations. NTI submits that the conditions and 

limitations set forth herein will ensure the safety of the NAS, as well as the safety of 

persons or property on the ground. 

NTI seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, 

because the S 1 000+ does not require an airworthiness certificate in accordance with 14 

C.F .R. Part 21, Subpart H. As such, NTI submits that it will ensure that the S 1 000+ is 

in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the S 1 000+ Flight Manual, and that the aircraft is in a condition for 

safe flight. 

NTI also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the S 1 000+ UA will not have a typical 

barometric altimeter onboard. However, altitude, azimuth, pitch, yaw, heading and 

speed information of the S1000+ UA will be provided to the PIC via the onboard On-Screen Display (OSD) module and A2 Global Positioning System 

(GPS) which transmits real-time flight information via a A VL58 DJI - 5.8Ghz 

Video Transmitter directly to the PIC's First Person View (FPV) video monitor 

located at the Ground Control Station (GCS) for active monitoring of flight 

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entitled Fuel Requirements for Flight in VFR Conditions. NTI submits that safety will 

not be affected by terminating flights of the battery powered SIOOO+ UA after 20 

minutes of continuous flight, which would allow for five minutes of battery power 

remammg. 

In accordance with 14 C.F.R. § 11.81, NTI provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner is: 

Needmore Towers, Inc. 

4400 West 31st Street 

Yankton, SD 57078-

6810 

The point of contact for this Petition and specific contact information is as follows: 

Eric Taylor 

Needmore Towers, Inc. 

4400 West 31st Street 

Yankton, SD 57078-

6810 

Tel: (605) 665-75321 

Email: eric.t@needmoretowers.com 

Or 

Mark A. Ekse 

Hagen, Wilka & Archer, LLP 

600 S. Main Avenue, Suite 102 

Sioux Falls, SD 57104 

Tel: (605) 334-0005 

Email: mark@hwalaw.com 

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subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as PIC 

of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an 

aircraft in connection with any business or employment if-

(1) The flight is only incidental to that business or employment; 

and 

(2) The aircraft does not carry passengers or property for 

compensation or hire. 

2. NTI Seeks Exemption From The Requirements Of Section 61.315 (a), 

(b), and (c) 

Section 61.315, entitled What are the Privileges and Limits of my Sport Pilot 

Certificate?, subsections (a), (b), and (c) prescribe the following in relevant part: 

(a) If you hold a sport pilot certificate you may act as pilot in command of 

a light-sport aircraft, except as specified in paragraph (c) of this section. 

(b) You may share the operating expenses of a flight with a passenger, 

provided the expenses involve only fuel, oil, airport expenses, or aircraft rental 

fees. You must pay at least half the operating expenses of the flight. 

(c) You may not act as pilot in command of a light-sport aircraft: 

(1) that is carrying a passenger or property for compensation or 

hire. 

(2) for compensation or hire. 

(3) in furtherance of a business. 

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Section 91.121, entitled Altimeter Settings, subsection (a), states the following, in part: 

(a) 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--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station 

along the route and within 1 00 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in 

paragraph (a)(l)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, 

the elevation of the departure airport or an appropriate altimeter setting available 

before departure; 

5. NTI Seeks Exemption From The Requirements Of Section 91.15l(b). 

Section 91.151, entitled Fuel Requirements for Flight in VFR Conditions, subsection (b), 

states the following: 

(a) No person may begin a flight in a rotorcraft 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, to 

fly after that for at least 15 minutes. 

6. NTI Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance Required, subsection (a), states the following: 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 

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(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 this chapter[.] 

8. NTI Seeks Exemption From The Requirements Of Sections 

91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(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 --

(1) An annual inspection in accordance with part 43 of this 

chapter and has been approved for return to service by a person authorized by § 

43.7 ofthis chapter; or 

(2) An inspection for the issuance of an airworthiness certificate 

in accordance with part 21 of this chapter. 

9. NTI Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

Section 91.417, entitled Maintenance Records, subsections (a) and (b), state the following: 

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: 

(1) Records ofthe maintenance, preventive maintenance, and 

alteration and records of the 1 00-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

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each propeller, and each rotor. 

