Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

B & N Aerial Innovations

, January 13, 2015

Re: Exemptio n Request Pursuant To Section 333 of the FAA Reform Act of 2012

Pursuant to §333 of the FAA Modernization and Reform Act of 2012 (the Refo rm Act) and 14 C.F.R. Part 11, B & N Aerial Inn ovations, operator of Small Unmanned Aircraft Syste ms (sUASs) equipped to conduct aerial photography for the Real Estate, media and advertising industries for pre

- planned, controlled area, photographic and surveying services, hereby applies for an exempt ion from the listed Feder al Aviation Regulations (FARs) to allow commercial operation of its UAS's, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration ( FAA) as required by §333. B & N Aerial Innovations' current operation of sUASs for commercial purp oses has been halted to comply with recently enacted federal aviation re gulations pertaining to UAS's. As described more fully below, the requested exempti on would permit th e operation of small, unmanned and relatively inexpensive multirotor aircraft under controlled conditions
in ai rspace that is 1) contained 2) predetermined 3) has on

- site safety personnel controlling access, and 4) would provide increas ed safety and enhancements to clients' business operations.

Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

B & N Aerial Innovations respectfully requests a grant of an exemption of the following sections of Title
14 of the Cod e of

Federal Regulations:

- 14 CFR 21;

- 14 CFR 91, et seq.;

- 14 CFR 45.23 (b); Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

• 14 CFR 61.113 (a) & (b);

• 14 CFR 407 (a)(l);

• 14 CFR 409 (a)(2);

• 14CFR417(a)&(b).

B & N Aerial Innovations also respectfully requests an Exemption from 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 61.1 13 (a) & (b);

• 91.7 (a);

• 91.9(b)(2);

• 91.103(b);

• 91.109;Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

• 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).

I. The Extent of Relief B & N Aerial Innovations Seeks and the Reason It Seeks Such Relief:

B & N Aerial Innovations submits this application in accordance with the Reform Act, 112 P.L. 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft sys tems) and operating to prevent B & N Aerial Innovations contemplated commercial photographic, mapping, and other flight operations within the U.S. national airspace
system. The Reform Act in §332 provides for such integration of civil UASs into o ur national airspace
system as it is in the public's interest to do so. B & N Aerial Innovations' lightweight UASs meet the
definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record
i n similar industries, B & N Aerial Inn ovations ' light duty UASs are ide al recipients of exemption by the
intent of the Reform Act. Considerations for relief include a combination of sUAS physical
characterist ics, safety features, and safe practices identiied in §333:

• sUAS weight,

• sUAS overall size,

• sUAS speed over ground,

• sUAS flight zone characteristecs,

- Non

- operation near airports (civilian or military),

- Tightly controlled operation in populated areas,

• Operation of the UAS by VLOS.

• Coordination by a minimum of 4 persons, three staff members of B & N Aerial Innovations and one safety official from the client.

Specific c onsideration is outline below.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes 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 sUASs, an exemption from Part 21 Subpart H meets theRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

requirements o f an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon co nsideration of the size, weight, spee d, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, 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 as safe, or safer, than a

conven tional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the
restric tions and conditions proposed. The sU AS to be operated by B & N Aerial Inn ovations is less than 11kg. with maxima l payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustible fuels, and operates exclusively within

a sec ured area. Unlike other ci vil aircraft, operations under this exemption will be tightly controlled and monitored by both the pilot (PIC) , 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety issues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liasons to the on

- site safety officials. These enhancements to current safety practices and regulations, which already apply to civil aircra ft, provide a greater degree of safety to the public and pro perty owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F. R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates th at there is no intrinsic credib le threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter " N" and the registration
number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to

t he cab in, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited; ' "restricted;' "light

- sport;' "experimental;' or "provisional; ' as applicable. Even though
the sUAS will have no airworthiness certif icate, an exemp tion 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 sUAS, two

- inch lettering will be impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size sui table for the available space. 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 workin g with the sUAV will see th e identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regula tion to Exemptions Nos. 10700, 8738, 10167 and 10167A. Further markings include the use of flashing green LED illuminatio n on
t he underside of the sUAS frame which stands at contrast against a blue or white sky

14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

§61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of s afety of current operations by requiring a ground crew member to have a private pilot's license rather than a commercial pilot's license to operate this sUAS. Unlike a co nventional aircraft that carries the pilot and

pa ssengers, the sUAS is remotely controlled with no persons on board. The area of operation is
controlled and r estricted, and all flights are planned and coordinated in advance. The risks associated
with the operation of the sUAS are so diminish ed from the level of risk associated with commercialRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

operations contemplated by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 C.P.R. §61.1 13 (a) & (b).

