FROM: Ronnie Krupa T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production) 3062 Hogback Hill

PO Box 3 Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

TO:

DOCKET OPERATIONS

ROOM W12

- 140 OF THE WEST BUILDING

GROUND FLOOR 1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590 Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF: T. Layne Enterprises, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF T HE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 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 3D Robotics IRIS+ PROFESSIONAL

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

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

- 95)

Submitted April 28, 2015T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 2 TABLE OF CONTENTS

GLOSSARYOFABBREVIATIONS...................................................... .............................3

SUMMARY...................................................................................................................... ...4

INTRODUCTION AND INTERESTS OF PETITIONER.................................................4

BACKGROUND.................................................................................................................4

BASIS FOR PETITION......................................................................................................5

NAME AN D ADDRESS OF PETITIONER....................................... ...............................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH T. LAYNE ENTERPRISES, LLC SEEKS EXEMPTION...........

. ............. .... .................................... ...6

T HE EXTENT OF RELIEF T. LAYNE ENTERPRISES, LLC FILMS SEEKS AND

THE REASON T. LAYNE ENTERPRISES, LLC SEEKS THE RELIEF.......

... . . .......... 8

THE REASONS WHY GRANTING T. LAYNE ENTERPRISES, LLC ’ S REQUEST

WOULD BE IN THE PUBLIC INTEREST ...............................

..... ........................ ......10

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..............

....................... ................. ..............................12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............. .19

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENT .............................19

CONCLUSION......................................................................................20T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 3 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration FAR Federal Aviation Regulation

GCS Ground Control Station GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command ROI Region Of Interest Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures

UA Unmanned Aircraft UAS Unmanned Aircraft Syste m VFR Visual Flight Rules

VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and LandingT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 4 SUMMARY T. Layne Enterprises, LLC ( Ronnie Krupa ) seeks exemption from the requirements of 14 C.F.R §§61.113(a) & (b), 91.109, 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 operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit T. Layne Enterprises, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors for r eal estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER T. Layne En terprises, LLC (D.B.A. 4 Forks Media Production) is a production company

based in Pennsylvania specializing in real estate videography, photography, music video production, special event production with plans to extend into web based film production.

The members of T. Layne Enterprises, LLC have been in the video and entertainment production business for one year ; have produced several business promotional videos,

event videos and real estate videos. T. Layne Enterprises, LLC’s objective is to conduct

a erial photography and videography in order to provide high quality digital imaging and

video content to its clients, in particular to homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspector s for real estate marketin g and inspections of home exteriors utilizing 3D Robotics IRIS+ UAS. More specifically, T. Layne Enterprises, LLC’s aerial video and photography operations will serve in the following areas: • Aerial photography of houses / residential and commercial build ings • Aerial videography of houses / residential and commercial buildings • Aerial event photography • Aerial event filming • Aerial Film production • Aerial location scouting and safety inspection • Increase public knowledge of UAS and promote safe UAS o perations.

The proposed aerial filming will be conducted over private property with controlled

access in the NAS and with the knowledge and permit of the private property’s owner. Unmanned Aircraft Systems: 3D Robotics IRIS+ Professional UAS T. Layne Enterprises, LLC seeks an exemption to operate 3D Robotics IRIS+

Professional UAS DRONES for compensation or hire within the NAS. The 3D Robotics

IRIS+ Professional UAS are vertical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Cont rol Station (GCS) utilizing electronic tablet or smart phone systems. The 3D Robotics IRIS+ Professional UAS have a maximum gross weight of approximately 2lbs 8oz, while having a length of 19.5 inches width of 19.5 inches, height of 4 inches, and a maximu m speed of approximately 29 knots.

