### April27, 2015 Docket Management System US Department ofTransportation 1200 NewJersey Ave, SE Washington, D.C. 20590 

# Conservaco, LLC www.conservaco.com



### 6278 N Federal Hwy Suite 210 Fort lauderdale, Florida 33308

RE: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act of2012


### To Whom It May Concern: Pursuant to (5)333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Conservaco, LLC, (Conservaco) operator of Small Unmanned Aircraft Systems {sUASs) equipped to cond uct aerial photographyforthe media and advertising industriesfor pre-planned, controlled area, photographic and surveying services, hereby applies foran exemption fromthe listed Federal Aviation Regulations{FARs) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration {FAA) as required by (S)333. Conservaco's current operation of sUASs for commercial purposes has been halted to comply with recently enacted federal aviation regulations pertaining to sUASs
. As described morefully below, the requested exemption would permit the operation ofsmall, unmanned and relatively inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained, 2) predetermined, 3) has on-site safety personnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations. The name and address of the applicant is: Conservaco, LLC Attn: MarkThimmig Ph: +1-{954) 594-2601 Email: MThimmig@cons ervaco.com Address: 6278 N Federal Hwy Suite 210, Fort Lauderdale, Florida 33308. Conservaco respectfully requests a grantofan exemption ofthe following sections ofTitle 14 ofthe Code of Federal Regulations: • 14 CFR 21; 

# • 14 CFR 91, et seq.; 

# • 14 CFR 45.23 (b); 

# • 14 CFR 61.113 (a) 

### & (b); 

# • 14 CFR 407 (a) (1); 

# • 14 CFR 409 (a) (2); 

# • 14 CFR 417 (a) 

### & (b)
. 1Conservaco also respectfully requests an Exemption from Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 

# • 14 CFR 45.23 (b); 

# • 14 CFR Part 21; 

# • 14 CFR 61.113(a) 

### &(b); 

# • 91.7 (a); 

# • 91.9 (b) (2); 

# • 91.103 (b) 

# • 91.109; 

# • 91.119; 

# • 91
.121; 

# • 91.151 (a); 

# • 91.203(a) 

### & (b); 

# • 91.405 (a); 

# • 91.407 (a) (1); 

# • 91.409 (a) (2); 

# • 91.417 (a) 

### & (b)
. 

### 1. The Extent of Relief MSAerial Seeks and the Reason. It Seeks
. Such Relief: Conservaco submits this application in accordance withthe Reform Act, 112 P. 95ss331-334, seeking relieffrom any currently applicable federal aviation regulations FARs pertaining to UASs (unmanned aircraft systems) and operating to prevent Conservaco contemplated commercial photographic, mapping, and other flight operations within the US. National airspace system, The Reform Act in 5332 provides for such integration of civil UASs into our national airspace system as it is in the public's interest to do so, Conservaco lightweight UASs meet the definition of small unmanned aircraft" asset set forth in §331 and combined with a sterling safety record in similar industries, Conservaco's light duty UASs are ideal recipients ofexemption by the intent ofthe Reform Act. Considerations for relief include a combination of sUAS physical characteristics, safety features, and safe practices identified in 333; • sUAS weight, • sUAS overall size, • sUAS speed over ground, • sUAS flight zone characteristics,

- Non-operation near airports (civilian or military), -Tightly controlled operation in populated areas, • Operation ofthe UAS by VLOVS. • Coordination by a minimum of 4 persons, three staff members of Conservaco and one safety official from the client,



### 2Specific consideration is outline below: 14C.F.R. Part 21, Subpart H. Airworthiness Certificates 14CFR 591.203 (a) {1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 591.203 (a) (1). Given the size and limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements of an equivalent level ofsafety under Part 11and 5333 ofthe Reform Act. The Federal Aviation Act (49
. U.S.C. 544701 (f) and 5333 of the 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 of the particular sUAS. 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 withoutthe restrictions and conditions proposed. The sUAS to be operated by Conservaco is less than 11kg, with maximal payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive orflammable materials including combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the pilot (PIC}, "spotter" role designated to act as both the remote sensing controller and secondary monitor for safety issues, and atechnician, which assists in matter s related to maintainingthe sUAS and also monitorsfor safety concerns and liaisons to the onsite safety officials. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide agreater degree ofsafety tothe public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under-14 C.F
.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates thatthere is no intrinsic credible threatto national security posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.
14 C.F.R. S45.23 (b). Markingofthe Aircraft The regulation requires: When marks include onlythe 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 mustalso display on thataircraft near each entrance tothe cabin, cockpit, or pilotstation, in letters not less than 2 inches nor more than 6inches high, the words limited" "restricted," "light-sport"

