U. S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b) ; 14 CFR Part 21; 14 CFR 61.113 (a) & (b) ; 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b) ; 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the “Reform Act”) and 14 CFR Part 11, Virginia Drone Services (“Applicant”), an aerial photography, videography, and mapping firm, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of i ts Small Unmanned Aircraft Systems (''sUASs") for aerial imaging of secured and controlled sites, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As de tailed in this document and the attached Flight Operations Manual (the “Manual”), the requested exemption would permit Applicant to operate sUASs under controlled conditions in airspace that is limited, predetermined, and controlled as to access, and in

a manner that provides safety enhancements to the already established safety protocols allowed in the industry for rotary and fixed wing aircraft. Approval of this exemption would thereby enhance safety and fulfill the responsibilities of the Secretary of
Transportation (“FAA Administrator”) to "establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333 (c) of the Reform
Act.
1The name and address of the Applicant is:

Virginia Drone Services Chris Fox/CEO Phone: 808

- 333

- 6095 Email: vadroneservices@gmail.com Address: 3724 Wainfleet Dr Richmond Va, 23235 Regulations from which the exemption is requested:
14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)
14 CFR 91. 103
14 CFR 91.109
14 CFR 91.119
14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)
I. STATUTORY AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA aut hority to issue exemptions. This statutory authority includes exempting “civil aircraft,” as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Admin istrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption to be or is in the public interest.2

49 U.S.C. §44701(f), See also 49 USC §4471 l (a) ; 49 USC §44704; 14 CFR §91.203 (a) (l). Section 333 (b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace System (NAS) without creating either a hazard to the us er or the public or a threat to national security. In making this determination, the Secretary must consider: ● The sUAS's size, weight, speed, and operaonal capability; ● Whether the sUAS operates within the visual line of sight of the operator; and
● W hether the sUAS operates outside of highly populated areas and away from close proximity to airports. Reform Act §333 (a). If the Secretary determines that a sUAS "may operate safely in the national airspace system, the Secretary shall establish requiremen ts for the safe operation of such aircraft in the national airspace system." Id . §333 (c). Applicant’s sUASs are multi-rotor vehicles weighing 10 or fewer pounds including payload. They operate under normal conditions at a speed of no more than 30 knots

a nd have the capability to hover and move in the vertical and horizontal plane simultaneously. The sUASs will operate only in the pilot's visual line of sight at all times and will operate only within the sterile area described in the confidential DividedSky Flight Operations Manual, attached as Exhibit 1 (hereinafter "the Manual"). Such operations will insure that the sUASs will "not create a hazard to users of the national airspace system or the public." Reform Act § 333 (b). Given the small size of the sU ASs involved and the restricted and sterile environment within which they will operate, the Applicant’s application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA, by exemption, must allow commercial operations of sUASs to commence immediately. Also, due to the small size of the sUASs and the low altitudes and restricted areas in which Applicant’s sUASs will operate, approval of the application presents no national security issue.Given the clear direction in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, as amended, the strong equivalent level of safety surrounding the
3 proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemption is in the public interest. Accordingly, Applicant Virginia Drone Services, respectfully requests that the FAA grant the requested exemption without delay.
II. PUBLIC INTEREST This exemption application (the “Application ”) is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before complet ion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress' intent of allowing sUASs to operate with significant safety precautions in low risk environments. Additionally, sUASs could replace the use of helicopters and small aircraft that are currently being used to complete these aerial image acquisition tasks. The sUASs Applicant proposes to fly in this application are less than five pounds and carry no combustible material on board, as oppos ed to the much larger conventionally powered small fixed and rotary winged aircraft. Shifting to sUASs from helicopters presents a marked safety increase for the Applicant’s workers and the public. Lastly, sUASs reduce the environmental impact by dramatica lly decreasing the energy used for aerial imaging and data collection. Applicant’s sUASs use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier. III. EQUIVALENT LEVEL OF SAFETY Applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safe ty to operations under the current regulatory structure, because the proposed operations represent a safetyenhancement to the already safe protocols followed on construction sites and in

