April 16, 2015

Exemption No. 11327 Regulatory Docket No. FAA

– 20 15

– 0018

Mr. Michael Harvey Unmanned Aerial Assess ment & Video LLC 5218 S Malaya Way Centennial CO 80015

Dear Mr. Harvey :
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exe mption, including the date it ends.

The Basis for Our Decision

By letter dated December 31, 2014 , you petitioned the Federal Aviation Administration (FAA) on behalf of Unmanned Aerial Assessment & Video LLC ( hereinafter petitioner or operator ) for an exe mption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to conduct s earch and r escue, Hazmat m anagement
( Chemical, Biological, Radiation & Nuclear )

, and e mergency and d isaster r esponse

. See Appendix A for the petitio n submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are DJI Inspires and DJI Phantom 2s or DJI Phantom 2 Visions

.2

The petiti oner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates and any associated noise certification and testing requirements of part 36, is not
necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No. 11062 to Astraeus Aerial ( see Docket No. FAA−2014− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS ope ration enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, an d 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Unmanned Aerial Assessment & Video LLC is granted an exemption from 14 CFR §§ 61.23(a ) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data c ollection

. This exemption is subject to the conditions and limitations listed below.3

Conditions and Limitations

In this grant of exemption, Unmanned Aerial Assessment & Video LLC is hereafter referred to as the operator.

Failure to comply with any of t he conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspires and DJI Phantom 2s or DJI Phantom 2 Vis ions when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are not
p ermitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operat ed at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be opera ted within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s licens e.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the 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 must be designated before the flight and cannot transfer his or her designation for the duration of the f light. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, a re hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and4
limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised docume nts if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its gran t of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight charact eristics, 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 fee t 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.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment . If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must f ollow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia , Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. 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 of training the operator’s PICs and VOs (training, proficiency, and experience

- b uilding) 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 d edicated 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 ac cordance with 14 CFR § 91.119.

15. 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

.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

pub lished 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 of agreement with the airport management must be made available to the Administrat or or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (co nsidering 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 five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traf fic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conduc ted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Statio n of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. 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 su fficiently 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 protecti on and are within 500 feet of the 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 thos e objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons un der this exemption.

27. 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 b e obtained for each flight to be conducted.

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

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.7
If this exemption permits closed

- 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) as documented in this grant of exemption.

30. At least 3 days before aerial filming , the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurren ce of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person respo nsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

- Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or l ocal officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes 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.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/ Jo hn S. Duncan Director, Flight Standards Service12/31/2014

Michael Harvey Unmanned Aerial Assessment & Video LLC 5218 S Malaya Way, Centennial CO 80015

Hon. Michael Huerta Administrator Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Unmanned Aerial Assessment & Video, LLC, a Colorado limited liability company, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow it t o operate a small Unmanned Aircraft System (“sUAS”) under the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airs pace that (1) is limited, (2) is predetermined, and (3) would provide safety enhancements to First Responders on the front lines in our communities . Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilitie s to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Unmanned Aerial Assessment & Video, LLC Attn: Michael Harvey Telephone: (720) 243

- 2775 Email: MichaelHarvey100@yahoo.com Address: 5218 S Malaya Way, Centennial CO. 80015Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3

Appendix 1 describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption.

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Refor m Act, which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Administrator must determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability ; • Operation of the UAS 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).

If the Administrator determines that such vehicles “may operate safely in the n ational airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The Administrator may grant an exemption from a requirement of a regu lation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.2 03 (a) (1).The Petitioner is a startup company, Unmanned Aerial Assessment & Video, LLC, The founder of the

company is a retired Military Veteran with training, both academically and militarily in Emergency Management. Prior to starting Unmanned Aerial A ssessment & Video, LLC, the founder worked as an Emergency Manager in both the Civilian and Military Contractor venues. He is also a certified Hazmat Specialist with over 15 years of experience with CBRN, (Chemical, Biological, Radiation & Nuclear) activit ies. Additionally, the founder has a strong interest in UASs and has been recreationally flying them for approximately 2 years, amassing over 120 hours of flight time.

The Petitioner has formulated a business plan to provide Emergency Management assistanc e to Local, State and Federal entities. The plan is to use small drones for SAR (Search & Rescue), Hazmat/CBRN Management and Emergency & Disaster Response. When responding to an emergency, one of the priorities is to understand how the most critical area s are affected and where they are situated

- before putting any more human lives in danger. The unmanned Drone platform puts the power of aerial intelligence directly into the hands of the first responders. Real

- time video streaming can show not only the e xtent of the damage but may also warn responders of additional hazards. Geo

- tagged digital photographs provide an aerial record of the on

- ground situation completely untouched. It is very improbable for First Responders to acquire, stay trained up on and b e on the leading edge of technology with regards to UASs due to turnover and other training requirements that take priority.