"experimental" or "provisional" as applicable,--- Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word E xperimental" can be placed. Given the size ofthe sUAS, two inch lettering will be impossible. The word Experimental will be placed on theframe in compliance with 45.29 at a size suitable forthe available space. The equ ivalent level ofsafety will be provided by having the sUA$ marked on its fuselage as required by 45 .29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. Further markings include the use offlashing green 

### LED illumination on the underside ofthe sUAS frame which stands at contrast against a blue or white sky.


### 314C.F.R. 561.113 {a) {b): Private Pilot Privileges and limitations: Pilot in Command. 561.113 (a) 

### & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring a ground crew member to have a private pilot's license rather than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the stasis remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 64 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 CFR
. 113 (a) 

### & (b).
14 C.F.R. 591.7 {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 aircraftand the requirements contained in the Manual for maintenance and use ofsafety check lists priorto each flight, a subset ofwhich are provided in enclosed Supplemental material, an equivalent level ofsafety will be provided.
14C.F.R. 591.9 (b) (2). Civil Aircraft Flight Manual in the Aircraft. 591.9 (b) {2) provides: No person may operate a US registered civil aircraft... {2) For which an Airplane or Rotorcraft Flight Manual is not required by 521.5 ofthis chapter, unless there is available in the aircraft current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a physical flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilotflying the sUAS will have immediate access to it. The FAA has issued the following exemptions tothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
14C.F.R. 591.103: Preflight Action This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weatherflight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help ofsUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to
.
14 CFR. 591.109: Flight Instruction 591.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unlessthat aircraft has fully functioning dual controls, sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls, Flight control is accomplished through the use of a 

### 4control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training without fully fu nctional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level ofsafety provided by the fact th at neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utilizing digital communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted.
14C.F.R. S91.1.19; Minimum Safe Altitudes 591.119 establishes safe altitudes for operation of civil aircraft
. 591.119 {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 sUAS that closely mimics the behavior of a helicopter, and the exemption requests authorityto operate at altitudes up to 400AGL, an exemption maybe needed to allow such operations. As set forth herein, the UAS will never operate a t higher than 400 AGL or beyond unaided visual line of sight, whichever is closer, it will however be operated in a restricted area with secu rity officials tasked with ensuring public safety, and where buildings and people will not be exposed to operations without their pre-obtained consent and training. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight operation will be taken without the permission of the property owner in the case of private property or local officials in the case of public propertyor private propertywith public interests. Because of the advance notice to the property owner and participants in the remote sensing activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraftweighting far more than the maximum 11kg ofConservaco's sUASs proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe sUAS will ensure separation between these smaii-UAS operations and the operations ofconventional aircraft that must comply with 591.119.
14C.F.R. 591.121 AltimeterSettings 591
.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The PIC and T echnician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height.
14 C.F.R. 591.151 (a): Fuel Requirements for Flight in VFR Conditions 591.151 (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 afterthatfor at least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes. The battery powering the sUAS provides approximately 15 

### 5minutes of powered flight in hover modewithout payload. Conservaco's sUAS will not be able to meetthe 30 minute reserve requirement in 14 CFR S91.151. Operating the small UAS, in a tightly 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 power, does not engender the type ofrisks that Section 91.151a) was intended to alleviate given the size and speed ofthe small UAS. Conservaco believes that an equivalent level ofsafety can be achieved by limitingflights to 10 minutes or 25% of battery power whichever happens first. This restriction wou ld be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.
14 C.F.R. 591.203 (a) 