imaging and surveying operations conducted with helicopters and other conventional aircraft.
4 Applicant will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption: 1. The sUAS will weigh less than 30 pounds, incl uding payload. 2. Flights will be operated within visual line of sight of the pilot. 3. Maximum total flight time for each operational flight will be 30 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude no higher than 350 feet AGL and never exceeding 400 feet AGL. 5. Crew for each operation will consist of the sUAS pilot, who will ke ep the sUAS within his visual line of sight at all times, a camera operator, who will be responsible for all camera operations, and an observer/controller, who will manage the flight operations area. 6. The sUAS pilot will be trained in the dynamics of fli ght, flight operations, weather, instrumentation, GPS systems, human performance factors and safety procedures as detailed in the Virginia Drone ServicessUAS Pilot Certification Program as prescribed in the Manual. 7. The sUAS will only operate within a co nfined "Sterile Area" as defined in the Manual. The Manual also requires the establishment of a "Security Perimeter" for the flight operations area. 8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production act ivities. Attendance at this briefing of all personnel who will be performing duties within the boundaries of the safety perimeter will be mandatory. 9. All onsite personnel will consent to the sUAS flyover on site by waiver, and theobserver/controller will obtain additional verbal or written consent of all persons

who will be allowed within 100 feet of the flight operations area. 10.The pilot will have been trained in operation of sUASs generally and received up-to-date information on the particular sU AS to be operated as required by the Manual. 11.Written and/or oral permission from the relevant property holders will be obtained. 12.All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including lo cal law enforcement, fire, or other appropriate governmental agencies. 13.If the sUAS loses communications or loses its GPS signal, it will have capability to return to and land at a pre-determined location within the Security Perimeter.
5 14.The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.
IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR Part 21,Subpart H: Airworthiness Certificates 14 CFR §91.203(a)(l) Subpart H, entitled Airworthiness Certificates, establ ishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Applicant, an exemption from Part 21 Subpart H mee ts the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. Applicant’s small UAS will be operated at low speed in a controlled environment at least fiv e miles from an airport. An analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment, and under the conditions proposed, will be at least assafe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an

airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than ten (10) lbs. fully loaded, carries neither pilot nor passenger, carries no exp losive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Flight Operations Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is currently done on active construction sites. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with construction sites, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness cert ificates issued under 14 CFR Part 21, Subpart H.
6 Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two (2) lbs. 14 CFR 45.23(b): Marking of the Aircraft This regulation requires certain experimental, provisionally certificated aircraft or lightsport category airc raft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "lightsport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station. Even though the sUAS will have no airworthiness certificate , an exemption may be needed as the body of the sUAS will have no “entrance” to a “cabin, cockpit or pilot station” on which the word "Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word "Experimental" w ill be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided by having the sUAS marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the
sUAS will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and
10167A. 14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command
Se ctions 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the

a ircraft to have completed a sUAS flight training course of 80 hours before flying a sUAS (See the Manual for more details). Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with

co mmercial operations contemplated by Part 61 when drafted that allowing operations of the sUAS as requested with a pilot who has met the minimum requirements stated in the Manual exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).
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Se ction 61.133 (a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Applicant respectfully proposes that operator requirements should take into account the characteristics of the particu lar sUAS. All of the sUAS that Applicant’s pilots will fly have a high degree of pre programmed control and various built in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exempti on application. Applicant‘s sUASs have an all digital software platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced flysafe controls enable safe, reliable operation, as well as advanced netwo rkingcapabilities and system extensibility.

● Plan your flight or fly adhoc: The system can autonomously fly a programmed flight path or fly in manual mode. ● Smart ba eries and charger: Flight me and ba ery minutes are displayed at all times. The system will return home and land automatically if user configurable limits are reached. Flight safety is a priority, no matter the operating environment or project. All of Applicant’s sUASs offer superior safety over manned aircraft by removing the need fo r people to be on board in potentially dangerous situations. With multiple built-in safety features, these platform leads other sUAS with respect to safety. ● Intelligent fault handling: The system automacally detects potenal issues with configurable a utomated response behavior such as a return home and land
routine. ● Automac preflight checks: The system self calibrates all of its sensors and performs self tests prior to takeoff to check for errors. ● No fly zones: The system has the ability to set u p visual and GeoFence no fly

