April27, 2015 

Docket Management System 

US Department of Transportation 

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: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 

To Whom It May Concern: 

Pursuant to (5)333 of the 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 conduct 

aerial photography for the media and advertising industries for pre-planned, controlled area, photographic and 

surveying services, hereby applies for an exemption from the 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 more fully below, the requested exemption would permit the operation of small, 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: Mark Thimmig Ph: +1-{954) 594-2601 Email: 

MThimmig@conservaco.com Address: 6278 N Federal Hwy Suite 210, Fort Lauderdale, Florida 33308. 

Conservaco respectfully requests a grant of an exemption of the following sections of Title 14 of the 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) . 

1 
Conservaco also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 

of the 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 with the Reform Act, 112 P. 95ss331-334, seeking relief from 

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 of exemption by the intent of the 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 of the UAS by VLOVS. 

• Coordination by a minimum of 4 persons, three staff members of Conservaco and one safety official from 

the client, 

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Specific consideration is outline below: 

14C.F.R. Part 21, Subpart H. Airworthiness Certificates 

14 CFR 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 of safety under Part 11 and 5333 of the 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 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 rotorcraft) 

operating with an airworthiness certificate without the 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 or flammable 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 a technician, which assists in 

matters related to maintaining the sUAS and also monitors for safety concerns and liaisons to the onsite safety 

officials. 

These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide 

a greater degree of safety to the 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 that there is no intrinsic credible threat to 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 inability to carry a substantial external load. 

14 C.F.R. S45.23 (b). Marking of the Aircraft 

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 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 Experimental" can be placed. Given 

the size of the sUAS, two inch lettering will be impossible. The word Experimental will be placed on the frame 

in compliance with 45.29 at a size suitable for the available space. 

The equivalent level of safety 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 of flashing green LED illumination on the underside of the sUAS frame which 

stands at contrast against a blue or white sky. 

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14 C.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 of the aircraft and the requirements contained 

in the Manual for maintenance and use of safety check lists prior to each flight, a subset of which are provided 

in enclosed Supplemental material, an equivalent level of safety 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 of this 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 pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this 

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 weather flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the 

help of sUAS 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 unless that 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 

4 
control box that communicates with the aircraft via 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 of safety provided by the fact 

that 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 

authority to operate at altitudes up to 400 AGL, an exemption maybe needed to allow such operations. As set 

forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line of sight, 

whichever is closer, it will however be operated in a restricted area with security 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 of safety will be achieved given the size, weight, speed of the 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 property or private property with public interests. 

Because of the advance notice to the property owner and participants in the remote sensing activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft 

or rotorcraft weighting far more than the maximum 11kg of Conservaco'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 of the sUAS will 

ensure separation between these smaii-UAS operations and the operations of conventional aircraft that must 

comply with 591.119. 

14C.F.R. 591.121 Altimeter Settings 

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 Technician 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 after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. The battery powering the sUAS provides approximately 15 

5 
minutes of powered flight in hover mode without payload. Conservaco's sUAS will not be able to meet the 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 of risks that Section 91.151a) was intended to alleviate given the size and speed of the small 

UAS. Conservaco believes that an equivalent level of safety can be achieved by limiting flights to 10 minutes or 

25% of battery power whichever happens first. This restriction would 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 it the 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) of this 

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 of safety will be achieved by keeping these documents at the 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 exemptions to this regulation. A representative sample of other exceptions 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 or owner shall 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 of time. 

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 of safety. 