### &(b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in S91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current air worthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under S91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than llkg 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 sUAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptionstothis regulation. A representative sample ofotherexceptions includes Exemption Nos. 9565,9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
14C.F.R. 591.405 (a); 407 (a) (1): 409 (a) (2); 417 (a) & (b): Maintenance Inspections These regulations require that an aircraft operator orownershall have that aircraft inspected as 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
..." 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 by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical 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 of any 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 exemption granted to Conservaco would permit its operation of lightweight, unmanned, remotely controlled, sUASs in atightly controlled environment with limited airspace, Conservaco utilizes local business safety officers in specifically determined areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goals, Technical enhancements to current safety controls will allow Conservaco to 

### 6operate exceeding current safety specifications, and stay-ahead of, or meet, new ones being implemented by the FAA and Department ofTransportation. Further, Conservaco conducts its operations in compliance with protocols described herein oras otherwise established by the FAA
.
11. Commercial and Public Benefits We at Conservaco believe that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system} and efficient means to meet technical problems solvable by elevated data collection instruments, Conservaco's client base are typically small to medium sized business looking to increase their awareness of s tructures or landscape on their respective properties through data collection by photographic, video graphic or lidar based surveying. By movingthese functions onto sUAS based aircraft, the potential for loss of life or property is diminished dueto the greater control in a smaller and safer aircraftthat holds no persons. Second, there are no reactive or combustible materials on board the sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of Conservaco's UASs allow the PIC to avoid hazards. Lastly, due to the nature of the remote sensing instrumentation onboard, the sUAS can maintain quite a safe dis tance between the aircraft and the objects} undergoing scrutiny. Accordingly, Conservaco's UASs have operated and will continue to operate at and above current safety levels. A. The costs and benefits ofyour proposed actionto society in general and specific groups within society As described above, Conservaco's past customers have been small to medium business seeking a remote sensing solution to specific issues before a larger efforton their partwould come underway
. Examples include construction efforts that sought elevated photographic imagery of specific landforms to minimize cost of efforts to develop, a regional park service that wanted to quantify the changing lifecycle of its flora by way of measuring leaf health through gradual chlorophyll depletion, and a local cities Dept. of Public Works that sought to collect images and 3D structural data byway of Lidar sensing 

### en masse of its bridges to serve as a supplement to its routine repair and planning documentation. The impact to society, financial and otherwise, would be extremely minimal. Indeed, it's been demonstrated that sUASs have the abilityto drastically increase the information available to policymakers atafraction ofthe cost of measuring this data by terrestrial means. One such impactwould be inconvenience to directly proximal and non-essential personnel that would be displaced from public or business owned property if it is deemed to be unsafe, in this case we relay our needs for aflight zone with the requirementthat it be safe from casual intrusions and allow the business time to shift operations in order to minimize potential safety issues. This is best performed with the aid of safety personnel that actively steer non-essential persons around the flight zone. 

### 1.The effect ofan exemption for Conservaco onthe quality ofthe natural and social environments Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an onboard pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civilian or militaryairports, and detrimental effects tothe environment caused byoperating a combustible fuel based, large scale aircraft, with restrictions on the proximityto the targetfor remote sensing.
Ill. Flight capabilities and characteristics ofConservaco's UASs Pursuant to 112 P
.L. 95 5333 (a}, concerns for public safety are mitigated by the overall capabilities and characteristics ofthe sUAS.


