October 1, 2015

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, RoomW12
-140 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 61.113(a) and (b); 14 CFR91.7(a); 14CFR 91.9(b)(2); 14CFR91.103; 14CFR 91.109; 14CFR91.119(c); 14CFR 91.121; 14CFR 91.lSl(a); 14CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b). Dear Sir or Madam: Tel
-Tec Security Systems Inc., respectfully requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.), specifically portions of 14 C.F.R. Parts 45 and 91, to permit the use of our small Unmanned Aerial System (UAS), the Monarch Ag, for use in aerial survey of agriculture plots in remote and rural areas of the United States. Granting an exemption is consistent with Congress’ intent, as reflected in Section 333 of the FAA Modernization and Reform Act of 2013, that safe systems be permitted in the National Airspace (NAS) prior to the issuance of final regulations governing general use of these small unmanned aerial systems. Tel
-Tec Security Systems Inc. owns and operates a Monarch One UAS which is an all
-environment, electric
-powered, self

-launched, small multirotor UAS that, depending on its payload, is capable of collecting airborne images and location information to a Ground Control Station (GCS). It can also conduct high
-resolution photogrammetry or perform Light Detection and Ranging (LIDAR) data collection. If used for high
-resolution photographs or LIDAR data, the Monarch One stores the photographs and imagery data onboard and makes it available for download after completion of the flight. The Monarch One has a maximum weight of 15 pounds and a diameter of 51.5 inches, with a maximum cruising speed of 15mph. It is battery powered, has a maximum flight time between twenty (20) and twenty five (25) minutes, and can operate in temperatures ranging from 14°F to 122°F. The Monarch one has two omni
- directional antennas, a primary and a redundant backup. The primary 9.5 MHz antenna has a range of 6.2 miles, and the 2.4 GHz backup antenna has a range of 1.4 miles
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14CFR Part 11, Tel
-Tec Security Systems, Inc., operator ofanUnmannedAircraft System (UAS), hereby applies for an exemption from the listed FederalAviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established bythe FAA as required by Section 333.Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and

sensors, would operate inthe following manner: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 6. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection ofthe persons and property. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions inthe NAS that would be a) limited, b) controlled, c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "
....establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system." The name and address ofthe applicant is: Tel
-Tec Security Systems, Inc Attn: Morgan Clayton Ph# (661) 397
-5511 Email: Morgan.clayton@tel
- tec.com Address: 5020 Lisa Marie Court, Bakersfield, CA 93313 Regulations from which the exemption is requested: 14CFRPart21subpart H 14CFR45.23 (b) 14CFR 61.113 (a) & {b)14 CFR 91.7 (a)

14CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14CFR91.119 (c) 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a) & (b) 14CFR91.405 (a) 14CFR 91.407 (a) (1) 14CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) Tel
-Tec Security Systems, Inc. proposes to operate a UAS, the Monarch 1 (MMMMMMM) as specified below: Monarch is an industry leader in small UAS production. Monarch UASs are loaded with ground breaking software enabling the user to set parameters 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. Inaddition, Monarch software provides real
-time altitude and location information to the PIC via the linked monitor telemetry device. **Monarch One**  **Specifications** Aircraft Model Monarch One Weight (BatteryIncluded)
- 15lbs HoveringAccuracy(GPSMode)
-Vertical: 2.5m; Horizontal: 2.5m Max Angular Velocity
- Pitch: 90°/s; Yaw: 90°

/s Max TiltAngle
- 45° MaxAscent Speed 1.25 m/s

– Max Descent Speed .5 m/s Max Speed
- 15 mph Max FlightAltitude
-4500m Max Flight Time
-Approximately 20
-25minutes MotorModel

–Avroto 3515 PropellerModel

–APC 16x4.5 MR Operating Temperature Range
-14°F to 122°F Dimensions

–51.5."x 51.5%"x 18" **Transmitter** OperatingFrequency
- 2.4 GHz; 2.400
-2.483GHz Communicating Distance (unobstructed)
- 805m OutputPower
-9W Operating Temperature Range
-14°F to 122°F Given the small size ofthe UAS and the controlled environment provided the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regardingthe level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limitedto reduced emissions and noise, the grant ofthe requested exemption is inthe public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.**AIRCRAFT AND**  **EQUIVALENT LEVEL**  **OF SAFETY** 

The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations underthe FAA issued exemption as set forth inthe Flight Operations Manual (FOM) include: 1. Aircraft shall weigh less than 55 pounds including payload. 2. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 3. The UA will be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 4. The UA will be operated within visual line ofsight (VLOS) of the PIC at all times and 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 or U.S. driver's license. 5. All operations will utilize a visual observer (VO). The UA will be operated within the visual line ofsight (VLOS) ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required ofthe VO. 6. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 7. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 flight.9. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components. 10. The UAS operator will comply with all manufacturer safety bulletins. 11. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 12. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs (training, proficiency, and experience
building) and determining the PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience
-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91. 119. 13. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 14. The UA may not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA
-published aeronautical chart, unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 15. 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. 16. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled
-access property. 17. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer ifgreater.18. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA). All operations

shall be conducted in accordance with an ATO
-issued COA. 19. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N
-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 20. Documents used by the operator to ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. 21. These documents must be made available to the Administrator or any law enforcement official upon request. 22. The UA must remain clear and give way to all manned aviation operations and activities at all times. 23. The UAS may not be operated by the PIC from any moving device or vehicle. 24. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard. 25. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 26. All operations shall be conducted over private or controlled
-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe 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 on the NTSB Web site: www.ntsb.gov. 28. For operations for the purpose ofclosed
-set motion picture and television filming and production, the following additional conditions and limitations apply.29. The operator must have a motion picture and television operations manual (MPTOM)

