UNITED STATES OF AMERICA DEPARTMENT
OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON,
DC Regulatory Docket No. _____

_ INTHEMATTER OFTHE PETITION FOR EXEMPTION OF: NEEDMORE TOWERS, INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE14 OFTHE 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 THEDJI INNOVATIONS SPREADING WINGS S1000+ UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THEFAA MODERNIZATION
AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 1 Submitted onJune 8, 2015 MarkA

.Ekse Hagen,Wilka
& Archer

,LLP Attorneys for PetitionerTABLE OF CONTENTS

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 2AGL AOI ATC 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 GLOSSARY OF ABBREVIATIONS Above Ground Level Area of Interest Air Traffic Control 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 3SUMMARY NEEDMORE TOWERS, INC. seeks exemption from the requirements

of14 C.F.R §§ 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), to operateanUnmanned Aircraft System pursuant
toSection 333 ofthe FAA Modernization
and Reform Act of2012 (FMRA). This exemption will permit NEEDMORE TOWERS, INC. to operateanUnmanned Aircraft System (UAS) for the commercial purposeof capturing still imagery, video acquisition and digital 3D data capture (hereinafter referred
toas"aerial data acquisition"). INTRODUCTION AND INTERESTS OF THE PETITIONER Needmore Towers,Inc. (hereinafter referred
toas"NTI")
is atowerconstruction and inspection firm

,incorporated

in 2011 tomeetthe highly specialized needs of the communication industry

. NTI'

slong record of technical achievements

is enhanced by their reputation for effective managementand personal service. NTI's clients benefit from the resourcesof an industry recognized organization while receiving personal service and experienced communication toweraudit expertise. NTIcontinues
tolooks for new technology that will enhance the quality of service, improve the data collected from such audits, and reduce the risk associated with communications toweraudits. Needmore Towers,Inc.has recently acquired

aDJI Innovations Spreading Wings S 1 000+ unmanned aircraft system (hereinafter
"S1 000+"). NTIhas historically used human surveyors
toassesscommunication towersand equipment. With the advent of unmanned systems (drones)
in recent years

,NTIhas found greatvalue in the services provided, 4efficiencies gained, and increase
in data availability presented through the useof aerial data acquisition. The useofUAS technology has allowed flight in waysneverbefore capable with conventional fixed wing and rotary vehicles, providing different project perspectives and bridging the gapbetween traditional land-based photography and traditional manned aerial photography.
Assetforthin this Petition, Needmore Towers, Inc.seeks to commercially operateits S1 000+ overcertain areasof the United States for the purposeof 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 operatethe DJI Innovations Spreading Wings S 1 000+ multi-rotor rotorcraft for compensation

orhire within the NAS. The S1000+

is avertical takeoff and landing (VTOL) Unmanned Aircraft (UA)

. The S1 000+ UAhas amaximum grosstake-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

adiameter of 41.1 inches, height of20 inches,

amaximum speed of60 mph (52.14 knots) and awind tolerance of 25 mph. The S 1 000+ UAis equipped with eight high strength performance plastic propellers, each of which
is driven by a500w brushless electric motorand 40amp Electronic Speed Control (ESC) unit. The S1 000+ is powered by asingle 6S (22.2V) 40C21 ,OOOmah Lithium Polymer battery. Flight times rangebetween
13 minutes and 25 minutes depending on payloads. 5The S1 000+ that will be operated by NTIwill be registered

in accordance with 49 U.S.C. 44103, Registration
of Aircraft,
aswell as14 C.F.R Part 47, Aircraft Registration, and marked in accordance with14 C.P.R. Part 45, Identification and Registration Marking. BASIS FOR PETITION Petitioner, NEEDMORE TOWERS, INC., by and through undersigned counsel, pursuant
tothe 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 operatethe S1 000+in the National Airspace System (NAS), and for an exemption from the requirements

of14 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 areaassociated with the unmanned aircraft and its operation, NTI'

soperation of the S1 000+ meetsthe conditions
of Section 333 and therefore, will not require anairworthiness certificate
in accordance with 14 C.F .R.Part 21, Subpart H. Accordingly, NTI requestsrelief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(l)

& (a)(2), and 91.417(a)