14 C.P.R. §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 th e size of the aircraft and the requirements contained in the Manual for maintenan ce and use of safety ch eck lists prior to each flight,

a subset of which are provided in enclosed Supplemental material, an equivalent lev el of safety will be provided. 14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is av ailable in the aircraft a current approved airplane or Rotorcraft Flig ht Manual, approved manual mat erial, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a physical flig ht manual on the aircraft. The equivalent level of safety will be maintained by ke eping the flight
manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The
FAA has issu ed the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,9565 8, 10167, 10167A, 10602,32827, and 10700

14 C.F.R. §91.103: Preflight action

This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As

FA A approved rotorcraft flight manuals will not be provided for the aircraft an exe mption will be
needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing
and takeoff distances and aircraft performance data b efore initiation of flight. Further, we ha ve proprietary manuals created with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices

are adhered to. 14 C.P.R . §91.1 09: Flight instruction §91.103 provides that no person may operate a civil aircraft (except a mann ed free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight contr ol is accomplished through the use of a control box that
communicates with the aircraft via radio commun ications. The FAA has approved exemptions for flig ht training without fully functional dual controls for a num ber of aircraft and fo r flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inherent in the rem ote controls utiziling digital communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted.

14 C.F.R. §91.119: Minimum safe altitudes

§91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) all ows helicopters to be operated at less than the minimums prescribed, provided the person operating the heli copter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, the

UA S will never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. It will however be operated in a restricte d area with security officials tasked with ensuring public safety, and where buildings and people will not be exposed to operations without their pre

- obtainedRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

consent and training. The equivalent level of safety will be achieved given the size, weight, s peed of t he
UAS as well as the location where it is operated. No flight operation will be taken without the permissio n of the property owner in the case of private property or local officials i the case of public property or private property with public interests. Because of the advance notice to the property owner and participants in th e remote sensing activity, all affected individuals will be aware of the planned flight operations. Compared to f light operations with aircraft or rotorcraft weighting far more than the maximum 11kg of B & N Aerial Inn ovations ’ sUAS s proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or bel ow 500 AGL. In addition, the low

- a ltitude operations of the sUAS will ensure separation between these small

- UAS operations and the operations of conventio nal aircraft that must comply with §91.119.

14 C.F.R. §91.121 Altimeter Settings

§91.121 requires each person operating an aircraft to maintain cruising altitud e by reference to an
altimeter that is set " ... to the elevation of the departure airport or an appropriate alti meter setting available before departure." As the sUAS may not have a barometr ic altimeter, but inste ad a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved b y the operator, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
The PIC and Techn ician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height. 14 C.F.R. §91.15l(a): Fuel Requirement s for Flight in VFR Conditions §91.151 (a) prohibits an individual from beginning "a flight in an airplan e 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

- (1) During the day, to fly after th at for at least 30 minutes; or ( 2) At night, to fly after that for at least 45 minutes:' The battery powering t he sUAS provides approximately 15 minutes of powered flight in hover mode without payload. B & N Aerial

Inn ovations ’ sUA S will not be able to meet the 30 minute reserve requirement in 14 CP R §91.151. Operating the small UAS , in a tightly controlled area where only people and property owners or official representatives who have s igned waivers will be allowed, with less than 30 minutes of reserve power, does not engender the type of risks th at Section 9l.l51(a) was intended to alleviate given the size and speed of the small UAS. B & N Aerial Inn ovations believ es that an equivalent level of safety can be achieved by limiting flights to » 10 minutes or 25% of battery power whichever happ ens first. This

rest riction would be more than adequate to return the sUAS toils plan ned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808

14 C.P.R. §91.203 (a ) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent 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 req uired 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 ll kg and is operated without an onboard pilot. As such, there is no ability or place to carry certification andRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

registration documents or to display them 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 extent th ey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representat ive sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance In spections These regulations require that an aircraft operator or owner
"shall have that ai rcraft inspected as prescribed in subpart E of this part and shall between required inspections, except a s provided in paragraph (c) of this section, have discrepa ncies 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 sec tion and Part 43 apply only to aircraft with an airworthiness certificate,
these sections wil l not apply to t he applicant. Maintena nce will be accomplished by the operator pursuant to the flight manual. An equivalent le vel of safety 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 of time. If mechanical issues arise the UAS ca n land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UA S is in working order prior to initiating flight, perfo rm required maintenance, and keep a log of any mainte nance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintai n the aircraft in an airworthy condition to provide t he equivalent level of safety. An e xemption granted to B & N Aerial

Inn ovations would permit its operation of l ightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited airspace. B & N Aerial Inn ovations utilizes local business' safety officers in specifically determined areas (de signed flight zone) to mitig ate injury and property damage while fulfilling clients' goals. Technical enhancements to current safety c ontrols will allow B & N
Aerial Inn ovations to operate exceeding current safety specifications, and stay ahead of, or meet, new
ones bei ng implemented by the FAA and Department of Transportation. Further, B & N Aerial

Inn ovations conduct s its operations in compliance with protocols described herein or as otherwise established by the FAA.