documented as follows: 30. At least 3 days before aerial filming, the operator ofthe UAS must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofproposed filming. The 3
-day notification may be waived with the concurrence ofthe FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number ofthe operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number ofthe person responsible for the on-scene operation ofthe UAS; d. Make, model, and serial orN
-Number of UAS to be used; e. Name and certificate number ofUAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list ofthose who gave permission must be made available to the inspector upon request; g. Signature ofexemption holder or representative; and h. A description ofthe flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitude essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.
**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 with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese 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 conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and incompliance with local public safety requirements. These safety enhancements provide a greater

degree of safety to the public and property owners than 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 UAS, due to its size, speed ofoperation, location of operation, lack of 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 the cabin, 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. Eventhough the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “experimental" can be placed. Giventhe size ofthe LIAS, two-inch letteringwill be impossible. The word "Experimental" will be placed onthe fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by havingthe UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe LIAS as "Experimental." **14 C.F.R.**  **§ 61.113**  **(a) and**  **(b): Private**  **Pilot Privileges**  **and Limitations:**  **Pilot in**  **Command.** Pursuantto 14CFR 61.113 (a) & (b), no personwho holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or property for compensation or hire. Tel
-Tec Security Systems Inc. may achieve an equivalent level ofsafety as achieved bycurrent Regulations becausethe applicant's UAS do notcarry anypilots or passengers norproperty. The risks attendant to the operation ofLIAS is far less than the risk levels inherent inthe commercial activities outlined in 14CFR 61. The PIC ofthe UAS will have a Private Pilot's License along with a current State of California Driver’s License complying with the current safety levels in relationto 14 CFR 61.113 (a) & (b). Ifeel the operation and limitations set forth inthe FOM will equate to the safe operation ofthe UAS. **14 C.** **F .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 the size ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided. **14 C.F.R.**  **§ 91.9**  **(b )**  **(2): Civil** **Aircraft Flight**  **Manual in** **the Aircraft.**  Section 91.9 (b) (2) provides: No person may operate a U.S.
-registered civil aircraft
... (2) For whichan Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, 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 on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. **14 C.** **F .R.**  **§ 91.103:**  **Preflight Action.**  This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PICwill take all actions as stated inthe FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing andtakeoff distances and aircraft performance data before initiation of flight. **14 C.** **F .R.** **§91.109: Flight**  **Instruction.** Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio telemetry communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety provided bythe fact that neither a pilot nor passengers will be carried inthe aircraft and bythe size and speed ofthe aircraft. **14 C.** **F .R.** **§91.119: Minimum**  **Safe Altitudes.**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved giventhe size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants inthe filming activity, all affected individuals willbe aware ofthe planned flight operations. Compared to flight operations with aircraft or

rotorcraft weighting far more than the maximum 55lbs. proposed herein andthe lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. Inaddition, the low
-altitude operations of the UAS will ensure separation betweenthese UAS operations and the operations ofconventional aircraft that must comply with Section 91.119. **14 C.F.R.**  **§91.121 Altimeter**  **Settings.** 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 UAS 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 safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. **14 C.F.R.**  **§ 91.151(a):**  **Fuel Requirements**  **for Flight**  **in VFR**  **Conditions** Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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 that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 15 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in atightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 15 minutes would greatly reduce theutilityforwhichthe exemptionwill begranted. Applicant believesthat an equivalent level ofsafety can be achieved bylimitingflights to 30 minutes or25% ofbatterypower- whichever happens first. This restrictionwouldbemorethanadequatetoreturntheUASto itsplanned landingzonefrom anywhere initslimitedoperatingarea. **14 C.F.R.**  **§91.203 (a** **) and**  **(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 required by paragraph (a) ofthis section or a special flight authorization issuedunder §91.715 is displayed atthe cabin or cockpit entrance so that itis legible to passengers or crew. The UAS fully loaded

weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level ofsafety will be achieved by keepingthese documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. **14 C.F.R.**  **§91.405 (a);**  **407 (a) (1);**  **409 (a)**  **(2); 417(a)**  **& (b):**  **Maintenance Inspections.**  These regulations require that an aircraft operator or owner "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 inpart43 ofthis chapter
...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished bythe operator pursuant to the flight manual and operating handbook. An equivalent level ofsafety will be achieved becausethe UAS isvery limited in size andwill carry a small payload and operate only inrestricted areas for a limited period oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafety will be achieved because maintenance and inspections will be performed inaccordance with the UAS Manufacturer's User Manual. As provided inthe FOM, the operator will ensure that the UAS is inworking order prior to initiating flight and perform required maintenance needed. **Additional Information**  The applicant, Tel
-Tec Security Systems, Inc. has one commercial rated MEL CFI Pilot under contract and two private pilots in its employ. The two private pilots both currentlyhold a SEL, Private Pilots Certificate, one pilotwith an Instrument rating. All three Pilots have an in
-depth understanding ofthe capabilities and safety concerns involved inusingthis technology as an asset to the community. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UAS. Sincerely, Morgan E. Clayton, President, Tel
-Tec Security Systems, Inc
. 5020 Lisa Marie Court. Bakersfield Ca. 93313