An exemption granted to Conservaco would permit its operation of lightweight, unmanned, remotely 

controlled, sUASs in a tightly 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 

6 
operate exceeding current safety specifications, and stay-ahead of, or meet, new ones being implemented by 

the FAA and Department of Transportation. Further, Conservaco conducts its operations in compliance with 

protocols described herein or as 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 structures or landscape on their respective properties through data collection by 

photographic, video graphic or lidar based surveying. By moving these functions onto sUAS based aircraft, the 

potential for loss of life or property is diminished due to the greater control in a smaller and safer aircraft that 

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 distance 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 of your proposed action to 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 effort on their part would 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 ability to drastically increase the information available to policymakers at a fraction of the 

cost of measuring this data by terrestrial means. One such impact would 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 a flight zone with the requirement that 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 of an exemption for Conservaco on the quality of the 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 military airports, and detrimental effects to the environment caused by operating a combustible 

fuel based, large scale aircraft, with restrictions on the proximity to the target for remote sensing. 

Ill. Flight capabilities and characteristics of Conservaco's UASs 

Pursuant to 112 P.L. 95 5333 (a}, concerns for public safety are mitigated by the overall capabilities and 

characteristics of the sUAS. 

7 
Conservaco 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 of detrimental 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 point of interest. 

They are capable of vertical 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 of the client's grounds. 

In the event of loss of visual of the 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 of conditions within the scope for sUAS operation. 

All of Conservaco'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 limits this to 10 to give ample time to control the sUAS 

to a safe landing zone. Conservaco further restricts flight time by not operating 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 if communication 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 allowing full 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 if one 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 of their surroundings and intimate knowledge of the behavior of the sUAS 

platform in many weather conditions. This safety record and implemented operational practices demonstrate 

an awareness of public safety. 

8 
Conservaco 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 support for 

this unit to create a tightly integrated and highly fault 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 of two 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 the following 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 of device to GPS aided readout to 300ft at maximum, 

• Numerous preprogrammed fail-safes that ensure specific behavior per issue, 

• Three main roles supplemented by on-site safety personnel, 

• Employ controlled lifecycle management of components to guard against multiple failures, 

• Preform a site check days) before flight to identify potential issues, 

• Subscribe to relevant local weather and safety alerts, 

• Expertly choose data collection instruments and accessories to minimize flight requirements or expertise, 

Conservaco has experience in similar fields 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 a small 

unmanned vehicle (11 kg or less) in elevated photographic and remote sensing operations. 

9 
Approval of exemptions allowing commercial operations of sUASs 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 of difficult 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 of small 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 

exempting the applicant from 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 marketing 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. 

10 
Supplement 8: Summary Selections of the 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 over this way point 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 based height ranging is performed by a separate system and so loss of GPS will not impact 

controlled landing in a safe manner. 

• Loss of Engine Power - In the event of one {1) (or to 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 failures the flight package can be configured to perform 

a safe landing or attempt operation to home base waypoint. 

- Note: Behavior of the landing location is highly dependent on the position and number of 

rotors/motors that are affected. 

• Loss of Ground Control Software Best, 

-This will not affect operation of the flight. The unit will be piloted to a safe landing area and then 

landed so that examination of the link can be made. 

SEE ATTACHED 

CALIFORNIA 

ACKNOWLEDGEMENT 

11 
CALIFORNIA All-PURPOSE 

CERTIFICATE OF ACKNOWLEDGMENT 

{CALIFORNIA CIVIl CODE§ 1189) 

A notary public 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 :/jQv'1\ ?:1. 10\S" before me, Jw~~ A. (',\o.( IC- • tJotwt.J Pcl\?l10 

(Date} ( ere Insert Name and Title of the Officer) 

personally appeared }J\C\(t f · \\'l l rY\rYll CJ , 

who proved to me on the basis of satisfactory evidence to be the person(¢ whose name(,gi s/a~ 

subscribed to the within instrument and acknowledged to me that@/~/tJo!ey executed the same 

in @ljfo:/t:l;(eir authorized capacity(t¢), and that by@/~r/t#eir signature{:S). on the instrument 

the persor$), or the entity upon behalf of which the person~) 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 of Attached 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-~- ------

Additional information: -----------------------------------

revision date 01/0l/2015 
April 27, 2015 

Docket Management System 

US Department of Transportation 

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 of Conservaco'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 by the manufacturer. It is of note that these specifications in some 

instances constitute the maximum values discovered by the 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 

Operating Temperature Range 

-10° to 40° C 

Diagonal Distance 

559 to 581 mm 

Dimensions 

438x451x301 mm 

Gimbal 

Camera 

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 Of View) 

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: 1920x1 080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SD Card Types 

Micro SD 

Max capacity: 64GB. Class 10 or UHS-1 rating required. 