(ii) The current status of life-limited parts of each 

airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on 

the aircraft which are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including 

the time since the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. If the AD or 

safety directive involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this 

chapter for each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the 

periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall 

be retained until the work is repeated or superseded by other work or for 1 year 

after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall 

be retained and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator 

under § 4 3 .11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

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holding a private pilot certificate and a third-class airman medical certificate, and who 

has completed training and currency requirements, to conduct the proposed UAS flight 

operations for compensation. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if- (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, NTI submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the S1000+ UA unless that PIC 

has demonstrated, through the UAS training and currency requirements, that the PIC is 

able to safely operate the S 1 000+ in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures. 

Further, NTI submits that all flights of the S1000+, conducted by the PIC pursuant 

to the grant of this Petition - (1) will be incidental to NTI's business; and (2) will not 

carry passengers or property for compensation or hire. 

13 
license, and who has completed training and currency requirements, to conduct the 

proposed UAS flight operations for compensation. 

This relief is requested since the limitations set forth in Section 61.315 (a), (b), 

and (c) state that the holder of a sport pilot certificate (a) may act as pilot in command of 

a light-sport aircraft, except as specified in paragraph (c) of this section; (b) may share 

the operating expenses of a flight with a passenger, provided the expenses involve only 

fuel, oil, airport expenses, or aircraft rental fees. You must pay at least half the operating 

expenses of the flight; and (c) may not act as pilot in command of a light-sport aircraft: 

( 1) That is carrying a passenger or property for 

compensation or hire. 

(2) For compensation or hire. 

(3) In furtherance of a business. 

As set forth more fully below, NTI submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the S1000+ UA unless that 

PIC has demonstrated, through the UAS training and currency requirements, that the 

PIC is able to safely operate the S 1 000+ in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures. 

14 
Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to 

the extent required to allow NTI to determine that the S 1 000+ is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the 

S 1 000+ Flight Manual, and that the aircraft is in a condition for safe flight. 

NTI seeks the requested reliefbecause the S1000+ does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

NTI will ensure that the S 1 000+ is in an airworthy condition based upon its compliance 

with the operating documents (i.e., the S 1 000+ Pilot Operating Handbook) prior to every 

flight, and as stated in the conditions and limitations below. 

4. Extent of Relief NTI Seeks And The Reason NTI Seeks Relief From 

Section 91.121. 

Relief from Section 91.121 entitled Altimeter settings, may be required to allow 

flight operations of the NTI, which utilizes GPS equipment and a radio communications 

telemetry data link to downlink altitude information to the PIC from the UA to the GCS. 

As more fully set forth below, safety will be maintained as a result ofthe S1000+ UA's 

altitude readout via GPS equipment, and NTI's operation ofthe SIOOO+ UA within 

visual line of sight, at or below 500 feet AGL. 

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rules (VFR) conditions, to continue for a total duration of 20 minutes or until the 

indicated battery level reaches 20% remaining, whichever occurs sooner, which will 

ensure that the UA will land with five minutes of battery power remaining. NTI seeks 

the requested relief because without an exemption from Section 91.151 (b), the flight 

time duration ofthe battery powered S1000+ UA will severely constrain the practicality 

of any aerial acquisition and flight operations that NTI proposes to conduct pursuant to 

this Petition. 

Significantly, as set forth below, the technical specifications of the S 1 000+, 

the S 1 000+ Flight Manual, and NTI' s proposed operating limitations, ensure that 

NTI will safely operate the battery powered S 1 000+ UA during daylight hours in 

VFR conditions, for a total flight duration of 20 minutes or until the indicated 

battery level reaches 20% remaining, whichever occurs sooner, landing with five 

minutes of battery power remaining. 

6. Extent Of Relief NTI Seeks And The Reason NTI Seeks Relief From 

Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) 

& (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, NTI requests relief from these 

Sections because the S 1 000+ does not require an airworthiness certificate. As set forth 

more fully below, the S1000+ meets the conditions of Section 333 ofthe FMRA for 

16 
Furthermore, NTI will document and maintain all maintenance records for the S 1 000+. 

D. Specific sections of 14 C.F.R. which the FAA has previously determined 

relief/exemption is not necessary. 

1. 14 C.F.R. 45.29: Size ofMarks 

The FAA has previously determined that relief from this section 1s not 

necessary, so long as the UAS in question is registered with the FAA and markings 

are as large as practicably possible. Exemption No. 11136 at 13. NTI requests the 

FAA make the same determination for this petition. 

