### July 15
, 2015

Exemption No. 12058 Regulatory Docket No. FAA

–2015

–1414

Mr. Mark S. McAdam Vice President, Wholesale Innovation, Research and Development Wells Fargo & Company 7679 Archer Lane North Maple Grove, MN 55311

Dear Mr. McAdam:
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated April 28, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofWells Fargo & Company (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial evaluation of agricultural operations, infrastructure, and crop damage

. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

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

.
Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2

.
In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation

### 2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21
, Certification procedures for products and parts, Subpart H

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

The Basis for Our Decision
You have requested to use a UAS for aerial data collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos

. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

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

—

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

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

 A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Wells Fargo & Company is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

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

Conditions and Limitations

In this grant of exemption, Wells Fargo & Company is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

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

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

.
2. Operations for the purpose of closed

-set motion picture and television filming are not permitted.

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

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

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

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

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times;
electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised

### 4

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

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

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

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

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

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

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

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

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

### 5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

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

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

-determined location within the private or controlled

-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

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

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct

operations that cannot be conducted under the terms of the attached COA

.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

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

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

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

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

27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

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

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

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

c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used;

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

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.
Sincerely, /s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril 28, 2015

Mr. James Williams Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department ofTransportation, Docket Operation West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE Washington, DC 20590 

# •.- --" ;_**·~::1-c:·­**

••

p 

## .-ri:-··-**~-!.r·.** :

' -I •. ,, • • •**~** - --· ., ;, ...

...... '· .: - ---. . ,_0 •.

.··' ! : ..:.. 0

Re: Request for exemption from multiple regulatory provisions to allow the use ofsmall unmanned aerial systems on land controlled by clients of [WELLS FARGO] to assist in the safe evaluation ofagricultural operations and crop damage for our clients.

Dear Mr. Williams:

[WELLS FARGO] respectfully requests an exemption from several provisions ofTitle 14 ofthe Code ofFederal Regulations (C.F.R.) to permit the use ofsmall-unmanned aerial systems (sUAS) to assist in the evaluation ofagricultural operations, infrastructure and crop damage for

our clients. ·

This request is motivated primarily by the desire to maximize safety in infrastructure and operations. While an exemption would not eliminate the current need for in-person visual inspection required by various federal regulatory departments, it would allow [WELLS FARGO]
to broadly evaluate assets and operations with sUAS, resulting in a safer and more efficient infrastructure network. Accordingly, the grant ofan exemption is consistent with Congress' intent, reflected in Section 333 ofthe FAA Modernization and Reform Act of2012 (Modernization Act), 1that safe systems be permitted in the national airspace prior to the issuance offinal regulations governing general use ofthese systems.2 A summary ofthis request suitable for publication in the Federal Register is provided as Appendix A.

Mark S. McAdam Vice President, Wholesale Innovation, Research and Development Wells Fargo & Company 7679 Archer Lane N. Maple Grove, MN 55311 Office: 612 2416 fargo.com

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate ofwaiver upon a finding that a type ofUAS, as a result ofits size, weight, speed, operational capacity, proximity to airports and populated areas, and operations within visual line ofsight do not create a hazard to users ofthe NAS or the public or pose a threat to national security

### Background Information [WELLS FARGO] is in the business ofassessing risk relative to the lands and infrastructures present on farm and ranch businesses operated by our clients. We have Clients looking to us to

assess damage incurred on the farm and ranch properties: damages that can be most safely and thoroughly assessed through the operation ofsUAS for Infrastructure Safety, Agricultural & Maintenance Inspections. As such, [WELLS FARGO] Clients look to us for Safe Operations of sUAS. We have developed specific [WELLS FARGO) Safe UAV Operational Procedures.