& (b), asthese sections setforth requirements for maintenance that only apply toaircraft with anairworthiness certificate. NTIsubmits that the requested relief is propersince an equivalent level of safety will be ensured. NTIwill useits authorized technicians

to perform maintenance, alterations,

or preventive maintenance
onthe UAS using the methods, techniques, and practices prescribed

in the manufacturer's maintenance manual. Furthermore, NTIwill document and maintain all maintenance records for the S1 000+ UA. 6Relief from certain requirements

of Section 61.113(a) and (b), entitled Private Pilot Privileges and Limitations:Pilot in Command,

is requested by NTItothe extent necessary

toallow

aPilotin Command (PIC) holding either anairline transport, commercial, private, recreational,

orsport pilot certificate. The PIC mustalso hold
a currentFAA airman medical certificate
oravalid U.S. driver's license issued by astate, the District of Columbia, Puerto Rico,

aterritory,

a possession,
orthe Federal government,and who has completed UAS training and currency requirements,

to conduct the proposed UAS flight operations. NTIsubmits that the conditions and limitations setforth herein will ensurethe safety of the NAS, aswell asthe safety of personsor propertyonthe ground. NTIseeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, because the S 1 000+ does not require anairworthiness certificate
in accordance with14 C.F .R.Part 21, Subpart H.As such, NTIsubmits that it will ensurethat the S1 000+ is in an airworthy condition, prior to every flight, by determining that the UAS isin compliance with the S1 000+ Flight Manual, and that the aircraft
isin acondition for safe flight. NTIalso seeks an exemption from the requirements

of Section 91.121, entitled Altimeter Settings,
asthe S 1 000+ UA will nothave

atypical barometric altimeter onboard. However, altitude, azimuth, pitch, yaw, heading and speed information
of the S1000+ UA will be provided
tothe PIC via the onboard On-Screen Display (OSD) module and A2 Global Positioning System (GPS) which transmits real-time flight information via aA VL58 DJI

-5.8Ghz Video Transmitter directly
tothe PIC's First Person View (FPV) video monitor located
atthe Ground Control Station (GCS) for active monitoring
of flight 7operations. This altitude information, combined with NTI's operation
of the S1 000+ UA within visual line of sight, atorbelow 500 feet AGL, will ensure

a level of safety equivalent

toSection 91.121. Additionally, NTIseeks an exemption from the requirements

of Section 91.151(b), entitled Fuel Requirements for Flight inVFR Conditions. NTIsubmits that safety will notbe 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. Inaccordance with14 C.F.R.

§ 11.81, NTI provides the following information in supportof its petition for exemption: A. Name And Address Of The Petitioner. The nameand address of the Petitioner
is: Needmore Towers,Inc. 4400 West31st Street Yankton, SD 57078- 6810 The point of contactfor this Petition and specific contactinformation

is asfollows: Eric Taylor Needmore Towers,Inc. 4400 West31st 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

8B. The Specific Sections of 14 C.F.R. From Which Needmore Towers, Inc. Seeks Exemption. 1. NTI Seeks Exemption From The Requirements
Of Section 61.113(a) And (b). Section 61.113, entitled Private Pilot Privileges and Limitations: Pilot in Command, 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. 93. NTI Seeks Exemption From The Requirements
Of Section 91.7(a). Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), statesthe following: (a) No person may operate

acivil aircraft unless
it isin an airworthy condition. 4. NTI Seeks Exemption From The Requirements
Of Section 91.121. Section 91.121, entitled Altimeter Settings, subsection (a), statesthe following,
in part: (a) Each person operating
anaircraft shall maintain the cruising altitude orflight level of that aircraft,
asthe casemaybe, by reference

toanaltimeter that is set,when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of astation along the routeand within

1 00 nautical miles of the aircraft; (ii) If there is nostation within the area prescribed

in paragraph (a)(l)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) Inthe caseof anaircraft not equipped with
aradio, the elevation of the departure airport oran 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 inVFR Conditions, subsection (b), statesthe following: (a) No person maybegin

aflight in arotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point of intended landing and, assuming normal cruising speed, to fly after that for atleast 15 minutes. 6. NTI Seeks Exemption From The Requirement
Of Section 91.405(a). Section 91.405, entitled Maintenance Required, subsection (a), statesthe following: Each owneroroperatorof anaircraft- (a) Shall have that aircraft inspected

as prescribed

in subpart
Eof this part and shall between required inspections, except

as provided
in paragraph (c) of 10this section, have discrepancies repaired
as prescribed

in part43of this chapter[.] 7. NTI Seeks Exemption From The Requirements
Of Section 91.407(a)(l). Section 91.407, entitled Operation after Maintenance