### 7Conservaco UASs utilizes eight (4) counter rotating propellers paired oppositely to each other for balance, control and stability. The total span of the sUASs - 1.2m allowing for stable flight or landing even with the sudden onset ofdetrimental environmental conditions. The sUASs have a maximal unit: payload mass of llkg, including cinematic photographic or other surveying equipment. Conservaco's sUAS is designed to primarily hover in place to capture photographic data and then operate at less than a 3Sknot maximum speed to the next pointof interest. They are capable ofvertical and horizontal operations but, in practice, is operated only within unaided VLOS of the PIC. In addition to the PIC, Conservaco employs a spotter (VOS role) and a technician (secondary VOS and onsite personnel liaison) which are within unaided verbal communication range. These personnel are supplemented by safety officials provided by the client who are instructed to cordon off and otherwise minimize pedestrian access in the flight zone ofthe client's grounds. In the event of loss ofvisual ofthe UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial based controls which allows the PIC to utilize one controller axis to recall the UAS to the PICs position without concern to the current heading of the sUAS, in the event of loss of sight of the sUAS into an area containing hazards or possible hazards, the spotter has a heads-up-display containing alive video feed which can be used to locate the UAS while it maintains its position in hover mode. The sUAS has demonstrated its ability to maintain its position by GPS coordinates in hover mode in 2Skph wind gusts at 25 feet representing an extreme environmental condition beyond the range ofconditions within the scope for sUAS operation. All ofConservaco's sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (10) minutes allowing the staff to work with small flight areas per phase
. The maximum flight time without payload is 18 minutes, however practical safe operation limitsthisto 10to give ample time to control thesUAS to a safe landing zone. Conservaco further restricts flighttime by notoperating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows Conservaco sUASs to hover in place ifcommunication with the PIC is lost and optionally follow a set of waypoints at a set speed and height to a home base predesignated safe landing zone, In the event of unforeseen motors) failure, the system will enter into a controlled descent while allowingfull use of all UAS flight controls by the PIC. All commands sent via remote controller received during a controlled descent are translated to an as meant paradigm meaning the flight control package will use its real-time 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity. Landing gear is also programmed to deploy based on sensing of range to ground from non-GPS based sources. This assures that ifone system is compensated a safe and successful landing can still occur. IV, Reasons Why an Exemption to Conservaco Will Not Adversely Affect Safety Standards Conservaco contends that operation of its sUASs will not create a hazard to users of the national airspace system or the public as stated in 112PL.b}. Given the diminutive size and weight of Conservaco's sUASs, combined with their operation in cordoned off and well-controlled areas, Consservaco's sUASs falls within Congress contemplated safety zone. Conservaco sUASs have an established safety record bolstered by multipoint preflight checklist, awareness oftheir surroundings and intimate knowledge ofthe behavior ofthe sUAS platform in many weather conditions. This safety record and implemented operational practices demonstrate an awareness of public safety.



### 8Conservaco operations routinely provide a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules. Conservaco has worked very closely with the regional vendors and supportfor this unitto create a tightly integrated and highlyfault tolerant platform that has been tested thoroughly by a vendor with a proven record for safety and solid designs. Though it does not mitigate safety it is of note that as of Nov 2014 there are few companies that will insure sUA$ operations and sUAS based companies. The sUAS of use at Conservaco is one oftwo models (by current awareness) that qualify for protection against damages or injury. Conservaco attained a significant level of insurance to rectify accidental damage or injury. Conservaco also continues to work closely with this organization to identify and mitigate sUA$ platform risk due to their expertise in several industries closely related to the aviation and transportation. Conservaco does not operate its UASs on or near airports and generally has only operated its fleet on private grounds with cordoned off areas or areas under the control of the property owner client with assistance by safety officials employed by the business. Conservaco determines the areas needed to fulfill the clients' goals and only operates its UASs in these flight zones and only in compliance with well-regarded safety protocols set forth initially by the RCUAS trade and hobby groups and recently codified by relevant FARs. Conservaco standardized on thefollowing practices to ensure safe operation of its UASs.
• Work with onsite personnel to plan the slight goals, • Work with onsite personnel to restrict access to non-essential persons, • Operation by unaided VLOS operation only, • Operation in phases 10 minutes in length, • Operation to minimal 25% battery power, • Operation ofdevice to GPS aided readout to 300ftat maximum, • Numerous preprogrammed fail-safes that ensure specific behavior per issue,
• Three main roles supplemented by on-site safety personnel, • Employ controlled lifecycle management ofcomponents to guard against multiple failures,
• Preform a site check days) before flightto identify potential issues, • Subscribe to relevant local weather and safety alerts, • Expertly choose data collection instruments and accessories to minimize flight requirements orexpertise, Conservaco has experience in similarfields and has adapted this experience in its use of UASs to increase safety. In combination to the ever expanding knowledge repositories from hobbyists and experts alike, Conservaco is constantly evolving its practices when there is a clear benefit to operations or increased safety element. A. Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Conservaco (applicant) seeks an exemption from the following rules: 14 C.F.R. 521, subpart H; 14 C.F.R. 45.23 (b); 14 CFR 561.113 (a) 