Under the plan, the Drones will be DJI Inspires, DJI Phantom 2s or DJI Phantom 2 Visions, flying below 400 feet above ground level and never within 5 miles from an airport. They will operate only within the line of sight of the operator and will only operate in populated areas for life and safety reasons and under the control of the on

- scene Incident Comma nder. Flights will be remote from noise sensitive areas such as parks, schools, hospitals, and churches. Flights will be only conducted in permissible weather

– rain, snow, or winds above 12 mph will terminate the flights. The Drones will only be operated by the Petitioner who has considerable experience flying UA Drones. Prior to operating the drones all pre

- flight checks will be conducted as per the Petitioners SOP (Standard Operating Procedures). Safety will be the paramount concern in defining flight pr ofiles.

I am aware that this business plan is only permissible if it obtains special permission from the FAA. Many potential competitors of Petitioner are actively flying sUAS, notwithstanding the FAA’s stated prohibition. Petitioner also notes and has r ead the congressional mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic and societal benefits that can result from widespread deployment of sUAS technology. Accordingly, P etitioner applies for authorization under the Federal Aviation Act and the FARs to undertake the following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a significant competitive advantage if it, as it prefers, c omplies with FAA policy.

**Vehicle** The Petitioner will fly one or more DJI Phantom 2s, DJI Phantom 2 Visions equipped with a three

- axis gimbal and camera, small oxygen and radiation sensors and eventually a thermal FLIR for better situational awareness du ring SAR and Wild land Fire mapping missions

.
These vehicles have the built in capability to limit the height they fly above the ground, to limit the radius of the distance they fly from the operator, and to exclude them from class B, C, and D airspace a s well any TFR’s (Temporary Flight Restricted) areas. The vehicles also have the built

- in capability to return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or airspace l imitations programmed into them.The vehicle weighs about five pounds and has a maximum gross weight of approximately twenty

pounds. It has a top speed of about 30 knots. It has four fixed

- pitch rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer smart battery.

**Flight profiles** The petitioner will program the Phantom so that it will not fly more than 400 feet above ground level, or more than 1500 feet away from its operator. The PIC (Person in Control) will carefully preflight the vehicle before each mission to assure that its compass and GPS system are properly calibrated and that the return

- to

- home feature, altitude, and radius limitations work. It will not operate in controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL where the Petitioner is operating its Phantom, the operator will keep both the vehicle and manned aircraft in sight and avoid the manned aircraft.

More particularly, the Petitioner will fly the Phantom only over the hazard areas that are in control of an

on

- scene Incident Commander, most likely being a Fire Chief, SAR rep or Police rep, etc.

**Public interest**

Granting the petition would be in the public interest because:

1. The Congress of the United States h as determined that early accommodation of sUAS into the National Airspace System advances the public interest. The Committee Report leading the House to adopt H.R. 658 said:

"The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support more than 23,000 high

- paying jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a barrier to such job creation . . . ." 1

Granting the Petition represents a step toward such integrat ion, in the absence of a comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in Emergency Response activities, one in which the responders themselves have a tool to safely, quickly and remotely assess a situation without placing lives in harm’s way. In comparison, the EOD robots have saved countless lives since their inception, a feat that will become common place for aerial assessments.

3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating new safety techniques and tactics with new aeronautical technology, thereby improving the efficiency of Emergency Responders around the world and making for a safer society.

The rules from which Petitioner seeks exemption artificially and irrationally limit the effective use of new technologies to expand Emergency Response safety and improve the efficiency of markets, thereby subverting the public interest.

_____________________________________________ 1. H. R. Rep. 112

- 29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House

- Senate Conference Committee on the FAA Modernization and Reform Act of 2012 recommended amendments to H.R. 658 in lieu of amendments ad opted by the Senate. Conference Report to Accompany H.R. 658, H.R. Rep. 112

- 381, 112th Cong., 2d Sess., at p. 1 (Feb. 1, 2012).4. Granting the Petition will enable the Petitioner to demonstrate that Wounded War Veterans , as I am,

can still thrive and be a part of the business community, regardless of any setbacks they may endure. This alone is in keeping with the Presidents stated ideology as well as the Veterans Administrations vision and in the public’s interest.