,Preventive Maintenance

, Rebuilding,
orAlteration, subsection (a)(1), statesthe following: (a) No person may operate anyaircraft that has undergone maintenance, preventive maintenance, rebuilding,
oralteration unless-- (1)

It has been approved for returntoservice by aperson 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), statesthe following: (a) Exceptasprovided
in paragraph (c)of this section, noperson may operateanaircraft unless, within the preceding
12 calendar months,

it has had-- (1) An annual inspection

in accordance with part43 of this chapter and has been approved for returntoservice by apersonauthorized
by § 43.7 ofthis chapter; or (2)An inspection for the issuance of anairworthiness certificate in accordance with part21of 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), statethe following: Exceptfor work performed

in accordance with§§ 91.411 and 91.413, each registered owneroroperatorshall 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 the1 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 anaircraft. The records must include--

(i) A description (or reference
todata acceptable

tothe Administrator)

of the work performed; and 11(ii) The date of completion
of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for returntoservice. (2) Records containing the following information: (i) The total timein service of the airframe, each engine, each propeller, and each rotor. (ii) The currentstatusof life-limited partsof each airframe, engine, propeller, rotor,and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required
tobe overhauled
onaspecified time basis. (iv) The current inspection statusof the aircraft, including the time since the last inspection required by the inspection programunder which the aircraft and its appliances aremaintained. (v) The currentstatusof applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, theADorsafety directive number and revision date.If theADor safety directive involves recurring action, the time and date when the nextaction
is required.

(vi) Copies of the forms prescribed
by § 43.9(d) of this chapter for each major alteration

tothe airframe and currently installed engines, rotors, propellers, and appliances. (b) The owneroroperatorshall 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 orfor1 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
atthe time the aircraft
is sold. (3)Alist of defects furnished
toa registered owneroroperator under § 4 3 .11of this chapter shall be retained until the defects arerepaired and the aircraft
is approved for returntoservice. 12C. The Extent Of Relief NTI Seeks And The Reason NTI Seeks The Relief. 1. Extent of Relief NTI Seeks And The Reason NTI Seeks Relief From Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Private Pilot Privileges and Limitations: Pilot in Command,

is requested
to the extent necessary
to allow

a PIC 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. 132. Extentof Relief NTISeeks And The ReasonNTISeeks Relief From Section 61.113(a) And (b). Relief from Section 61.315 entitled What arethe Privileges and Limits of my Sports Pilot Certificate,

is requested
tothe extent necessary
toallow

aPIC holding

a sport pilot certificate and either

athird-class airman medical certificate
orvalid driver's license, and who has completed training and currency requirements,

toconduct the proposed UAS flight operations for compensation. This relief is requested since the limitations setforthin Section 61.315 (a), (b), and (c) statethat the holder of asport pilot certificate (a) mayactaspilotin command
of a light-sport aircraft, exceptas specified
in paragraph (c)of this section; (b) mayshare the operating expensesof aflight with
a passenger, provided the expensesinvolve only fuel, oil, airport expenses,
oraircraft rental fees. Youmust payatleast half the operating expensesof the flight; and (c) maynotactaspilotin command of a light-sport aircraft: ( 1) That is carrying

a passenger
or propertyfor compensation

orhire. (2) For compensation

orhire. (3)Infurtherance
of abusiness. Assetforth morefully below, NTIsubmits that an equivalent level of safety will be maintained because noPIC will be allowed
to operatethe S1000+ UA unless that PIC has demonstrated, through the UAS training and currency requirements, that the PICis able to safely operatethe S1 000+in amannerconsistent with the operations specifications

asdescribed
in this exemption, including evasive and emergency maneuvers,

aswell as maintaining appropriate distances from people, vessels, vehicles and structures.

