Douglas R. Bond T: +I 207 432 2225 xcamaerialsolutions@gmail.com
March 29, 2015
U.S. DepartmentofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590

Dear SirorMadam:Re: Exemption Request Section 333 ofthe FAA Reform Actand Part II ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR61.113 (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); 91.407(a) (I); 91.409 (a) (2); 91.417 (a) & (b)

Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012 (the Reform Act) and 14 C.F.R. Part II, X-cam Aerial Solutions, Inc., operatorofsmall Unmanned Aircraft Systems ("sUAS")equipped to; conductaerial photographyand 3d mappingforthe Agricultural Industryto help Farmers in the US get higheryield on their products and to help preventcontamination offarm lands ifthere was a manned aircraft accident, to provide real estate listingvideos and photographyfor real estate professionals, to safelyprovide aerial video and photographic inspection offacilities for the insurance industry, and to support businesses requiringenhanced marketingvideo and photography, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs")to allowcommercial operation ofits sUASs, so long as such operationsare conducted within and underthe conditions outlined herein oras maybe established bythe FAA as required by Section 333. As described more fully below, the requested exemption would permitthe operation ofsmall Unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that·is I) limited 2) predetermined 3)controlled asto access and 4)would provide safetyenhancementstothe already safeoperations in the Agricultural and Oil and Gas Industrypresentlyusing conventional aircraft. Approval ofthis exemption wouldtherebyenhance safetyand fulfill the SecretaryofTransportation's (the FAAAdministrator's) responsibilitiesto"

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."
Thename and address ofthe applicant is:
X-Cam Aerial Solutions, Inc. Attn: Douglas Bond, President Address: 30 Woodland Drive, Waterboro, Maine, 04087. Ph: 207-432-2225 EmaiI: xcamaerialsolutions@gmail.com' 

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### The conditionsproposed by the applicant are drawn from order 8900.1 CHG 0 Regulations from which the exemption is required
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR91.9 (b)(2) 14C.F.R.91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 CFR91.151 (a) 14 CFR91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR407 (a)(I) 14 CFR409 (a) (2) 14 CFR417 (a) & (b)
This exemption application is expressly submittedto fulfill Congress' goal in passing Section 333(a)through (c)ofthe Reform Act. This lawdirectsthe SecretaryofTransportationto consider whethercertain unmanned aircraft systems mayoperate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In makingthis determination, the Secretary is required to determine which types ofsUASs do not create a hazardto users oftheNAS orthe public orpose a threatto national security in light ofthe following:

• The sUAS's size, weight, speed, and operational capability • Operation ofthe sUAS in close proximityto airports and populated areas; and • Operation ofthe sUAS within visual line ofsightofthe operator. Reform Act Section 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary Shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ID Section 333(c)(emphasis added)
The Federal Aviation Act expressively grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under section 40I0I ofthe Act that includes sUASs, from the requirement that civil aircraft must have a currentairworthiness certificate. 

### Applicant interprets this provision to place the duty on the Administrator not only process applicants for exemptions under section 333, but for the administrator to craft conditions for the safe operation ofthe UAS, ifit should be determined that the conditions set forth herein do not fulfill the statutoryrequirements for approval.

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### The Administrator may grant:an exemption from a requirement of a regulation prescribed undersubsection (a) or (b) ofthis section or any sections44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. Section 4470l(f) 

### see also 49USC Section447ll(a);49 USC Section44704; 14 CFRSection91.203 (a) 

### (1).
X-Cam Aerial Solutions, Inc. operates sUASs fixed wing and mulitrotors weighing 55 or fewer lbs. including payload. They operate under normal conditions at a speed ofno more than 70 knots. They will operate in a line of sight and will operate only within the sterile areas made up of; Farm land, Gas and Oil Fields, Power Utility Grid, Pipeline Inspection and Cell Towers locations, restricted perimeters around listed real estate properties, restricted perimeters around structures requiring aerial inspections, and restricted perimeters around businessentitiesrequiringpromotional video and/orphotography.
Given the small size ofthe sUASs involved and restricted sterile environment within which they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to <:;ommence immediately. Also due to the size of the UASs and the restricted areas in which the relevant 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 proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions and chemical spills, exemptions associated with allowing sUASs for agricultural operations, oil and gas surveying operations. The grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption withoutdelay.
AIRCRAFTAND EQUIVELANTLEVEL OF SAFETY
Theapplicantproposesthat the exemption requested herein applyto aircraftthat have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe agricultural services and crops dusting currently being used with conventional aircraft.
I. The sUASs will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofapilot and/orobserving. 3. Maximum total flight time for each operational flight launch to land time is 8 hours for fixed wing operation. Flight operations ofMulitcopters is 90 minutes launch to land. Flights will be terminated at 25% batterypowerreserve. 4. 