The 3D Robotics IRIS+ Professional UAS is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The 3D Robotics IRIS+T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 5 Professional UAS that will be operated by T. Layne Enterprises, LL C will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION Petitioner, T. Layne Enterprises, LLC , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 3D Robotics IRIS+ Professional

UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R§§ 61.113(a) & (b), 91.109, 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).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, T. Layne Enterprises, LLC’s operation of

3D Robotics IRIS+ UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H. Accordingly, T. Layne Enterprises, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.4 17(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. T. Layne Enterprises, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. T. Layne Enterprises, LLC will use experienced personnel

or technicians to perform maintenance, alterations, or preventive maintenance on the

UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3D Robotics IRIS+ Instruction Manual). Furthermore, T. Layne Enterprises, LLC will document and maintain all maintenance

records for the 3D Robotics IRIS+ Professional UAS . T. Layne Enterprises, LLC seeks relief from Section 91.7(a), entitled Civ il aircraft airworthiness, because the 3D Robotics

IRIS+ Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, T. Layne Enterprises, LLC submits that it will ensure

that the 3D Robotics IRIS+ Professional UAS is in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and 3D Robotics Instruction Manual), and that the

aircraft are in a condition for safe flight. T. Layne Enterprises, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the

3D Robotics IRIS+ Professional UAS will not have a typical barometric altimeter onboard. However, altitude info rmation of the 3D Robotics IRIS+ Professional UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This a ltitude information, combined with T. Layne Enterprises, LLC ’ s operation of the 3D Robotics IRIS+ Professional UAS within visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section

91.121. Additionally, T. Layne Ent erprises, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. T. LayneT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 6 Enterprises, LLC submits that safety will not be affected by operation of the 3D Robotics

IRIS+ Professional UA d uring daylight hours in visual meteorological conditions (VMC)

under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81,

T. Layne Enterprises, LLC provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Pet itioner and point of contact is: Ronnie Krupa T. Layne Enterprises, LLC 3062 Hogback Hill

PO Box 3 Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

B. The Specific Sections Of 14 C.F .R. From Which T. Layne Enterprises, LLC Seeks Exemption.

1

. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

2

. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Section

91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each pe rson 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 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In t he case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

3

. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.15 1, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 7 (b) 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 20 minutes.

4

. T. Layne Enterprises, LLC 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 this section, have di screpancies repaired as prescribed in part 43 of this chapter[.]

5

. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or altera tion, subsection (a)(1), states the following: (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 §

4 3.7 of this chapter[.]

6

. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of thi s 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 app roved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

7

. T. Layne Enterprises, LLC Seeks Exemption From The Requireme nts Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or a pproved 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; andT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 8 (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return

to service. (2) Records containing the following information: (i) The total time in service o f the airframe, each engine, 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 requir ed 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 rep eated 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 § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

C. The Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne Enterpris es, LLC The Relief.

2. Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne Enterprises, LLC Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to a llow T. Layne Enterprises, LLC to determine that the 3D Robotics IRIS+ UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log, and 3D

Robotics IRIS+ Pro fessional Instruction Manual). T. Layne Enterprises, LLC seeks the requested relief because the 3D Robotics IRIS+ UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, T. Layne Enterprises, LLC will ensure that the

3D Robotics IRIS+ UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 3D Robotics IRIS+ Professional Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 9 3. Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne Enterprises, LLC Seeks Relief From Section 91.121. Relief from Section 91.121, e ntitled Altimeter settings, may be required to allow flight operations of the 3D Robotics IRIS+ Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude information fro m the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), T. Layne Enterprises, LLC seeks the requested relief because the 3D Robotics IRIS+ UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the 3D Robotics IRIS+ Professional UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Ext ent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne Enterprises, LLC Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered 3D Robotics

IRIS+ Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming norm al cruising speed, to fly after that for at

least 4.5 minutes. T. Layne Enterprises, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered 3D

Robotics IRIS+ UA will severely cons train the practicality of any aerial video or still photo flight operations that T. Layne Enterprises, LLC proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the 3D Robotics IRIS+ Professional operating documents, and T. Layne Enterprises, LLC proposed operating limitations, ensure that T. Layne Enterprises, LLC will safely operate the battery powered 3D Robotics IRIS+ Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of T. Layne Ent erprises, LLC Seeks And The Reason T. Layne Enterprises,

LLC Seeks Relief From Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to air craft with an airworthiness certificate, T. Layne Enterprises, LLC requests relief from these Sections because the 3D Robotics IRIS+ Professional UAS do not require airworthiness certificates. As set forth more fully below, the 3D RoboticsT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 10 IRIS+ Profession al UAS meet the conditions of FMRA Section 333 for operation without

an airworthiness c ertificate. Accordingly, T. Layne Enterprises, LLC will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, t echniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and 3D Robotics IRIS+ Professional Instruction Manual). Furthermore, T. Layne Enterprises, LLC will document and

maintain all maintenance records for the 3D Robotics IRIS+ UAS.

