Sir/Maam,

The following is the information needed to comply with the requirements of 1 1.81.

"The reason wh y granting the request would be in the public interest; that is, how it would benefit the public as a whole"

This exemption would allow me to of f er the service of aerial video/photography through m y business "Marks Service Center located at 342 US Route 1 1 Central Square, NY 13036." There is a growing public demand for professionally shot and edited aerial video content and obtaining this exemptio n would allow us to satisfy that need for our customers.

"The reasons wh y the exemption would not adversely af fect safet y"

THE APPLI CABLE LEGAL ST ANDARD UNDER SECTI ON 333 Mark Martino Jr./Mark's Service Center Inc. submits that grant of this exemption ap plication for use of the proposed UAS's in of aerial photography , aerial videography

, and aerial inspections, and other sUAS flight operations will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs in to the national airspace s ys tem (“NAS”) if it can be accomplished safely

. This law directs the Secretary of T ransportation to consider whether certain UASs may

operate safel y in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which t ypes of UASs do not create a hazard to users of the NAS or the public or pose a threat to national securit y in light of the following: • The UAS’ s size, weight, speed, and operational capability ; • Operation of the sUAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator

. Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may oper ate safel y in the national airspace s ys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace sy stem.” Id. §333(c) (emphasis added).1 The Federal Av iation Act expressly grants the F

AA the authorit y to issue exemptions. This statutory authorit y, by

its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may

grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or an y of sections 44702

- 44716 of this title if the Administrator finds the exemption is in the public interest.

1 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the condition s proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the UAS. ark Martino Jr./Mark's Service Center Inc. welcomes the opportunity to consult with F

AA staf f in order to address any

issues or conce rns that this proposal may raise that they

believemay

require modification. 49 U.S.C. §44701(f). See also 49 USC §4471 1(a); 49 USC §44704; 14 CFR §91.203(a)(1). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Av iation Act, as amended; 4 the strong equivalent level of safet y surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings a ssociated with transitioning to UASs for aerial photography , aerial videograph y, and aerial inspections and other . Accordingly

, the applicant respectfull y requests that the F AA grant the requested exemption without delay

. Airworthiness of the sUAS A criti cal element of the exemption application involves evidence of the airworthiness of the sUAS. The Federal Av iation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the F

AA to exempt aircraft from the requirement for an airworthines s certificate, upon consideration of the size, weight, speed, operational capability , and proximity

to airports and populated areas of the particular sUAS. Our small UAS's will operate at low speed in a controlled environment, at least five miles from an a irport. An anal ys is 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 conventional aircraft (fixed wing or h elicopter) operating with an airworthiness certificate without the restrictions and conditions proposed.

RI SK MITIGA

TI ON Mark Martino Jr./Mark's Service Center Inc., has reviewed F AA exemptions references 1

- 3 Condition and L imitations sections and believe s that procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safet y. A preflight checklist developed and employ ed to ensure that the sUAS airworthiness will be verified before launch. Airworthiness will be maintained b y performance of routine inspections before each flight, maintaining flight and maintenance logs to record time failure prone components. Mark Martino Jr./Mark's Service Center Inc. requests that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written approval from the F

AA. The UA

may not operate within 5 nautical miles of the geographic center of a nontowered ai rport as denoted on a current F AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conducted accordance with a NOT

AM as required b y the operator ’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.” Operations within five (5) miles of an airport are not anticipated to be routine, but Mark Martino Jr./Mark's Service Center I nc. is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within Class B airspace are not requested due to lack of mode C transponder

. Mandatory

Operating Conditions (see O&M and Safet y Lists) Grant of the exemption t o Mark Martino Jr./Mark's Service Center Inc. will be subject to the followingmandatory

conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional

res trictions:

• All operations to occur in Class G airspace. • Operations to be conducted over private or controlled

- access property

. • Permission from land owner/controller required before commencing an y flight.

5 • Operations to occur during V isual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Vi sual L ine of Sight (VLOS).

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline a zimuth of runway centerline measured from runway thresholds.