### & (b); 91.7 (a), 91.9 (b) (2), 91.103b); 91.109, 91.1.19, 91,121; 91
. 151 (a); 91.203 (a) 

### & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91
.417 (a) 

### & (b) to operate commercially asmall unmanned vehicle (11 kg or less) in elevated photographic and remote sensing operations.



### 9Approval ofexemptions allowing commercial operations ofsUASs in the media industry will enhance safety by reducing risk associated with conventional aircraft operations and other means of elevated remote sensing involving persons. The public benefit served by approval of this petition is increased awareness of characteristics ofdifficult imaging targets. A sUAS weighing fewer than 11kg and powered by sealed batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed data. The operation ofsmall UASs, weighing less than 55 lbs
., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exemptingthe applicantfrom the requirements of Part 21 and allowing commercial operations. As identified and described herein, Mark F. Thimmig, and his company Conservaco, LLC, is an experienced, recognized media services professional. Mr
. Thimmig and his companies have been producing and delivering advertising, media and technical solutions for the ma rketing industry for several years with a impeccable safety record. The FAA has been given the authority to issue the exemption to Conservaco, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval of this petition.

Chairman, CEO
encl: Supplement A: Physical characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation More characteristics have been outlined in the enclosed supplemental materials.



### 10Supplement 8: Summary Selections ofthe Flight Operations and Procedural Manual (FOPM)



### • All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective action procedures (CAP) that are performed. Note: All irregular behavior have root cause analysis performed before UAS operation is resumed. 

### VI. Emergency Procedures 

### • Loss of Remote Signal The flight package features an optional enhanced fail-safe which returns the UAS to the home base waypoint via the same path taken to point of lost signal. The UAS will then preform a hover overthis waypoint and then a controlled landing.
• Loss of GPS signal The system will operate in GPS assisted mode with three {3) satellites. At loss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to perform a controlled landing to the home base waypoint
. Ground bas ed height ranging is performed by a separate system and so loss ofGPS will not impact controlled landing in a safe manner. • Loss of Engine Power - In the event of one {1) (orto two oppositely positioned) rotor or motor failure the system will enter into controlled spin where all controls are translated based on current orientation and will behave as normal operation to the PIC to ensure a safe landing, -In the event of multiple rotor or motor failuresthe flight package can be configured to perform a safe landing orattempt operation to home base waypoint.

- Note: Behavior of the landing location is highly dependent on the position and number of rotors /motorsthat are affected. • Loss of Ground Control Software Best, -This will not affectoperation ofthe flight. The unitwill be piloted to a safe landing area and then landed so that examination ofthe link can be made
.



## SEE ATTACHED

CALIFORNIA ACKNOWLEDGEMENT 11

# CALIFORNIA All-PURPOSE CERTIFICATE OF ACKNOWLEDGMENT {CALIFORNIA CIVIl CODE§ 1189) A notary pub lic or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. STATE OF CALIFORNIA COUNTY OF 

# Q(Q(!@C:, On 

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### that@/~/tJo!ey executed the same in @ljfo:/t:l;(eir authorized capacity(t¢), and that

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### signature{:S). on the instrument the persor$), orthe entity upon behalf of which the

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### acted, executed the instrument
. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

___________ ADDITIONAl OPTIONAl INFORMATION_________ _ Description ofAttached Document Title or Type of Document: 

# 'rAPr

**()l-e~@lM** Aw\1C{,{;t\Oh Document Date: 

# 4 {'21

# t 

# \

sNumber of Pages:---:....:.\\ __ Signer(s) Other Than Named Above:



# -~=----N-~- **------** Add itional information:

# -----------------------------------

revision date 01/0l /201 5

### April 

### 27, 2015 Docket Management System US Department ofTransportation 

### 1200 New Jersey Ave, SE Washington, D.C. 

### 20590 

# Conservaco, LLC
www.conservaco.com



### 6278 N 

### Federal Hwy Suite 

### 210 Fort Lauderdale, Florida 

### 33308

RE: Supplement A: Physical Characteristics ofConservaco's UAS To Whom It May Concern : Please find in this document specifications related to the UAS subject to consideration for Exemption
. All specifications have been provided bythe manufacturer. It is of notethat these specifications in some instances constitute the maximum values discovered bythe manufacturer and averaged over several test units
. Conservaco utilizes these metrics when forming safe and sustainable flight operations and in no way do the specification extremes contained herein constitute normal Conservaco flight parameters.



### Model 

### T600 Weight (Battery Included) 2935 g 

### Hovering Accuracy (GPS Mode) Vertical: 

### 0.5 m Horizontal: 2.5 

### m Max Angular Velocity Pitch: 

### 300°/S Yaw: 

### 150°/S Max Tilt Angle 35° 

### Max Ascent Speed 5 

### m/s 

### Max Descent Speed 

### 4 m/s 

### Max Speed 22 m/s (A Til mode, no wind) 

### Max Flight Altitude 

### 4500 

## m Max Wind Speed Resistance 

### 10 m/s

### Max Flight Time 

### Approximately 18 minutes Moto1· Model 

### DJI 3510 Propeller Model 

### DJI 1345 Indoor Hovering 

### Enabled by default OperatingTemperature Range 

### -10° to 40° C Diagonal Distance 

### 559 to 581 mm Dimensions 

### 438x451x301 mm 

## Gimbal

Cam er

a Model 

### ZENMUSE X3 Output Powe1· (With Camera) 

### Static: 9 W In Motion: 11 W Operating Current 

### Station: 750 mA Motion: 900 mA Angular Vibration Range 

### ±0.03° Mounting 

### Detachable Controllable Range 

### Pitch: -90° to +30° Pan: ±320° Mechanical Range 

### Pitch: -125° to +45° Pan:±330° Max Controllable Speed 

### Pitch: 120°/S Pan: 180° /S Name 

### X3 Model 

### FC350 Total Pixels 

### 12.76M Effective Pixels 

### 12.4M Image Mn Size 

### 4000x3000 ISO Range 

### 100-3200 (video) 100-1600 (photo) Electronic Shutte1· Speed

### Remote Controller 8s- 1/8000s FOV (Field OfView) 94° CMOS Sony EXMOR 1/2.3" Lens 20mm (35mm format equivalent)f/2.8 focus at oa 

### 9 Elements in 9 groups Anti-distortion Still Photography Modes Single shoot Burst shooting: 3/5n frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time-lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate OfVideo Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264) Supported SD CardTypes Micro SD Max capacity: 64GB. Class 10 or UHS-1 rating required. OperatingTemperature Range 

# oo to 40° C Name C1 Operating Frequency 922.7-927.7 MHz (Japan Only) 5.725-5.825 GHz 2.400-2.483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 

### km EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video OutputPort USB, mini-HDMI Power Supply Built-in battery Charging DJI charger Dual User Capability Host-and-Slave connection Mobile Device Holder Tablet or Phone Max Mobile Device Width

### Charger

Battery (Standard)

Battery (Optional) 170mm Output Power 9W 

### OperatingTemperature Range -10° to 40° C StorageTemperature Range Less than 

### 3 months: -20° to 45° 

### C More than 3 

### months: 22° to 28° C 

### ChargingTemperature Range 0-40° 

# c Battery 6000 mAh LiPo 2S Model A14-100P1A Voltage 26.3 

## v Rated Power 100W Name Intelligent Flight Battery Model TB47 Capacity 4500 mAh Voltage 22.2V BatteryType LiPo 6S High voltage battery Energy 99.9 