II. Commercial and Public Benefits

We at B & N Aerial Inn ovations believe that granting this exemption request furthers the pub lic interest by providing safe (by way of an unmanned system) and efficient means to meet technical prob lems solvable by elevated data collection instruments. B & N Aerial Inn ovations client b ase are typically small
to med ium sized business' looking to increase their awareness of structures or landscape on their respective prop erties through data collection by photographic, videographic or lidar based surveying. By moving these functions onto sUAS based aircraft, the potential for loss of life or property is diminished due to the gr eater control in a smaller and safer aircraft that holds no persons. Second, there are no
reactive or comb ustible materials on board the sUAS and thus the potent ial for fire or explosions is greatly diminished. Thi rd, the small size and extreme maneuverability of B & N Aerial Inn ovations UASs allow the PIC to avoid hazards. Lastly, d ue to the nature of the remote sensing instrumentation onboard, the sUAS can maintain quite a s afe distanc e between the aircraft and the object(s) undergoing scrutiny. Accordingly, B & N Aerial Inn ovations ’ UASs have operated a nd will continue to operate at and above current safety levels.

A. The costs and benefits of your proposed action to society in general and specific groups within society

As described above, B & N Aerial Inn ovations ‘ past customers have been small to medium bus iness seeking a remote sensing solution to specific issues before a larger effort on their part would c ome underway. Examples include Real Estate efforts that sought elevated photographic imagery of specificRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

Estates to minimize cost of efforts to market said homes

. The angles that can be achieved by means of sUASs give a home buyer an extended feeling of the property within. The impact to s ociety, financial and otherwise, would be extremely minimal. Indeed, it's been demonstrated that sUASs have the ability to drasticially increase the information availible to policymakers at a fraction of the cost of measuring this data by terrestrial mea ns. One such impact woul d be inconvenience to directly proximal and non

essential personnel that would be displaced from public or bu siness owned property if it is deemed to
be unsafe. In this case we relay our needs for a fl ight zone with the requiremen t that it be safe from casual intrusions and allow the business time to shift operations in order to min imize potential safety
issues. This is best performed with the aid of safety personnel that actively steer no n

- essential persons
around the flight zo ne.

1. The effect of an exemption for B & N Aerial Inn ovations on the quality of the natural and social
environments

Utilizing sUASs minimizes the requirement for conventional aircraft. This elimi nates the need for an on board pilot, time consuming adherance to regulations surrounding bookeeping and submission of flight paths to local civiliar or military airports, and detrimental effects to the env ironment caused by operating a combustible fuel based, large scale aircraft, wi th restrictions on the proximity to the target for remote sensing.

Ill. Flight Capabilities and Char acteristics of B & N Aerial Inn ovations ’ UASs Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated b y the overall capabilities and characteristics of the sUAS. 1
B & N Aerial Inn ovations UASs utilizes eight (8) counter

- rotating propellers paired opposit ely to each other for balance, control and stability. The total span of the sUAS is ""'1.2m allowing for stab le flight or landing even with the sudden onset of de trimental environmental conditions. The sUAS's hav e a maxima l unit+ payload mass of llkg, including cinematic/photographic or other surveying equipment. B & N Aerial Inn ovations ’ sUAS is designed to primarily hover in place to capture photographic data and then operate at les s than a 35 knot maximum speed to the next point of interest. They are capable of vertical and horizontal operations but, in practice, is operated only within unaided VLOS of the PIC. In addition to the PIC, B & N Aerial Inn ovations employs a spotter (VOS role) a nd a technician (secondary
VOS and on

- site personnel ) which are withi n unaided verbal communication range. These personnel are supplemented by safety officials provided by the clien t who are instructed to cordon off and otherwise minimize pedestria n access in the flight zone of the client's gr ounds. In the event of loss of visual of the UAS, the PIC can change flight controls from Cartesian (X,Y,Z) bas ed controls to radial (r, a ,h) based
controls which allows the PIC to utilize one controller axis to recall the VAS to the PIC's position without concern to the current heading of the sUAS. In the event of loss of sight of the sUAS into an area containing hazards or possible hazards, the spotter has a heads

- up

- display containing a live video feed
wh ich can be used to locate the UAS while it maintains its position in hover m ode. The sUAS has
demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in "

- '25 kph wind gusts at rv25 feet representing an extreme environmental condition beyond the range of condit ions within the scope for sUAS operation. All of B & N Aerial Inn ovations ’ sUASs utilize LiPo (lithium polymer) battery based power so urces, decreasing safety risks from more easily combustible, fuel based, power sources. Flight tim es generally last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per phase. T he maximum flight time without payload is 15 minutes, however practical safe operation limits this to 10 to give ample time to control the sUAS to a safe landing zone. B & N
Aerial Inn ovations further restricts flight time by not oper ating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows B & N Aerial Inn ovations sUASs to hover in place if communication with the PIC is lo st and optionally
follow a set of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. InRe: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

the event of unforeseen motor(s) failure, the system will enter into a controlled descent while allowing
full use of all UAS flight controls by the PIC. All commands sent via remote controller received during a
controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's real time 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity.