14Further, 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. 3. Extent of Relief NTI Seeks And The Reason NTI Seeks Relief From 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. 155. ExtentOf Relief NTISeeks And The ReasonNTISeeks Relief From Section 91.15l(b

). Relief from Section 91.151 (b) entitled Fuel requirements for Flight inVFR Conditions,

is requested
tothe extent required
toallow flights of the battery S1000+ UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR) conditions,

tocontinue for atotal duration of 20 minutes oruntil the indicated battery level reaches 20% remaining, whichever occurssooner,which will ensurethat the UA will land with five minutes of battery power remaining. NTIseeks 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 anyaerial acquisition and flight operations that NTI proposes
toconduct pursuant
to this Petition. Significantly,

assetforth below, the technical specifications

of the S1 000+, the S1 000+ Flight Manual, and NTI'

sproposed operating limitations, ensurethat NTIwill safely operatethe battery powered

S1 000+ UA during daylight hours in VFR conditions,
for
atotal flight duration of 20 minutes oruntil the indicated battery level reaches 20% remaining, whichever occurssooner, landing with five minutes of battery power remaining. 6.ExtentOf Relief NTISeeks And The ReasonNTISeeks 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 toaircraft with anairworthiness certificate, NTI requestsrelief from these Sections because the S1 000+ does not require anairworthiness certificate. Assetforth more fully below, the S1000+ meetsthe conditions
of Section 333 ofthe FMRA for 16operation without an airworthiness certificate. Accordingly, NTI will use 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+. 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. 17Alternatively, NTI requestsan exemption from 14 C.F.R. 91.9(b)(2). This part provides: "(b) No person may operate

a U.S.-registered civil aircraft

...(2) Forwhich anAirplane
orRotorcraft Flight Manual

is not required by §21.5 of this chapter, unless there is available
in the aircraft

acurrent approved Airplane
orRotorcraft Flight Manual

, approved manual material, markings, and placards,
oranycombination thereof

." First, there does not currently exist

amethod of approving manuals for UAS. Second, given the size and configuration

of the UAS, there is nospaceto carrysuch
a flight manual onthe aircraft.
In addition, carrying the manual onthe aircraft would be pointless, since there is nopilot orother persononboard who could read oruseit. On August

8, 2014, the FAA issued

amemorandum entitled "Interpretation regarding whether certain required documents maybe kept atanunmanned aircraft's control station." This document stated that in the caseof AUS, "maintaining these documents

atthe pilot's control station would meetthe intent of the rule asthe pilot would be able to produce the documents for his orher owninformation

ortoanFAA inspector." Exhibit E. Equivalent level of safetv: NTIwill keep its flight manual
atthe ground station, where both the PIC and VO canaccessit. 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 tothis 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

1snot necessary. Exemption No.11136 at16. NTI requeststhe FAA tomake the same determination about its petition.

18Alternatively, NTI requests
an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person may operate

a U.S.-registered civil aircraft unless that aircraft
is identified
in accordance with part45 of this chapter." As stated above, NTIwill obtain N-Numbers from the FAA Registration Office and the UASs, due toits small size, does nothave roomtocontain fireproof placard orto display aircraft marks in aconventional size. However, onceNTIobtains its NNumbers,

it will place the number onthe "arms" of the aircraft
aslarge as practicably possible. Equivalent level of safety: NTIwill obtain N-Numbers from the FAA Registration Office and affix
it tothe "arms" of the aircraft
aslarge as practicably possible. An equivalent level of safety to14 C.F.R. 91.9(c)

is metbecause the UASs will be registered with the FAA and identifiable

in the eventof anincident. 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 areno training scenarios
in which

adual setof controls would be utilized or required. Exhibit
Dat20.AIR requeststhe samedetermination

tobe made here. Alternatively, NTI requests
an exemption from 14 C.F.R. 91.109. Section
14 C.F .R. 91.109 provides that noperson may operate

acivil aircraft (except

amanned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Remotely piloted aircraft, including the DJIS 1 000+ here, are designed and constructed without dual controls. Flight control will be accomplished through the useof acontrol box that conmlunicates with the aircraft via aradio transmitter. Equivalent level of safety: The requested exemption from 14 C.F .R. 91.1 09 will provide an equivalent level of safety tothis section because AIR's training will not 19require dual controls. Additionally,
the DJI S 1 000+ IS a small UAS and will carry neither

a pilotnorpassengers. D. The Reasons Why Granting NTI's Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing NTI to 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 20