D. The Reasons Why Granting T. Layne Enterprises, LLC 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 T. Layne Enterprises, LLC to safely, efficiently, and economically perform aerial video and photography of real estate, special events, film sets, and landscape over certain areas of

the United States. Additionally, use of the 3D Robotics IRIS+ Professional UAS wi ll decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably,

the benefits of T. Layne Enterprises, LLC ‘s proposed operation of the 3D Robotics

IRIS+ UAS will be realized without implicating any privacy iss ues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3D Robotics IRIS+ Professional UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3D Robotics IRIS+ UAS would reduce

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 3D Robotics IRIS+

Professional UA do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer

aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3D Robotics IRIS+

UAS. Conducting aerial acquisitions with the 3D Robotics IRIS+ Professional UAS, instead of manned aircraft, will greatly benefit t he public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the 3D Robotics IRIS+

Professional UAS produce no air pol lution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft

that are typically utilized for aerial video and photography, while burning approximately

20

- 30 gallons per hour of le aded aviation fuel. The 3D Robotics IRIS+ Professional UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the 3D Robotics IRIS+ Professional UAS to perform aerialT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 11 acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially

re duced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 3D Robotics IRIS+ UAS (we ighing approximately 2 pounds 8 ounces, at their maximum gross weights with lengths of 19 inches and with no fuel on

board ), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42

feet , a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The 3D Robotics IRIS+ UAS Will Benefit The Economy. In addition to being safe and efficient, the 3D Robotics IRIS+ Professional is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 3D Robotics IRIS+ Professional UAS will allow United States based companies, like T. Layne Enterprises, LLC , to remain competitive and contri bute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative

t echnology in order to remain competitive. Operating the battery powered 3D Robotics

IRIS+ Professional UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility with out the high operational cost of a traditional manned aircraft. By operating the 3D Robotics

IRIS+ Professional UAS, companies such as T. Layne Enterprises, LLC , can remain competitive and profitable, and therefore, provide greater job stability to employe es and contractors, which will ultimately contribute to growth of the U.S. economy. Improved

financial performance of U.S. companies, through commercial use of the 3D Robotics

IRIS+ Professional UAS, provides a stable workforce that increases consumer spen ding; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, T. Layne Enterprises, LLC proposed operation of the 3D Robotics IRIS+ UAS

would not implicate any privacy issues. Specifically, the 3D Robotics IRIS+ UAS will be operated only in compliance with oper ating documents (i.e., the Monthly Maintenance Log, 3D Robotics IRIS+ Professional Instruction Manual ), which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, includ ing the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To ThatT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 12 Provided By The Rule From Which T. Layn e Enterprises, LLC Seeks Exemption. 1. Reasons Why The 3D Robotics IRIS+ Professional UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, T. Layne Enterprises, LLC’s operation of the 3D Robotics IRIS+ UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine i f certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rule

- making required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraf t Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and

po pulated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or

airworth iness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, T. Layne Ent erprises, LLC submits that the 3D Robotics

IRIS+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3D Robotics IRIS+ Professional UAS; and (b ) the specific operating limitations.

a. The Spec ifications Of The 3D Robotics IRIS+ Professional UAS Demonstrate Its Safe

Characteristics.