### Wh Net Weight 570 g OperatingTemperature Range

- 10° to 40° 

### C StorageTempet·ature Range Less than 3 

### months: -20° to 45° C 

### More than 3 

### months: 22° C 

### to 28° C 

### ChargingTemperature Range 

# oo to 40° C 

### Max Charging Power 180W Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh

### Vision Positioning

DJI Pilot App Voltage 22.8

# v BatteryType LiPo 

### 6S Energy 129
.96 Wh Net Weight 

### 670 g OperatingTemperature Range -10° to 40° C StorageTemperature Range Less than 

### 3 months: -20 to 45° C More than 3 months: 22oto 28° C ChargingTemperature Range 

# oo to 40° C Max Charging Power 180W Velocity Range Below 8 m/s (2m above ground) Altitude Range 5-500 em Operating Environment Brightly lit (lux > 

### 15) patterned surfaces Operating Range 0-250 em Mobile Device System Requirements iOS 8.0 or later Android 4.1
.2 or later Supported :\-tobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus , iPad Air, iPad Air Wi-Fi + 

### Cellular. iPad mini 3, and iPad mini 3 Wi-Fi 

### + Cellular. This app is optimized for i * Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II , Google Nexus 9, Mi *Support for additional Android devices available as testing and development co

# Conservaco, LLC www.conservaco.com



### 6278 N Federal Hwy Suite 210 Fort Lauderdale, Florida 33308
April 

### 27, 2015 Docket Management System US Department ofTransportation 1200 New Jersey Ave, SE Washington, D
.C. 20590 RE: Supplement B: SummarySections of Flight Operations and Procedure Manual (FOPM) 

### To Whom It MayConcern: 

### I. Introduction This manual describes the notable roles, tasks, and operations performed by Conservaco. The aim is to document everything that is needed to be done during a mission, so it can act as a reference pointfor team members. II. Roles and Responsibilities As much as is possible, Conservaco staff attemptto have redundancy in expertise and skillsets related to operations ofthe UAS. Pilot in Command (PIC)
• Piloting the UA V. This will include: -Takeoff,

- Normal Flight,

- Flight during emergency procedures, -Landing,
• Assembling the UAV • Performs pre-flight checks ofthe firmware, • Performs pre-flight checks ofthe hardware, • Preforms pre-flight checks ofthe software. Spotter


### • Relays notable flight parameters such as flight

### times, battery strength, and metrics from the UAS. • Primary communication link between pilot and on-site safety personnel, • Will hold physical documents related to current flight, • Preforms pre-flight checks ofthe data collection equipment,

### • Monitors ground and greaterabove-ground environmentfor safety concerns Technician


### • Assembling the UAV, • Preforms pre-flight checks ofthe hardware, • Performs pre-flight checks ofthe software, • Secondary communication link between pilot and on-site safety personnel, • Relays to the Spotter and records notable flight parameters metricsfrom the UAS, • Monitors ground and greaterabove-ground environment for safety concerns Ill. Pre-Flight Checklist A. Before Power Applied


### • Check for physical damage and any missing hardware, • Check all electronics present and connected/ check cord connections are tight. • Confirm all batteries charged, • Check all rotors and moving parts for debris that would prevent properoperation. • Check weather patterns the night beforehand. Drone should be raised above the ground when tes ting landing gear or recalibrating servo travel. • Check data collection equipment for proper operation. • Check data collection equipment for issues that would impact safe operation offlight package. B. After Power Source Applied


### • Confirm proper power reading of battery, • Run hardware based systems check, • Run software based systems check, • Check flight LED array, • Confirm proper radio linkto flight controller, • Confirm proper radio linkto data collection device controller, • Confirm secondary controller connection to UAS onboard flight controller, • Confirm waypoints and geofences are accurate to current flight, • Confirm desired behavior ofemergency iffailsafe's, • Check with on-site safety personnel for any changes in goals 

## I flightpath. IV. 

### Flight-time Checklist


### • Check with on-site s afety personnel for a safe flight area forfi rst flight, • Record relevant metrics in flight log, • Check for ground hazards at home-base and rectify, • Confirm > 