### Flights will be operated at an altitude ofno more than 400 

### feet AGL. 5. Minimum crew for each operation will consistofthe sUAS Pilot, and Visual Observer. 6. sUAS Pilot will be certified by the aircraft manufacture for operations and have obtained at least a Sport Pilot license (LSA), No Medical required, valid driver's license required.

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7. sUAS Pilot will be pilot in command (PIC). Ifa pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the aerial coordinator),that person can also bedesignated as PIC. 8. The UAS will only operate within a confined "sterile area" and have a "Security Perimeter"for the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production activities. Itwill be mandatory that all personal that will be performing duties within boundaries ofthe safetyperimeterbe presentfor this briefing. I0. The operator will obtain the consent ofall persons involved in the flying area and ensure that only consenting persons be allowed within I00 feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety and determination. II. Pilot and observer will have been trained in the operation ofUAS generally and received up-to-date information on the particular UAS. Observerand Pilot will at all times be able to communicate byvoice ortext. 12. Written and/ororal permission from the relevant propertyholders will be obtained. 13. If the sUAS losses communications or it losses its GPS signal, the UAS will have capabilityto return to a pre-determined location within the Security Perimeterand land. 14. The sUAS will have capability to abort flight in case of unpredictable obstacles or emergencies. 15. Section 333 Air Worthiness Exemption is transferable from manufactureto operatorupon completion ofall requirements defined in this petition. 

### 14 C.F.R.Part21, SubpartH:Airworthinesscertificates 14 C.F.R. Section 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR Section 91.203 (a) (1). Given the size and limited operating area associated with aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meetsthe requirementsofan equivalen-t level ofsafetyunder Part II and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, proximityto airports and populated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in a restricted environment and underthe conditions proposed will be at lease as safe, or safer, than conventional aircraft (fixed wing or rotorcraft)operating with an airworthinesscertificate withoutthe retractions and conditionsproposed.
The sUAS to be operated here under is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable materials liquid fuels, and operates exclusively within a secured area as set forth in our S.O.P. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and, pursuant to the requirements, and in compliance to local public safety requirements, to provide security ofthe area ofoperation as is now done with conventional flag man. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection to agricultural aerial applicators, provide a greater degree ofsafetyto public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese 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 ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load.



### 414 C.F.R. Section45.23 (b). Markingofthe aircraft The regulation requires:
When marks include only the Roman capital letter "N" and the registration ofthe number is displayed on limited, restricted or in a light-sport category aircraft or experimental or provisionally certified aircraft, the operator must also display on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light spot," "experimental," or "provisional," as applicable.
Even though the sUAS will have no airworthiness certificate, and exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Given the size of the sUAV, the two inch lettering will 

### be impossible. The word "experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level ofsafety will be provided by having the sUAV marked on it fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe sUAV as "Experimental." The FAA has issued the following exemptions to this regulation; ExemptionsNos. I0700, 8738, I0167A.
14 C.F.R.

### § 61.113 (a) 

### & (b): PrivatepilotsPrivileges and Limitations: Pilotin Command. Sections 61.113 (a) & (b) limit pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety of current operations by requiring the PIC operating the aircraft to have a minimum ofa Sport Pilots Certificate rather than have a Commercial Pilots Certificate to operate this small UAS. Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled with no living thing onboard. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth by in the S.O.P. The level of safety provided by the requirements included in the S.O.P exceedsthat provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with the operation ofcommercial operations contemplated with Part 61 when drafted, that allowing operations ofthe sUAS as requested witli a recreational Sport Pilot as the PIC exceeds the present level ofsafety achieved by 14 C.F.R. §61,113 (a) 

### & (b).
14 C.F.R. §91.7 (a): CivilAircraftAirworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthiness 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 requirements contained in the SOP for maintenance and the use ofsafety check lists priorto each flight, an equivalent level ofsafetywill be provided.



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### 14 C.F.R. § 91.9 (b) (2): Civil AircraftFlightManual in theAircraft Section 91.9 (b) (2) provides:
No person mayoperatea U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placard, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot onboard, but because there is no room or capacityto carrysuch an item on the aircraft.
The equivalent level ofsafety will be maintained bykeeping the flight manual at the ground control point where the pilot flying the sUAS will have access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658,**1016~** 10602,32827,and 10700. 

### 14 C.F.R. §91.103: Preflightaction This regulation requires each pilot in command to take certain actions before flight to insure the safety ofthe flight. As the FAA approved rotor craft flight manuals will not be provided as set forth in sections ofthe S.O.P., the PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance databefore initiation offlight. 

### 14 C.F.R. §91.109: Flightinstruction 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. sUASs and remotely controlled aircraft, by their design do not have fully functioning dual controls. Flight control is accomplished though the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functioning dual controls for a number of aircraft and for flight instruction in experimental aircraft. See exemption Nos.5778K & 9862A.