The 3D Robotics IRIS+ Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its si ze, weight, speed, and operational capability.

i. Technical Specifications Of The 3D Robotics IRIS+ Professional UAS. The technical specifications of the 3D Robotics IRIS+T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 13 Professional UAS is set forth by the 3D Robotics IRIS+ Professional Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The 3D Robotics IRIS+ Professional UAS Autonomous Flight And Navigation Modes

Enable The UAS To Remain Within A Defined Operational Area. The 3D Robotics

IRIS+ Professional UAS may be operated in both manu al and fully autonomous flight modes. A complete description of the flight and navigational modes of the 3D Robotics

IRIS+ UAS is provided at pages 11

- 12 of the 3D Robotics IRIS+ , User Manual, attached

hereto as Exhibit B.

iii. The 3D Robotics IRIS+ Profes sional UAS Are Designed For Automatic Return To

Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the 3D Robotics IRIS+ UA will remains stationary, in flight. If,

the 3D Robotics IRIS+ Professional UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complet e description of the Failsafe Functions of t he 3D Robotics IRIS+

UAS are set forth at page 7 of the 3D Robotics IRIS+ Professional U ser Manual, attached

hereto as B

.

iv. The 3D Robotics IRIS+ Professional GCS And Its Operation. A complete description of t he operation and specifications of the 3D Robotics IRIS+ GCS and flight control software is provided at pages 8

- 20 of the 3D Robotics IRIS+

Professional User Manual. 3D Robotics IRIS+ User Manual is attached hereto as Exhibit

B

. b. Flight Operations Of 3D Robotics IRIS+ Professional UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. T. Layne Enterprises, LLC will use a safety observer to assist all pilots during flight time. c. Flights Of 3D Robotics IRIS+ Pr ofessional UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, proposes to commercially

operate 3D Robotics IRIS+ UAS for the special purpose of conducting aerial video and photography over certain areas of United S tates, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: 3D Robotics IRIS+ Professional Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to con ducting operations for the purpose of aerial video and photography for homeowners, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be conduct ed on occasional basis for film and television sets, special events and landscape photography as deemed necessary. 3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s). 4. The UAS must be operated at an altitude of no more than 200 (500 per the User Manual) feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 14 5. The UAS must be ope rated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be abl e to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure

t hat the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted t o operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations c ontained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlin ed in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such

revisions and present updated and revised documents to the Administrator upon request. The operator must also presen t updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition fo r amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe fli ght. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or fl ight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the f unctional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all pot ential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, insp ection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul compone nt parts must be noted in the aircraft records, including total time in service, description of work accomplished, andT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 15 the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manu facturers Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17 . The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from per sons, vessels,

vehicles and structures.

18 . UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request w ill be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR)

are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- publishe d aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made avai lable to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accorda nce with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% batte ry power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption.

26 . Before conducting operations, the radio frequency s pectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available t o the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official

upon request. 29. The UAS must remain clear and yield the right of way to all mann ed aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipatingT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 16 persons (persons other than the PIC, SO, o perator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue haza rd, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be

conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertic al boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained o n the

NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. T. Layne Enterprises, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate

the 3D Robotics IRIS+ unless they have read and agreed to adhere to the 3D Robotics IRIS+ Instruction manual and have had adequate supervised flying time under the supervision of an exper ienced operator, The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 1110 9, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be m aintained because prior to every flight, T. Layne Enterprises, LLC will ensure that the 3D Robotics

IRIS+ UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1111 2, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 17 The equivalent level of safety established by Section 91.121 will be maintaine d because

the altitude information of the 3D Robotics IRIS+ UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude

i nformation, combined with T. Layne Enterprises, LLC operation of the 3D Robotics

IRIS+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generat ed by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Re quirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 3D

Robotics IRIS+ UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, T. Layne Enterprises,

LLC will ensure that it will safely operate the battery powered 3D Robotics IRIS+

Professional UA during dayl ight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the 3D Robotics IRIS+ UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the 3D Robotics IRIS+ Professional UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the 3D Robotics IRIS+ UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adve rsely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 1 0650. Moreover, the FAA has previously granted

relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 1106 7, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safe ty. In seeking this exemption, T. Layne Enterprises, LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements establishedT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 18 by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be

met because T. Layne Enterprises, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Monthl y Maintenance Log, and 3D Robotics IRIS+ Professional Instruction Manual). Furthermore, T. Layne Enterprises, LLC will document and maintain all maintenance

records for the 3D Robotics IRIS+ Professional UAS. Since the 3D Robotics IRIS+

Professional UAS wi ll be inspected as prescribed by the operating documents, T. Layne Enterprises, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3D Robotics IRIS+ User