zones. ● Self monitoring: Monitoring ba ery levels, and other system and environmental conditions are automatically handled by the system.
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● Ba ery communicaon: Ba ery minutes and flight me are displayed at all mes. The system will return home and land automatically if user configurable limits are reached. ● Addional automated safety funcons and safety enhancing features of Applicant’s sUASs include the following: ○ Auto detecon of lost GPS warns the pilot and i nitiates an immediate landing. ○ Low ba ery on Applicant’s sUASs triggers a Non Fatal Warning alarm to return home, land and replace the battery.○ If Applicant’s sUASs detect a lost link to the base staon the vehicle will

perform its predefined Non Fatal Condition Response. Given these safety features, Applicant proposes that operators of Applicant’s sUASs should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:
1. Have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA recognized equivalents including ICAO issued commercial, private license and ground school and ; 2. Have completed the Virginia Drone ServicesAerial Production Pilot Certification Program for operation of the sUAS. Applicant notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant t o public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority,
g ranted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of Applicant’s sUASs without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein.
9 The risks associated with the operation of Applicant’s sUASs (given their size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the present level of safety provided under 14 CFR § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).14 CFR 91.7 (a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requi rements contained in the Manual for maintenance and use of safety checklists prior to each flight, as set forth in Section B and Section G, an equivalent level of safety will be provided. 14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placa rd requirements Given its size and configuration, the sUAS has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but also because there is no room or capacity to carry such an item on the aircra ft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 14 CFR 91.103: Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed fro m this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual. T hese actions will provide an equivalent level of safety.
10 14 CFR 91.109: Flight Instruction Section 91.103 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. By design, sUASs and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates withthe aircraft via radio communications. The FAA has previously approved exemptions for

aircraft without fully functional dual controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers wil l be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and by the size and speed of the aircraft. 14 CFR 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multi-rotor craft th at flies similarly to a helicopter, with vertical takeoff and vertical landing, which typically will operate at altitudes of 200 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at an altitude higher than 400 AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. See Manual for detailed procedures. The equivalent level of safety will be achieved given the size, weig ht, and speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personnel as outlined in the Manual, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum ten (10) lbs. proposed herein and carrying flammable fuel, any risk associated w ith Applicant’s operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 AGL in the any industry. In addition, the low-altitude operations of the sUAS will ensure separation between th ese small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.
11 14 CFR 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitudeby reference to an altimeter that is set "...to the elevation of the departure airport or an

appropriate altimeter setting available before departure." As the sUAS may not have a Barometric Altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 CFR 91.151 (a): Fuel requirements for flig ht in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Applicant’s sUAS is limited to operations in sterile and controlled environments as outlined in the Manual, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a). The battery powering the sUAS provides approximately 30 minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 5 minutes in l ength. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Virginia Drone Servicesbelieves that an exemption from 14 CFR §91.15l (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the sUAS, in a tightly controlled area where only peopl e and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve battery power, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zon e from anywhere in its limited operating area. Similarexemptions have been granted to other operations, including Exemptions 2689F, 5745,

10673, and 10808.
12 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration The regulation provides in part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate . . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than 10 l bs and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping the required documents at the
ground flight control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes
Exe mption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 CFR 91.405 (a) ; 407 (a) (l); 409 (a) (2); 417 (a) and (b): Maintenance inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...," and others shall inspect or maintain the aircraft
in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operatin g handbook as referenced in the Manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restrictedareas for limited periods of time. If mechanical issues arise, the sUAS can land

immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and, thus, best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of s afety.
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******* Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H ; 14 CF R 45.23 (b) ; 14 CFR §§ 61.113 (a) and (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109;
91.119 ; 91.121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) and (b) to operate commercially a small unmanne d vehicle (55 lbs or less) in image acquisition operations. Approval of exemptions allowing commercial operations of sUASs in the construction industry enhances safety while reducing risk. Manned aircraft image acquisition and surveying operations creates a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of

com bustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of sUASs weighing less than 30 lbs. and conducted in the strict conditions ou tlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at s low speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.Privacy

All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.
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****** * Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012, including size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security, provides mor e than adequate justification for the grant of the requested exemptions allowing commercial operation of Applicant's sUASs in the image acquisition industry pursuant to the Manual appended hereto. Sincerely, Chris Fox Virginia Drone Services