• All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. O perator Requirements Mark Martino Jr./Mark's Service Center Inc. respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain UASs, such as the DJ I Phantom 3 Advanced, is characterized b y a h ig h degree of control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. Please see details in the attached O&M manuals for each in Appendix B. Additional automated safety functions and safet y enhancing features of the sUAS's include the following:

• Auto

- pilot detection of lost GPS or of insuf ficient satellites initiates an immediate return to aircraft take

- of f location ("home") • L ow power on the aircraft triggers escalat ing alarms at GCS at 35% and 10% levels. • If the auto

- pilot detects a lost

- link to the GCS for longer than 30 seconds, landing procedure begins. Given these safet y features, Mark Martino Jr./Mark's Service Center Inc. proposes that operators of the sUAS s hould not be required to hold a commercial or private pilot certification. Instead, operators should be required to: • have successfull y completed, at a minimum, F AA private pilot ground school instruction and passed the F AA Private Pilot written examinati on or F AArecognized equivalents; • have completed the manufacturer ’s training or a minimum of 40 hours training program for operation of the sUAS's.

Mark Martino Jr./Mark's Service Center Inc. notes that the F AA has found that safet y factors permitted
ope ration of sUASs b y operators with these qualifications in the case of operations pursuant to public COAs when the mandatory

operating conditions specified above were present. See Federal Av iation Administration, Notice N

- 8900.227, Unmanned Aircraft Sy stems (UAS) Operational Approval, at 20

- 21 (July

30, 2013). The F

AA has the statutory

authority to grant exemptions to the requirements for and privileges associated with the grant of airmen’ s certificates. 49 USC§44701 (f).

* * *

In summary

, applicant seeks an exemption from the F ARs set forth above and in Appendix A to allow commercial operations of a sUAS's conducting precision aerial inspections or surveys. 6 Approval of the exemption allowing commercial operations of the sUAS for precision inspection and survey

work will enhance safet y b y reducing risk. Conventional aerial photography , aerial videograph y and aerial inspection operations, using helicopter or piston

- powered aircraft present risks associated with vehicles that weigh in the neighborhood of 5,0 00 to 7,000 lbs., or
more, carry

large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the location. Other conventional manned climbing or manned lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards, and inhalation hazards associated with the structures being inspected. In contrast, a sUAS weighing less than 25 lbs. and powered b y batteries eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board a manned aircraft and the lack of risks associated with manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft fligh ts, manned lifts or climbing hazards. Additionally

, no national securit y issue is raised b y the grant of the requested exemptions. Given the size, load carry ing capacity , speed at which it operates, and the fact that it carries no explosives or other dange rous materials, the sUAS poses no threat to national security

. The operation of the sUAS, weighing less than 25 lbs., for aerial photography , aerial videography

, and aerial inspections in accordance with the strict conditions outlined above, will provide an equivalent level of safet y supporting the grant of the exemptions requested herein, including exempting Mark Martino Jr./Mark's Service Center Inc. from the requirements of Part 21. The sUAS’ s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports, operation within visual line of sight, and national security

— and its showing of an equivalent level of safet y as it may relate to the requirement for F

AA training, provi de more than adequate justification for the grant of the requested exemptions allowing commercial operation of the sUAS in the commercial aerial photography

, aerial videography

, and aerial inspections business. Mark Martino Jr./ Mark's Service Center Inc. is requesting this exemption for the purpose of aerial photography

, aerial videography

, aerial inspections and other flight operations that may arise. The reason for such a general based exemption request is to integrate a horizontal business model in orde r to capitalize on vast opportunities in the future without delay in additional exemption requests.

EXEMPTION REQUESTA ND EQUIV

ALENTL EVE L OF SAFETY SHOWI NGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION Mark Martino Jr./Mark's Service Center Inc. reques ts an exemption from the following regulations as well

as an y additional regulations that may technicall y apply to the operation of the sUAS's: 14 C.F .R. § 45.23(b): Marking of the Aircraft The regulation provides:When marks include only the Roman capital letter “N” and the registration