Alternatively, NTI requests an exemption from 14 C.F.R. 45.27. This part 

provides, inter alia, at subpart (3) that the registration marks for rotorcraft must be at 

least 12 inches high. The UAS, due to its small size, does not have any surface area 

large enough to display marks anywhere near 12 inches high. 

Equivalent level of safety: NTI will affix its registration numbers as 

large as practicably possible on its "arms" once it obtains N-Numbers for its 

UASs. This exemption provides an equivalent level of safety to 14 C.F.R. 45.29 

because the UAS will be registered with the FAA Aircraft Registration Branch. In the 

event of incident, the UAS will be traceable to NTI. 

2. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard 

requirements. 

The FAA previously stated that exemption to this section was not necessary. 

Exhibit D at 19. NTI requests the same detemlination to be made for this Petition. 

17 
approved manual material, markings, and placards, or any combination thereof." 

First, there does not currently exist a method of approving manuals for UAS. 

Second, given the size and configuration of the UAS, there is no space to carry such a 

flight manual on the aircraft. In addition, carrying the manual on the aircraft would be 

pointless, since there is no pilot or other person on board who could read or use it. On 

August 8, 2014, the FAA issued a memorandum entitled "Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft's control 

station." This document stated that in the case of AUS, "maintaining these 

documents at the pilot's control station would meet the intent of the rule as the pilot 

would be able to produce the documents for his or her own information or to an FAA 

inspector." Exhibit E. 

Equivalent level of safetv: NTI will keep its flight manual at the ground 

station, where both the PIC and VO can access it. An equivalent level of safety to 

14 C.F .R. 91. 9(b )(2) is provided because the intent of this rule -the pilot having access 

to this material during flight -is met. 

3. 14 C.F.R. 91.9( c): Civil aircraft flight manual, marking, and placard 

requirements. 

The FAA has previously determined that relief from this section 1s not 

necessary. Exemption No. 11136 at 16. NTI requests the FAA to make the same 

determination about its petition. 

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and the UASs, due to its small size, does not have room to contain fireproof placard 

or to display aircraft marks in a conventional size. However, once NTI obtains its NNumbers, it will place the number on the "arms" of the aircraft as large as practicably 

possible. 

Equivalent level of safety: NTI will obtain N-Numbers from the FAA 

Registration Office and affix it to the "arms" of the aircraft as large as practicably 

possible. An equivalent level of safety to 14 C.F.R. 91.9(c) is met because the UASs 

will be registered with the FAA and identifiable in the event of an incident. 

4. 14 C.F.R. 91.109: Flight instruction; Simulated instrument flight and 

certain flight tests. 

The FAA has previously stated that relief from this section was unnecessary 

when there are no training scenarios in which a dual set of controls would be utilized or 

required. Exhibit D at 20. AIR requests the same determination to be made here. 

Alternatively, NTI requests an exemption from 14 C.F.R. 91.109. Section 14 

C.F .R. 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. Remotely piloted aircraft, including the DJI S 1 000+ here, are designed 

and constructed without dual controls. Flight control will be accomplished through the 

use of a control box that conmlunicates with the aircraft via a radio transmitter. 

Equivalent level of safety: The requested exemption from 14 C.F .R. 91.1 09 will 

provide an equivalent level of safety to this section because AIR's training will not 

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safely, efficiently, and economically perform aerial data acquisition commercially, in 

support of DoD, federal, state, local government and private entities in relation, but not 

limited to communications, engineering, environmental, energy, technology, planning, 

transportation, and land development services. Additionally, use of the S 1 000+ will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits ofNTI's proposed operation ofthe S1000+ will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Aerial Data Acquisition. 

NTI submits this Petition to commercially operate the S 1 000+ and perform aerial 

data acquisition throughout the United States, in support of DoD, federal, state, local 

government and private entities in relation, but not limited to communications, 

engineering, environmental, energy, technology, planning, transportation, and land 

development services. The S 1 000+ will provide safe, efficient, and economical aerial 

data acquisition to capture project specific imagery for project efforts and for use in 

pursuits. 

The specific operations that NTI will perform with the S 1 000+ demonstrates how 

the requested exemption will directly benefit the above-referenced industries and the 

public. In all industries referenced, the aerial data acquisition performed by the S 1 000+ 

will be used to acquire still images, video and other various forms of advanced sensing 

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