5. Granting the Petition will fulfill t he FAA’s own declaration that encouraging new aviation technologies advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging and developing civil aeronautics, including new aviation technology." 2 Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the United States because of the rapid pace of innovation in aeronautical and associated technologies, followed by their commerci alization and their introduction into the marketplace. The drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from using this in air commerce subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, specifically recognizes the advantages to air com merce obtainable from the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the availability of these technologies in the National Airspace System, thereby representing a congressional determination that the public interes t is served by making these technologies more widely available at the earliest practicable date. The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional mandate and meeting its obligation to enhance the pub lic interest by making new technologies available by allowing the use of sUAS technologies in a manner that protects the public and the rest of the aviation community from significant risk.

The commercial activities by Petitioner proposed in the Petition represent contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act.

7. Granting the Petition will enhance aviation safety, thereby advancing the public interest. The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the National Airspace System and to persons and property on the ground. Many others are flying sUAS without regard to these hazards. Granting the Petition will offer the Peti tioner up as an example of how the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS operations.

Users of th e National Airspace System are confronted by mushrooming threats from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying the hazards to manned aircraft and to persons and property on the ground.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act relating to size, weight, speed, operating capabiliti es, proximity to airports and populated areas and operation within visual line of sight, and national security. The Petition justifies grant of the requested exemptions to allow the Petitioner to engage in Emergency Response procedures using small Drones.

_____________________________________________ 2 FAA, Safety: The Foundation of Everything We Do, http://www.faa.gov/about/safety_efficiency/

.Respectfully submitted,

Michael Harvey Unmanned Aerial Assessment & Video LLC

Appendix 1**FAR section Subject**  **Justification**

**14 CFR § 45.23(b) Requirement to display**  **registration number on vehicle Insufficient space on vehicle** 

**14 CFR Part 21 Aircraft certification**  **requirements and procedures Designed for manned aircraft;**  **not suitable for off**

**- the** 

**- shelf** 
**sUAS 14 CFR § 61.3**  **Requirement for pilot certificate**  **Part 61 requirements designed for manned aircraft, not sUAS;**  **petition describes training for sUAS operator**  **14 CFR § 91.7 (a) Airworthin**  **ess requirement Designed for manned aircraft;**  **not suitable for off**

**- the** 

**- shelf** 
**sUAS 14 CFR § 91.9 (b) (2)**  **Requirement for manual to be available in the cockpit**  **No one aboard to read manual**

**14 CFR § 91.103(b) Requirement for crew** 
**members to be onboard Unmanned vehicle** 

**14 CFR § 91.109 Requirement for dual controls**  **during flight instruction No one aboard to operate** 
**controls 14 CFR § 91.119**  **Minimum altitudes for safe flight**  **Safety requires operation**
**below these altitudes 14 CFR § 91.121**  **Altimeter settings No one aboard to read** 
**altimeter 14 CFR § 91.151(a)**  **Fuel requirements Vehicle does not use fuel**  **14 CFR § 91.203 (a) & (b) Requirement for registration**  **and airworthiness certificates**
**to be onboard No one aboard to read**  **certificates**

**14 CFR § 91.205(b) Cockpit instruments**  **No one aboard to read**
**FAR section Subject**  **Justification 14 CFR § 45.23(b)**  **Requirement to display registration number on vehicle**  **Insufficient space on vehicle**

**14 CFR Part 21 Aircraft certification**  **requirements and procedures Designed for manned aircraft;**  **not suitable for off**

**- the** 

**- shelf** 
**sUAS 14 CFR § 61.3**  **Requirement for pilot certificate**  **Part 61 requirements designed for manned aircraft, not sUAS;**  **petition describes training for sUAS operator**  **14 CFR § 91.7 (a) Airworthiness requirement**  **Designed for manned aircraft; not suitable for off** 

**- the** 

**- shelf** 
**sUAS 14 CFR § 91.9 (b) (2)**  **Requirement for manual to be available in the cockpit**  **No one aboard to read manual**

**14 CFR § 91.103(b) Requirement for crew** 
**members to be onboard Unmanned vehicle** 

**14 CFR § 91.109 Requirement for dual controls**  **during flight instruction No one aboard to operate** 
**controls 14 CFR § 91.119**  **Minimum altitudes for safe flight**  **Safety requires operation**
**below these altitudes 14 CFR § 91.121**  **Altimeter settings No one aboard to read** 
**altimeter 14 CFR § 91.151(a)**  **Fuel requirements Vehicle does not use fuel**  **14 CFR § 91.203 (a) & (b) Requirement for registration**  **and airworthiness certificates**
**to be onboard No one aboard to read**  **certificates**

**14 CFR § 91.205(b) Cockpit instruments**  **No one aboard to read**