number is display ed 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, o r 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. The sUAS's has no entrance to the cabin, cockpit, or pilot station on which t he 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 forward fuselage in compliance with § 45.29(f). The equivalent level of safet y will be achieved b y having the sUAS marked on its forward fuselage as required b y § 45.29(f) where the pilot, observer, and others working with the UA V will see the identification of the sUAS as “Experimental.” The F AA has issued the following exemptions to this regulation to Aeria l Pros, Exemption No. 10700, and to others, including Exemption Nos. 8738, 10167 and 10167A. 14 C.F .R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requireme nts for the issuance of airworthiness certificates as required by F AR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Mark Martino Jr./Mark's Service Center Inc., an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safet y under Part 1 1 and Section 333 of the Reform Act. The Federal Av iation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the F AA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity

to airports of the particular UAS. Our small sUAS's will be operated at low speed in a controlled environment, at least five miles from an airp ort. An anal ys is of these criteria demonstrates that the sUAS's 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 h elicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor
passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and under 9 the requirements and in compliance with local public safet y requirements, to provide security for the area of operation as is currentl y done on active construction sites. These safet y enhancements, which alread y appl y to civil aircraft operated in connection with construction sit es, power plant sites and the like provide a greater degree of safet y to the public and propert y owners than conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly , application of these same crit eria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater th an two lbs. 14 C.F .R. § 61.1 13(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Section 61.1 13(a) & (b) limit private pilots to non

- commercial operations. Unlike a conventional ai rcraft that carries a pilot, passengers, and cargo, the sUAS in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a)requires an individual with a commercial pilot’ s license to be pilot in command of an airc raft

for compensation or hire. Mark Martino Jr. Mark'Service Center Inc. respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Mark Martino Jr./Mark's Service Center Inc. sUAS has a high degre e of control and various built

- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. The sUAS has navigation and control s ys tem comprised of a Ground Control St ation (GCS) and
auto

- pilot sy stem. All flights utilize precision GPS guidance. In the case of unplanned events, the operator inputs evasive maneuvers from the control unit, and the control unit executes that

maneuver. Operator interventions include diversi on to the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut of f and land (Flight Te rmination Sy stem). Given these safet y features, Mark Martino Jr./Mark's Service Center Inc. proposes that operators of the sUAS should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: • have successfull y completed, at a minimum, F AA private pilot ground instruction and passed the F AA Private Pilot written examination or F AA

- recognized equivalents; • have completed manufacturer's training program or a minimum 40 hours training program for operation of the UAS. Mark Martino Jr./Mark's Service Center Inc. notes that the F AA has found that safet y factors permitted operation of sUASs b y operators with these qualifications in the case of operations pursuant to public COAs where the mandatory

operating conditions specified above are present. See Federal A viation Administration, Notice N

- 8900.227, Unmanned Aircraft Sy stems (UAS) Operational Approval, at 20

- 21 (July

30, 2013). The F

AA has the statutory

authority , granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the sUAS without a private pilot’ s certificate or a commercial pilot’ s certificate, under the conditions set forth herein. 10 The risks associated with the operation of the sUAS (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level of safet y provided under 14 C.F .R. § 61.1 13(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a). 14 C.F .R. § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the sUAS without an airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size of the aircraft and the requirements that have presumably alread y been met for the sUAS (for instance, the sUAS’ s Operations and Maintenance Manual and Safety Manual and Checklist), an equivalent level of safety will be achieved by

insuring compliance with the Mark's Service Center In c. manuals prior to each flight.14 C.F .R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulat ion provides: No person may

operate a U.S.

- registered civil aircraft ... For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 (2) of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Fligh t Manual, approved manual material, markings, and placards, or an y combination thereof. Given the size and configuration of the sUAS, it 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 safet y will be achieved b y keeping the flight manual (see, e.g., User Guide, Exhibit 4) at the ground control point where the pilot fly ing the sUAS will have immediate access to it. The F AA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 14 C.F .R. 91.103: Preflight Action This regulation requi res each pilot in command take certain actions before flight to ensure the safet y of flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual and Safety Checklists. These actions will provide an equivalent level of safety

. 14 C.F .R. § 91.109(a) & 91.319(a)(1): Flight Instruction T hese regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. 11 The sUAS is a remotel y piloted aircraft and b y design , does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safet y will be assured. The F AA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. Th e equivalent level of safet y will be achieved b y the manufacturer providing the training as outlined. 14 CFR § 91.1 19: Minimum Safe Altitudes Section 91.1 19 establishes safe altitudes for operation of civil aircraft. Specifically , 91.1 19(c) limits aircraft fl yi ng over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. As set forth herein, the sUAS will never operate at higher than 400 feet AGL. Because aerial photography