### Infrastructure Safety Inspection Operations: Utility & Infrastructure Inspection specific to crop harvest and delivery from field Agriculture Inspection

As part ofthis [WELLS FARGO) is requesting FAA Exemption for sUAS operations for safety, inspection and image 

### I video capture usage:


### Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 ofthe Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(£) ifit has determined that such an exemption is in the public interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety or how the exemption would provide at least an equivalent level ofsafety as compliance with the underlying regulation. In this case, approval of this exemption would advance the public interest by significantly enhancing the safety and efficiency ofinfrastructure operations and by providing the FAA with valuable user experience

on sUAS in a context with appreciable economic and societal benefits. As described more fully below, the requested exemption would permit the operation ofsUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary, as explained below, [WELLS FARGO] anticipates that use ofsUAS will enhance safety in infrastructure and agricultural operations.

Granting an Exemption is in the Public Interest. The safety and efficiency ofinfrastructure and agricultural operations is heavily dependent upon constant analysis ofassets, right-of-way, infrastructure and other assets/facilities on the farm and ranch land along with the condition of the farm and ranch land itself. There are a wide variety offactors that can affect conditions and

cause problems for infrastructure and agricultural operations that can impact crop yield and soil conditions. Even relatively small objects or minor failures can lead to accidents or other incidents causing downtime ofinfrastructure. Extreme weather events can lead to flooding or overheating infrastructure, damage to the structural integrity ofthe buildings themselves and the conditions ofthe surrounding fields. As a result, pursuant to federal regulations and company policy, our client's maintenance employees and in the case ofan alleged loss, Wells Fargo, routinely inspect the infrastructure and agricultural fields at issue. At present, this work is done primarily by company personnel in motor vehicles, on foot, in specialized equipment. This is often a labor-intensive and sometimes arduous and riskyjob. While our clients do all they can to make these inspections as safe as possible, there is an irreducible element ofrisk involved whenever employees are required to go out on structures ill'l:d distraught farm land. Employees

# .,

may need to climb over or onto structures, which can be slippery, rough, and/or exposed to the elements. Equipment moving through inspection zones can increase risk as well, especially in
remote areas where they can get stuck and the conditions ofimpact to the soil difficult to obtain 

### in flood like conditions. While the use ofsUAS for supplemental infrastructure and general asset evaluation would not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risks to employees by allowing for remote aerial review.

Additionally, the sheer amount ofassets and the widely dispersed locations inherent in the field ofagriculture operations

- in most ifnot all instances far from sizeable population centers

- means that visual inspection in all instances by company personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical because the required altitudes for safe flight reduce visibility below meaningful levels- it is simply not possible to see all asset anomalies from such heights. Helicopters present better vantage points; however manned helicopters are much more costly, subject to human safety and carry highly explosivejet fuel making them impractical for deployment. By using sUAS for supplemental asset evaluation, [WELLS FARGO] will be able to substantially upgrade its capacity to detect and address issues with the right-of-way and other assets before they become a problem for safe operations. Thus, the use ofsUAS has the potential to improve efficiency, resulting in faster and safer delivery of crop/damage evaluations, and agricultural resources vital to the U.S. economy.


### Granting an Exemption will not Adversely Affect Safety

[WELLS FARGO] notes that there is no applicable standard for an equivalency determination. Some have argued that the appropriate standard is that for model aircraft, noting that their operations, ifconducted for recreational purposes, would fall completely within the allowable operations for model aircraft. We believe it is difficult to argue that there is sufficient correlation between model operations controlled by the Academy ofModel Aeronautics and the ones contemplated by [WELLS FARGO]. At the same time, it is clear that equivalency cannot be established for traditional, manned civil aircraft because the design and use profiles between traditional aircraft and sUAS are simply too different. As such, we believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, which is all that §11.8l(e) requires.

Granting an exemption will not adversely affect safety. [WELLS FARGO] contemplates conducting sUAS operations over client owned or controlled land, solely during daylight hours,
at altitudes under 400 feet AGL well below that which would pose a risk to other aircraft and within FAA sUAS requirements. In general, sUAS operations are intended to be conducted in

areas distant from both congested areas and airports. Moreover, because ofthe inherent risks presented by standard infrastructure operations, our clients have already taken steps to secure property against unauthorized public access. For example, substantial stretches ofpipeline, utilities, railroad track and oil production sites are fenced, elevated, or otherwise secured to prevent access. Other long stretches ofinfrastructure are, as noted above, in very remote wilderness areas. The nature ofoperations anticipated by [WELLS FARGO] requires that the sUAS be flown at relatively low altitudes and relatively low speeds.

