St Louis Aerial Photography Bob Krull 10812 Arnett Drive St Louis, MO 63123 Telephone: 314-892-1233 Email: stlouisaerialphotography@gmail.com

April 20, 2015 U. S. DepartmentofTransportation Docket Management System West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE Washington DC 20590



### RE: Exemption RequestSection 333 ofthe FAA ReformAct Dear Sir or Madam: We respectfully request exemption under Section 333 ofthe FAA Reform ACT and Part 11 ofthe Federal Aviation Regulations. Petitioner: St Louis Aerial Photography Bob Krull 10812 Arnett Drive St Louis, MO 63123 Telephone: 314-892-1233 Email: stlouisaerialphotography@gmail.com STLAP is a small business. STLAP intendsto incorporate the use ofsUASs for a variety of projects which may include but not be limited to project and construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and rescue, etc. Specific Section(s} seeking exemption: 14C.F.R Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2)

### 14C.F.R. 91.109 U. S. DepartmentofTransportation Docket Management System April 20, 2015 Page Two 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) and (b) 14 C.F.R. 91.215 14 C.F.R. 91.104 through 91.417 Extend of relief requested: 

### To permit commercial operation ofSmall Unmanned Aircraft Systems (sUASs) for operations conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333. Said exemption would permitthe operation ofsUASs under controlled conditions in limited, predetermined and controlled airspace. Upon grantingofthis proposed exemption request, STLAP would conduct commercial operations ofsUASs meeting or exceeding all operational and safety requirements per Section 333. Public Benefit: 

### 1. Project and construction management, inspections and monitoring. The use ofsUASs on construction sites may improvethe safety ofworkers, local residents and general public by assessing potential dangerous situations. Falls and injuries may be reduced or eliminated through a morethorough review ofthe construction sites. In some cases, sUASs may reduce the reliance of helicopters orsmall aircraftto monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy usage; 2. Environmental Review projects. The use ofsUASs duringthe process of reviewing projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review ofthe project site as well as surrounding areas. Reliance of helicopters orsmall aircraft may be eliminated; 3. Aerial surveying. The use ofsUASs in connection with aerial surveying ofsmaller areas may eliminate the use of helicopters oraircraft. This could provide a more cost effective, safer and more energy efficient product;

### 4. Agricultural projects. Wildlife and Forestry projects. The use ofsUASs could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information when problems occur, vermin infestation, fire hazards, etc.; 5. Remote Sensing projects. The use ofsUASs could provide views and information for remote and inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft; U.S. DepartmentofTransportation Docket ManagementSystem April 20, 2015 Page Three 6. Educational and Research projects. The use ofsUASs could provide information for said projects in a more cost effective and efficient mannerthan otheravailable options; 7. Aerial filmmaking, photography and real estate purposes. The use ofsUASs may provide a point of view previously unavailable through other means. They would be more cost effective, efficient and more safely than helicopters and aircraft; and 8. Search and rescue. The use ofsUASs may provide assistance to local law organizations during search and rescue missions. SUASs may reach areas unattainable orviewable with helicopters and aircraft. SUASs may be implemented quicker as time is ofthe essence duringsearch and rescue operations. Reasons whythe exemption would notadversely affect safety or howthe exemption would provide a level ofsafety at least equal tothe existing rule. 

### Proposed operations using sUASs provide increased safety enhancement especiallywhen compared with helicopters and aircraftforthe following reasons: 

### 1. The sUASs will weigh less than ten (10) pounds; 2. Flights will be operated within the visual line ofsight ofthe pilot; 3. Maximum total flighttime for each operational flightwill bethirty (30) minutes. Flighttimes may be less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return tothe ground station with at least 20% battery power reserved; 4. Flights will be operated at an altitude of200 feet AGL. Flights will never exceed 400 feet AGL; 5. Minimum crewfor each operation will consist ofthe sUAS pilot and aVisual Observer; 6. A briefingwill be conducted daily by all personnel workingwith said sUAS; 7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent will be required ofall persons within 100feet offlight operation; 8. Written and/or oral permission from relative property owners will be obtained priorto operatingthe sUAS;I \

9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and 11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and horizontally; 12. The sUAS will have the capability to return and land atthe pre-determined location with the Security Perimeter should the sUAS lose communication or GPS signal duringany operations; 13. The sUAS will have the capabilityto abortaflight in case of unpredicted obstacles or emergencies; 14. Operations will not be conducted over densely populated areas or heavilytraffic highways; and U. S. Department ofTransportation Docket ManagementSystem April 20, 2015 Page Four 15. Operations will not be conducted within five (5) NM ofan airport or heliport. STLAP will abide by all regulations includingthefollowing: 1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates; 2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations; 4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 5. 14 C.F.R. 91.9 Civil aircraftflight manual, marking and placard requirements; 6. 14 C.F.R. 91.109 Flight instruction; Simulated instrumentflight and certain flighttests; 7. 14 C.F.R. 91.119 Minimum safe altitudes: general; 8. 14 C.F.R. 91.121 Altimetersettings; 9. 14 C.F.R. 91.151 Fuel requirements forflight in VFR conditions; 10. 14C.F.R. 91.203 Civil aircraft: Certifications required; 11. 14C.F.R. 91.205 Powered civil aircraftwith standard category U.S. airworthiness certificates: Instrument and equipment requirements; 12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 13. 14C.F.R. 91.401 Applicability; 14. 14C.F.R. 91.403 General;l '

15. 14C.F.R. 91.405 Maintenance required; 16. 14C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding oralteration; 17. 14C.F.R. 91.4091nspections; 18. 14C.F.R. 91.411 Altimeter system and altitude reporting equipmenttests and inspections; 19. 14C.F.R. 91.413 ATC transpondertests and inspections; 20. 14C.F.R. 91.415 Changes to aircraft inspection programs; and 21. 14C.F.R. 91.417 Maintenance records.

Equipment and Specifications. 3DR SOLO**KIT~** 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set- Black, 3DR Solo Battery Charger, 3DR Solo Controller Charger Specifications: Up to 26 minutes offlighttime (20 with camera and Solo Gimbal), HD video streamingto mobile Top speed: 55 mph MaxAltitude: 400ft, per FM rules Weight: 1600 g; 1760 gwith Solo Gimbal and GoPro Wifi range: upto a halfa mile, dependingon environment Controllerwith color screen and live flight data Pixhawk 2flight controller software Customizable color LEOs for orientation Solo Battery: 14.8V LiPo (5200mAh) Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available} 10x4.5 selftightening props 880 kV motors Plug and playwith 3-axis Solo Gimbal from 3DR Please feel free to contact our office should you have any additional questions orcomments. Thank you foryour cooperation with this matter. Sincerely,Bob Krull St Louis Aerial Photography