, aerial videography

, and aerial inspections must be accomplished at relativel y low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.1 19(c) is needed. 14 C.F .R § 91.121 Altimeter Settings Mark Martino Jr./Mark's Service Center Inc. requests an exemption from 14 C.F .R. 91.121. This Part provides guidelines for altimeter use below 18,000 feet mean sea level (“MSL ”) in main taining the cruising altitude or flight level of the aircraft. Mark Martino Jr./Mark's Service Center Inc. operation of the sUAS will notexceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight such as a manned aircraf t will ty picall y fl y. The ground station has live feedback and GPS information about the sUAS, including but not limited to the height of the sUAS, its forward velocity , and compass heading. The operator will be able to observe and control the maximum heig ht of the sUAS. Additionally
, the sUAS will be operated within the line of sight. Therefore, the equivalent level of safet y provided b y Section 91.121 will be met. 14 C.F .R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohib its 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 fl y after that for at least 45 minutes.” The sUAS batteries provide approximately 15

- 30 minutes of powered flight. Wi thout an exemption from § 14 CFR 91.151, the sUAS’ s flights would be l imited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in day light VFR conditions is reasonable. Mark Martino Jr./Mark's Service Center In c. believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel does not engender the ty pe of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo 12 also enhances its safety

. Additionally

, limiting sU AS flights would greatly reduce their utility

. In the unlikely

event that the sUAS should run out of battery charge, it would simply

land. Given its weight and construction material, the risks are less than contemplated b y t he current regulation. Mark Mart ino Jr./Mark's Service Center Inc. believes that an equivalent level of safet y can be achieved by maintaining 10 minutes of reserve battery , which, allows approximately 30 minutes of flight time, but Mark Martino Jr./Mark's Service Center I nc. limits all f lights to no greater than 20 minutes, would be more than adequate to return the sUAS to its planned landing zone from an ywh ere in its operating area. 14 C.F .R. § 91.203 (a) & (b): Carry ing Civil Aircraft Certification and Registration This regulation provi des as follows: (a) . . . no person may

operate a civil aircraft unless it has . . . an appropriate and current airworthiness certificate. (b) No person may

operate a civil aircraft unless the airworthiness certificate required b y paragraph (a) of this sec tion 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's fully

loaded weighs no more than 25 lbs. As such, there is no ability or place to

carr y certif

ication and registration documents or to display them on the sUAS. I n addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot fl yi ng the sUAS w ill have immediate access to them. The F AA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F .R. § 91.405(a); 407(a)(1); 409( a)(2); 417(a) & (b): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspectedas prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph ( c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to ser vice. Maintenance of the sUAS's will be accomplished by the owner/operator pursuant to the manuals. An equivalent level of safet y will be achieved because the sUAS is small in size, will

carr y no external pay load, will operate onl y in restricted predetermi ned areas and is not a complex mechanical devise. As provided in the attached Maintenance Manual and the Safet y Checklist, the trained operator of sUAS will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworth y condition and to ensure an equivalent level of safety

. 13 APPENDIX B SUMMA RY OF TRIMBLE SECTION 333 EXEMPTI ON REQUEST Mark Martino Jr./Mark's Service Center Inc. hereby provides pursuant to Part 1 1 a summary of its exemption application to allow commercial operation of the DJ I Phantom 3 Advanced sUAS's for aerial photography

, ae rial videography

, and aerial inspections. An exemption is requested from the following regulations: 14 C.F .R. Part 21; 14 C.F .R. 45.23(b); 14 C.F .R. 61.1 13(a) & (b); 14 C.F .R. 61.133(a); 14 C.F .R. 91.7(b); 14 C.F .R. 91.9(b)(2); 14 C.F .R. 91.109(a); 14 C.F

. R. 91.1 19; 14 C.F .R. 91.121; 14 C.F .R. 91.151(a); 14 C.F .R. 91.203(a) & (b); 14 C.F .R. 91.405(a); 14 C.F .R. 91.407(a)(1); 14 C.F .R. 91.409(a)(2); 14 C.F .R. 91.417(a) & (b).