### 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operations ofcivil 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. As exemption is for the sUAS that is a helicopter and the exemption requests authority to operate at altitudes ofup to 400 AGL rotorcraft and 1500 AGL for fixed-wing, or not more than 200 above an elevated platform such as radio towers, an exemption maybe needed to allow such operations. As set forth byherein, exceptfor the limited conditions stated in the SOP, the UAS will neveroperate higher than 400 AGL rotorcraft and 1500 AGL for fixed-wing. It will however be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.



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The equivalent level ofsafety will·be achieved given the size, weight, speed ofthe 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 participants in the activity, all affected individuals will be aware ofthe planned flight operations as set forth in the SOP. Compared to flight operations with aircraftorrotorcraft weighing far more than the maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those currently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these sUAS operations and the operations ofconventional aircraftthat mustcomplywith Section 91.119.


### 14 C.F.R. §91.121 AltimeterSettings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe 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 ofsafety will be achieved bythe operator, pursuant to the Manual and SafetyCheck list, confirmingthe altitude ofthe launch site shown on the GPS altitude indicatorbefore flight. 

### 14 C.F.R. §91.151(a): Fuel RequirementsforFlightin VFRConditions Section 91.151 (a) prohibits and individual from beginning "aflight in an airplane underVFR conditions unless (considering wind and forecast weatherconditions)there is enough fuel to fly to the first point ofintended landing, and assuming normal cruising speed- (I) During the day, to fly after that for at least 30 minutes; or(2) At night, to fly afterthat for at least45 minutes."
The battery powering the sUAS provides approximately 8 hours ofpowered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 7 hours and 30 minutes in length. Given the limitations on the sUAS'sproposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylightor night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR (a) falls within the scope of prior exemptions. See Exemption I0673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where only people and propertyowners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender the type ofrisk that Section 91.151(a) was intended to alleviate given the size speed ofthe sUAS. Additionally, limiting sUAS flights to I0 minutes would greatlyreduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 7 hrs 30 minutes or 25% ofbattery power, for both fixed wing and rotocraft, whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, I0673, and I0808.



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### 14 C.F.R. §91.203 (a) and (b): CarryingCivil AircraftCertification andRegistration The regulation provides in pertinentpart: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following:

(I) An appropriate and currentairworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed at the cockpit entrance so that it is legible to passengers orcrew. The sUAS fully loaded weighs no more than 55lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or displaythem on the sUAS.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying·the sUAS will have immediate access to them; to the extentthey are applicable tothe sUAS. The FAA has issued numerous exemptionsto this regulation. A representative sample of other exemptions includes Exemption Nos. 9565, 9665,9789, 9789A, 9797, 9816A, 10700. 

### 14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & 

### (b)
These regulations require that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspectormaintain the aircraft in compliance with part43.
Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the application. Maintenance will be accomplished by the operator pursuant to the flight manual and operating checklist. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the sUAS can land immediately and will be operating no higher than 400 feet AGL for rotorcraft and 1500 AGL for fixed-wing. As provided in the SOP, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance preformed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthycondition to provide the equivalent level ofsafety.



### 8Pursuant to 14 C.F.R Part II, the following summary is provided for publication in the Federal Register, should itbe determined thatpublication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R45.23 (b); 14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a)(I); 91.409 (a)(2)and 91.417 (a) & (b)to operate commercially a small unmanned vehicle (55lbs or less) in the Agricultural 3d Mapping Service Operations, Oil and Gas Exploration and Pipeline Inspection. Approval ofexemptions allowing commercial operations of sUASs in the Agricultural 3d mapping/scanning, Oil & Gas Exploration, Pipeline and Tower Inspection Industry, restricted perimeters around listed real estate properties, restricted perimeters around structures requiring aerial inspections, and restricted perimeters around business entities requiring promotional video and/or photography, will enhance safety by reducing risk. Conventional operations usingjet or piston aircraft operate at extremely low altitudesjust feet from the equipment and livestock and structures and present the risks associated with vehicles that weigh in the neighborhood of 3,000-5,000 lbs. This equipment can carry large amounts ofjet A or other fuel. Helicoptersoperate with 140 gallon fuel in theirtanks in most operations which could be a significant risk to the environment. The sUAS will carry no passengers or crew and therefore will not expose them to the risks associated with manned aircraft flights. The operations ofsmall UASs, weighing less then 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe Part 21 and allowing commercial operations. These lightweight UAYs operate at slow speeds, close to the ground and in sterile environmentand as a result are far saferthan conventional operationsconducted with a piston and orturbine aircraftoperatingcloseto the ground. Public

### Acknowledgement/Privacy All Flights will occur only once the property owner has authorized operations to be conducted. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximity to populated areas and or close proximity to airports and operations within visual line ofsight provides more then adequatejustification for the grantofthe requested exemptions allowing commercial operation ofapplicant's sUAS in the commercial industry described in this exemption petition.
Sincerely, 

# c;J,lJJ

Douglas R Bond President, X-Cam Aerial Solutions, Inc. Private Pilot Certificate#2097196



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