# I ( ( I Accordingly, the risk ofinterference with another aircraft is minimal. [WELLS FARGO] also plans to conduct sUAS operations at least five miles from any public airports (including heliports). In the event an operation needs to be conducted closer to an airport, [WELLS FARGO] will inform the airport operator and airport air traffic control tower ofthe contemplated operation and will comply with any directions issued by air traffic control at that airport. sUAS PICS will also be instructed as a part ofpre-flight planning to contact local crop dusting business(s) to ensure the sUAS will not be flown over fields scheduled during dusting operations
at least three days in advance.

Approval ofexemptions allowing commercial operations ofsUASs in the infrastructure and agricultural aerial inspection industry will enhance safety by reducing risk. Conventional operations, usingjet or piston power aircraft, operate at extremely low altitudesjust feet from the subject being inspected and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts of jet A or other fuel (140 gallons forjet helicopters). Such aircraft must fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried

on board. The sUAS is carried to the inspection site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation ofsmall UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft requirements and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. The safety ofthose on the ground is protected by the fact that no one will be allowed into the area without the permission ofthe company. Security will be established for the flight area as part of the pre-flight control. Each individual within the secure area will be briefed prior to flight and will consent to being in the area. All others will be excluded from the area.

[WELLS FARGO] initially intends to use a dedicated stafffor sUAS operations. All operations will be within visual line-of-sight (i.e., no more than approximately 0.5 miles from the manipulator ofthe controls, or pilot in command (PIC)). Each PIC will conduct at least three take-offs and landings with the sUAS on which he or she is trained every 90 days. PIC's will establish their qualifications thru a combination ofaeronautical knowledge, UAS airmanship skills, and verification through testing offlight ability before infrastructures operations have commenced. Depending on the type ofoperation, additional ground-based visual observers may be employed as well. These observers will be within constant visual line ofsight and in constant contact with the PIC. The visual observers will assist the PIC in avoiding objects near the sUAS.[WELLS FARGO] intends to use commercially available sUAS Components for sUAS. These sUAS systems will be tested for quality & safety in our test facility before being deployed to the field. The sUAS is less than 50 lbs. fully loaded, carries neither a pilot

nor passenger, and operates exclusively within a secured area. We have a routine maintenance schedule to verify that the sUAS will remain in safe and operational condition.

Please see 

### Appendix B, for Specific Types ofsUAS.

Notes Regarding: 14 C.F.R. Part 21, Subpart H In accordance with the statutory criteria provided in Section 333 ofPL 112---95 in reference to 49 USC 44704, and in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its operation, we request that this aircraft exemption meets the conditions ofSection 333. Therefore, ifgranted Section 333 reliefof 14 CFR part 21, and any associated noise certification and testing requirements ofpart 36, is not necessary.

Notes Regarding: 14 C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft Given the size ofthe sUAV, two-inch lettering will be impossible.

UA will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N---Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

[WELLS FARGO]'s request is based on the fact that no airworthiness certificate will be issued for the UAS. [WELLS FARGO]'s UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from§ 91.7(a) is not necessary.

Notes Regarding: 14 CFR 

### § 91.9(b)(2) Civil aircraft flight manual, marking & placard Certifications required, the original intent ofthese regulations was to display an aircraft's airworthiness, certification, and registration documents so they would be easily available
to inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014, the requested relieffrom 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests Small UASs, by their design, do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. Aircraft being considered for use by [WELLS FARGO] allow the UAS Instructor to place the aircraft into 'loiter' mode (fixed altitude stationary hold). In the event of the student losing control, the UAS Instructor can quickly and via alternate equipment (equipment not in the hands ofthe student) place the aircraft into a mode that then allows the instructor to bring the aircraft back into control and back to the predetermined and/or safe landing location. [WELLS FARGO] does not describe training scenarios in which a dual setofcontrols would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other company-designated individual, that would require that individual to have fully functioning dual controls. Rather, [WELLS FARGO] evaluates the qualification ofits PICs based on their experience with the VAS to be operated and verifies through testing, in lieu of formalized training.