### 8 satellite GPS lock, • Confirm initial state of controllers, • Initialize rotors and check for proper operation, • Perform controlled flight to hover mode approximately Sm above ground, • Check landing gear flight mode (up) operation, • Perform controlled multi-axis roll procedure to check for proper orchestrated rotor operation, • Perform controlled multi-axis (if applicable) control procedure ofdata collection package,

### • Switch controller mode to radial based, check proper operation to maximum Sm distance to PIC and return to initial position, • Return UAS to normal orientation, • Perform controlled flightto hover mode approximately lm above ground, Check landing gear landing mode (down) operation, • Land the UAS and check for properde-initialization of rotors, • Perform controlled flight to hover mode approximately Sm above ground, • Check landing gear flight mode (up) operation, • Operate UAS to each waypoint I position until maximum flight time is achieved, • Return UAS to normal orientation, • Perform controlled flight to hover mode approximately 1m above ground, • Check landing gear landing mode (down) operation, • Land the UAS and check for properde-initialization of rotors, • Remove powerto the flight package, • Remove powerto the data collection package, • Remove powerto controllers, • Complete flight log. 

### V. Standing Procedures
• The Pilot, Spotter, and Technician will be the only Conservaco staff members in the forward flight area. On-site personnel will be within verbal range and behind Conservaco staff. • The maximum power used to control the device is soft limited to 75% in orderto maintain power in reserve for unforeseen conditions, • Flight time is limited to 15 minutes and goals will be planned in phases to be accomplished during this time. • Flight time is limitedto reserving 25% battery power, • Flight height is soft limited tovisible and unaided line ofsight (VLOS), and hard limited to 300ft, 

### whichever is less. • F lighttime is limited to operation in safe environmental conditions, • Flight staffwill maintain proximity so as to be in clear and unaided verbal range, • The PIC will announce all movementsto Conservaco and on-site staffso that non-PIC staff members can identify possible safety concerns before operation ofthe UAS to the next waypointor position. Regards,

Mark F. Thimmig Chairman, CEO

# Conservaco, LLC

Operations Area (VFR Chart with Coordinates)
• Florida: Greater South Florida 0 

## N 25 26.46

# I 

# w80 29.28 • California: Greater LA 

# I Orange County Area 0 

## N 3341.59 

# I w 11749.49

## Conservaco, LLC OJI Inspire 1 Purchase Receipt 4-24-2015 

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- SUITE 220 I RVINE, CALIFORNIA 92606-4801 United States

## TRANSPORT RIS T RANSPORT RI SK M ANAGEMENT Inc P.O. Box.899, Pine,CO 80470 Ph
. 720
.208.0844 Fax. 720
.208.0845 

# CERTIFICATE OF INSURANCE
THIS IS TO CERTIFY TO: To Whom It May Concern 

# STATE IONAL PAN I E S



### THATTHE FOLLOWING POLICY /IES OF INSURANCE HAVE BEEN ISSUED TO: Conservaco, LLC 6278 N. Federal Hwy #210 Fort Lauderdale, FL 33308
POLICY NUMBER: BINDER04292015 POLICY PERIOD: From 04/29/2015 to 04/29/2016 Coverage only applies as indicated by a specific limit and deductible
. 

### A. Aircraft Liability Single Limit for Bodily Injury and Property Damage

**~eluding** 

### Passengers Liability with Passenger liability Limited to B
. Medical Expense

**~eluding** 

### Crew C. Physical Damage to Your Aircraft
ID Number TRM1563 Year 2015 Make and Model DJI Inspire 1 Agreed Value *•** 

### Limits of Liability $1,000,000 Each Occurrence $ ** 

### Each Passenger $ 5,000 Each Person Physical Damage $2 ,900 $5% Deductibles Total Loss $15%

The Aviation Managers have made provision to give the certificate holder prompt notice ofcancellation of any policy above
. But,the Aviation Managers assume no responsibility forfailure to provide such notice. This certificate does not change in anyway the actual coverages provided by the policy specified above
. Certificate No. TRM001



# ~~ BY __ 

# ------ **-- ~~~~**  **---- ~--**  **-------- --**  Date of Issue: 04/30/2015 (Authorized Representative) 5105 Al1010 

### Page 1 of 1