L anding gear is also programmed to deploy based on sensing of range to ground from non

- GPS based

sources. T his assures that if one system is com pensated a safe and successful landing can still occur.

IV. Reasons Why an Exemption to B & N Aerial Inn ovations Will Not Adversely Affect Safety Standards

B & N Aerial Inn ovations ’ contends that operation of it's sUASs will not "create a hazard to users of the national airspace syst em or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of B & N Aerial Inn ovations ’ sUASs, combined with their operation in cordoned off and well

controlled areas, B & N Aerial Inn ovations ’ sUASs falls within Congress's contemplated safety zone. B &
N Aerial Inn ovations sUASs have an estab lished sa fety record bolstered by multi

- point preflight checklist, awareness of their surroundings and inti mate knowledge of the behavior of the sUAS platform in many weather conditions. TI1is safety record and implemented oper ational practices demonstrate an awareness of public safety. B & N Aerial Inn ovations operations routinely provide a level of safety at least equal to exist ing rules, and in nearly every instance, exceeds existing rules. B & N Aerial

Inn ovations has worked very closely with the region al vendors and support for this unit to create a tightly integrated and highly fauh tolerant platform that has been tested thoroughly by a vendor with a proven record for safety and solid designs. Though it does not mitigate safety it is of note that as of Nov
2014 the re are few companies that will insure sUAS operations and sUAS based companies. The sUAS of

use at B & N Aerial Inn ovations is one of two models (by current awareness) that qualify for protection against damages or injury. B & N Aerial Inn ovations attained the maximal l evel of insurance to rectify accidental damage or injury. B & N Aerial Inn ovations also conti nues to work closely with this organization to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to the aviation and transpor tation. B & N Aerial Inn ovations does not operate its UASs on or near airports and generally has only operated its fleet on private grounds with cordoned off areas or areas under the control of the property own er I client with assistance by safety officials employed by the
business. B & N Aerial Inn ovations determines the areas needed to fulfill the clients' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS tr ade and hobby groups and recently codified by relevant FARs.

B & N Aerial Inn ovations standardized on the following practices to ensure safe operation of it's UASs:

• Work with on

- site personnel to plan the flight goals,

• Work with on

- site personnel to restrict access t o non

- essential persons,

• Operation by unaided VLOS operation only,

• Operation in phases 10 minutes in length,

• Operation to minimal 25% battery power,

• Operation of device to GPS aided readout to 300ft at maximum,

• Numerous pre

- programmed fail

- s afes that ensure specific behavior per issue,

• Three main roles supplemented by on

- site safety personnel,

• Employ controlled lifecycle management of components to guard against multiple failures,Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

• Preform a site check day(s) before flight to identify potential issues,

• Subscribe to relevant local weather and safety alerts, Expertly choose data collection instruments and
accessories to m in imize flight requirements or expertise.

B & N Aerial Inn ovations has experience in similar fields and has adapted this experie nce i n it's use of
UASs to increase safety. In combination to the ever expanding knowlege repositories fro m hobbyists and experts alike, B & N Aerial Inn ovations is constantly evolving it's practices when there is a clear benefit

to operations or increased safety eleme nt.

A. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for public ation in the Federal Register,
should it be determin ed that publication is needed: B & N Aerial Inn ovations {applicant) seeks an exemption from the following rules: 14 C.P.R. §21 , subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 91.103{b); 91.1 09; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91.409 (a) {2) a nd 91.41 7 (a) & (b) to operate commercially a small unmanned vehicle (11kg or less) in elevated p hotographic and remote sensing operations. Approval of exemptions allowing commercial operations of sUASs in the media industry will enhance safety by reducing risk associated with conventional a ircraft operations and other means of elevated remote sensing involving persons. The public benefit served by approval of this p etition is increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer t han 1lkg and powered by sealed batteries eliminates virtually all associated risk inherent in operating convention al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would b e able to
collect needed data. The operation of small UASs, weighting less than 55lbs., conducted in the str ict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptio ns requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations

.

As identified and described herein , Michael Brewer , and her compa ny B & N Aerial Inn ovations

, is an experienced, recogn ized media services professional in the various photographic industries. Mr. Brewer and his companies have been producing and delivering media and tec hnical solutions for the media service industry for ten (1 0) years with a spotless safety record. The FAA has been given the authority to issue the exemption to B & N Aerial Inn ovations pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek y our consideration and approval of this petition.

PIC VLOS Best,

Michael Brewer