As such, [WELLS FARGO] does not seek relieffrom 14 CFR 

### § 91.109. Notes Regarding 

### § 14 CFR 91.119(b) Relieffrom 

### § 14 CFR 91.119(b), operation over congested
areas, is not applicable, because the [WELLS FARGO]'s operations will only be conducted within the secured area described herein.


### [WELLS FARGO) Safety Operations & 

### Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from highly-reputable industry partners will include features1. Auto descent (landing) ifcommunication signal were to be severed. Ifthe sUAS loses communications, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land.

2. Auto descent and return to home- RTH (landing) ifbattery were to drop lower than nominal level(25%).

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we can monitor the

scene from the vehicle's perspective for collision avoidance, and to maintain spatial orientation.

5. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all times: speed, altitude, number ofGPS satellites (when available), heading and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures occur (highly improbable), vehicle returns automatically to the point of launch.

8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

Mechanical/Physical:1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminating the concern ofsignal severance (flying behind objects/walls).

2. The sUAS will weigh less than 50 lbs and travel at less than 87 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude ofno more than 400 feet AGL.

5. Fireproofbags for storage and charging ofhigh capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or as otherwise authorized by the FAA.

Personnel:

I. Spotters ensure safe operation and act as a redundant set ofeyes for operators (pilot, gimbal op)

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication.

3. A briefing will be conducted in regard to all planned sUAS operations prior to each days activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be contact WF RCIS central operations to ensure all required activities have been completed.

4. The operator will obtain the consent ofall persons involved in the sUAS operations and ensure that only consenting persons will be allowed within 100 feet ofthe flight operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Pilot and observer will have been trained in operation ofUAS generally and received up-to-date information on the particular UAS to be operated.


### Operations:

1. The unmanned aircraft (UA) will weigh less than 50 pounds (25 Kg), including energy source(s) and equipment. Operations authorized by this petition ofexemption are limited to the following aircraft described in Appendix B. Proposed operations ofany other aircraft will require

a new petition or a petition amendment to this request.

2. The UA may not be flown at a ground speed exceeding 87 knots.

3. Flights must be operated at an altitude ofno more than 200 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC
must be in feet AGL.( 4. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. The operator's manual included as Appendix C and this petition ofexemption must be maintained and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator's manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator's manual. The operator may update or revise its operator's manual. 

### It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment. Ifthe operator determines that any update or revision would affect the basis for which the FAA grants this petition for exemption, then the operator must petition for amendment
to their exemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operator's manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, ifutilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional
test flight in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator's manual.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, requirements for the following must be included in the operator's manual:

a. Actuators 

### I Servos; b. Powerplant (motors);

c. Propellers; d. Electronic speed controller;

# --

i (!

e. Batteries;. f. Remote command and control; g. Ground control station (ifused); and h. Any other components as determined by the operator;

10. Prior to operations conducted for the purpose ofinfrastructure and agricultural inspections, the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.5l(b), a minimum of50 flight cycles and 10 hours oftotal time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type. Prior documented flight experience that

was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under this petition of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119.

11. Prior to operations conducted for the purpose ofinfrastructure inspection, the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61 .51 (b), a minimum offive hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience building, and take-offand landing currency flights can be conducted under this petition ofexemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience-building, and take-offand landing currency flights all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119.

13. Prior to any flight operations authorized by this petition ofexemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator's manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion ofthe operator. A record ofcompletion ofthis qualification process must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose ofinfrastructure and agricultural operations inspection, a flight demonstration, administered by an operator-approved and -qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval ofcompany designated examiners, the petitioner will conduct these tests in accordance with the operator's manual.

15. The UA may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event ofa UAS failure or emergency.f I

16. Regarding the distance from participating persons, the operator's manual has safety mitigations for authorized and consenting personnel. At all times, those persons must be essential to the operations.