Operating Temperature 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 Output Port 

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 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature 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 

Battery Type 

LiPo 6S High voltage battery 

Energy 

99.9 Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10° to 40° C 

Storage Tempet·ature Range 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature 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 

Battery Type 

LiPo 6S 

Energy 

129.96 Wh 

Net Weight 

670 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20 to 45° C 

More than 3 months: 22o to 28° C 

Charging Temperature 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 of Transportation 

1200 New Jersey Ave, SE 

Washington, D.C. 20590 

RE: Supplement B: Summary Sections of Flight Operations and Procedure Manual (FOPM) 

To Whom It May Concern: 

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 

point for team members. 

II. Roles and Responsibilities 

As much as is possible, Conservaco staff attempt to have redundancy in expertise and skillsets 

related to operations of the 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 of the hardware, 

• Preforms pre-flight checks of the 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 of the data collection equipment, 
• Monitors ground and greater above-ground environment for safety concerns 

Technician 

• Assembling the UAV, 

• Preforms pre-flight checks of the hardware, 

• Performs pre-flight checks of the software, 

• Secondary communication link between pilot and on-site safety personnel, 

• Relays to the Spotter and records notable flight parameters metrics from the UAS, 

• Monitors ground and greater above-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 proper operation. 

• Check weather patterns the night beforehand. Drone should be raised above the ground when 

testing landing gear or recalibrating servo travel. 

• Check data collection equipment for proper operation. 

• Check data collection equipment for issues that would impact safe operation of flight 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 link to flight controller, 

• Confirm proper radio link to data collection device controller, 

• Confirm secondary controller connection to UAS on board flight controller, 

• Confirm waypoints and geofences are accurate to current flight, 

• Confirm desired behavior of emergency if failsafe's, 

• Check with on-site safety personnel for any changes in goals I flightpath. 

IV. Flight-time Checklist 

• Check with on-site safety personnel for a safe flight area for first 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 of data 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 flight to hover mode approximately lm above ground, 

Check landing gear landing mode (down) operation, 

• Land the UAS and check for proper de-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 proper de-initialization of rotors, 

• Remove power to the flight package, 

• Remove power to the data collection package, 

• Remove power to 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 order to 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 limited to reserving 25% battery power, 

• Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 300ft, 

whichever is less. 

• Flight time is limited to operation in safe environmental conditions, 

• Flight staff will maintain proximity so as to be in clear and unaided verbal range, 

• The PIC will announce all movements to Conservaco and on-site staff so that non-PIC staff 

members can identify possible safety concerns before operation of the UAS to the next waypoint or 

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 w 80 29.28 

• California: Greater LA I Orange County Area 

0 N 33 41.59 I w 117 49.49 
Conservaco, LLC 

OJ I Inspire 1 Purchase Receipt 4-24-2015 

amazon 

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Tuesday, Apnt 28. 2015-

Thursday. April 30, 2015 

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The Eureka BurldJng I Care of Mark 

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1621 ALTON PKWY 

SECOND FlOOR- SUITE 220 

IRVINE. CAUFORNJA 9260&-4801 

Unfted States 

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Monday, April 27, 2015 

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Thimmig 

1621 ALTON PKWY 

SECOND FlOOR - SUITE 220 

IRVINE, CALIFORNIA 92606-4801 

United States 
TRANSPORT RIS T RANSPORT RISK 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 

THAT THE 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 of cancellation of any policy 

above. But, the Aviation Managers assume no responsibility for failure to provide such notice. This certificate does 

not change in any way 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