Manual is attached here to as Exhibit B ; a copy of the 3D Robotics IRIS+ UAS

Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because T. Layne Enterprises, LLC will use trained technicians to perform maintenance, alte rations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91 .417(b), because all maintenance of the

3D Robotics IRIS+ Professional UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. In consideration of T. Layne Enterprises, LLC proposed operating limitations, the operating documents, and the technical aspects of the 3D Robotics IRIS+ Professional UAS, T. Layne Enterprises, LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R . Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064 , 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 111 56, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform A ct of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, T. Layne Enterprises, LLC

requests that the FAA prescribe special conditions for the intended operation of the 3D

Robotics IRIS+ UAS, which contain such safety standards that the Administ rator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 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). Such sp ecial conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA

Section 333 sets f orth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness

certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe specialT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 19 conditions pursuant to 14 C.F.R. § 21.16, for operation of the 3D Robotics IRIS+

Professional UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this sub chapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments there to for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that e stablished in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for T. Layne Enterprises, LLC intended operation of the 3D Robotics IRIS+ UAS, which contain su ch safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which T. Layne Enterprises, LLC Seeks Exemption: T. Layne Enterprises, LLC seeks exemption from the requirements of 14 C.F.R 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). A Brief Description Of The Nature Of The Exemption T. Layne Enterprises, LLC Seeks: This exemption will permit T. Layne Enterprises, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support T. Layne Enterprises, LL C Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if

certain UAS may operate safely in the NAS. As such, T. Layne Enterprises, LLC reques t for exemption may be granted pursuant to the authority of FMRA Section 333 and 14
C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or

ot herwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, T. Layne Enterprises, LLC will operate the 3D Robotics IRIS+ Professional UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, T. Layne Enterprises, LLC seeks an exemption pursuant to 14 C.F.R.T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 20 § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3D Robotics IRIS+ Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting

aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing T. Layne Enterprises, L LC to safely, efficiently, and economically operate

the 3D Robotics IRIS+ UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, T. Layne Enterprises, L LC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 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), and permit T. Layne Enterprises, LLC to operate the 3D Robotics IRIS+ Professional UAS commercially for the purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home b uilders, home contractors and / or home inspectors f or real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape over certain areas of the United

States.

Dated: April 28 , 2015 Respectfully submitted by,

Ron nie Krupa

_________________________ Ronnie Krupa T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production) 3062 Hogback Hill

PO Box 3 Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

Appendixes:

A

– 3D Robotics IRIS+ Specifications Data SheetT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 21 B

– 3D Robotics IRIS+ Manufacturer’s User Manual

C

– Monthly Maintenance Log

APPENDIX

– A

3D Robotics IRIS+ Technical Specifications T. Layne Enterprises, LLC only utilizes safe and reliable UASs. 3D Robotics i s an industry leader in small UAS production. 3D Robotics IRIS+ UASs are loaded with ground breaking software enabling the user to set paramet ers which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, 3D Robotics IRIS+ software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

Autopilot Hardware: Pixhawk Firmware: APM: Copter3.1

GPS: 3DR uBlox GPS with Compass (LEA

- 6H module, 5 Hz update) Telemetry Radio: 3DR Radio Telemetry v2 (915 mHz Battery: 3S 5.1 Ah 8C lithium polymer Low battery voltage: 10.5 V Maximum voltage: 12.6 V Battery cell limit: 3S Payload capacity: 400 g (.8 lbs) Radio range: up to 1 km (.6 miles) Flight time: 16

- 22 minutes, depending on payload

APPENDIX

– B

3D Robotics IRIS+ Manufacturer’s User Manual (uploaded in a separate attachment )

APPENDIX

– C

MONTHLY MAINTENANCE LOGT. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 22 Ronnie Krupa T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production) 3062 Hogback Hill

PO Box 3 Mineral Springs, PA 16855

Tel: 814.577.0872 Email: Ronnie@4forksmedia.com