17. Regarding distance from nonparticipating persons, the operator must ensure that no persons are allowed within 500 feet ofthe area except those consenting to be involved and necessary for the infrastructure inspection operations. This provision may be reduced to no less than 200 feet ifit would not adversely affect safety and the Administrator has approved it. For example, an equivalent level ofsafety may be determined by an aviation safety inspector's evaluation ofthe infrastructure inspection area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of

an accident.

18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the security perimeter and land or be recovered in accordance with the operator's manual.

19. The UAS must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the operator's manual.

20. Each UAS operation must be completed with 25% battery power remaining. 21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under this petition ofexemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with \4 CFR part 45, Subpart C. Markings must be as large as practicable.

23. The operator must develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status ofreplacement/overhaul component parts, and the total time in service ofthe UAS. These procedures must be added to the operator's manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator's manual.

26. The preflight inspection section in the operator's manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant-preflight inspection sections ofthe operator's manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.28. At least three days before scheduled infrastructure inspection, the operator ofthe UAS affected by this exemption must submit a written Plan ofActivities to the local FSDO with**jurisdic~ion** over the area ofproposed infrastructure inspection. The 3-day notification may be waived with the

concurrence ofthe FSDO. The plan ofactivities must include at least the following:

a. Dates and times for all flights; b. Name and phone number ofthe operator for the UAS infrastructure inspection operations conducted under this petition ofexemption;

c. Name and phone number ofthe person responsible for the on-scene operation ofthe UAS; d. Make, model, and serial or N-number ofUAS to be used;·

e. Name ofUAS PICs involved in the infrastructure inspection event; f. A statement that the operator has obtained permission from property owners and/or local officials
to conduct the infrastructure and agricultural operations inspection event; the list ofthose who gave permission must be made available to the inspector upon request;

g. Signature ofexemption-holder or representative; and

h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state over which infrastructure inspection will be conducted and the altitudes essential to accomplish the operation.

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

30. The UA must remain clear and yield the right ofway to all other manned operations and activities
at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations
must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

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

33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

34. The UA may not operate in Class 8, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreement with the airport management must be made available to the Administrator upon request.

.

35. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National(

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume operations is provided.


### Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, [WELLS FARGO] provides the following information:



### Contact Information: Mark McAdam./ Vice President Wells Fargo Bank, NA Wholesale Security Strategic Services 7679 Archer Lane N Maple Grove, MN 55311 Mark.Mcadam@wellsfargo.com
Regulatory Provisions from which [WELLS FARGO] seeks ari. Exemption

[WELLS FARGO] believes it may need an exemption from the following provisions to conduct the contemplated operations. In some instances, reliefis needed because relief from another provision renders compliance with the regulation at hand infeasible.

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(l)&(2) 14 C.F.R. §91.417(a)&(b)

[WELLS FARGO] believes an exemption is only needed from the above-listed regulatory provisions. To the extent that the FAA believes that additional reliefis required for [WELLS FARGO] to conduct the operations described here, we request an exemption from any such regulatory provisions as well.33 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements "as applicable". Since none ofthe underlying requirements (e.g., inspection intervals) can be met and will require an exemption, [WELLS FARGO] believes a separate exemption should not be required for §91.417(a).



### The Extent of Requested Relief and the Reasons Relief is Needed Section 333 Aircraft Exemption Status:

Section 333 ofthe Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration ofthe size, weight,

## ,.

speed, operational capability ofthe particular UAS, as well as its proximity to airports and populated areas. An analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate in the areas and under the conditions contemplated by [WELLS FARGO] will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with

an airworthiness certificate without the conditions proposed in this request. The sUAS is less than 55 Ibs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area ofoperation as is now done with conventional equipment, infrastructure, bridge and out building evaluation. These safety enhancements provide an expanded degree ofsafety to the inspectors over conventional operations. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials and inability to carry a substantial external load. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe 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 without the restrictions and conditions proposed.

14 C.F.R. §61.113(a) and (b)



### §61.113 Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of

an aircraft in connection with any business or employment if:

( 1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.


## ***** [WELLS FARGO] anticipates initially using a cadre ofspecially trained staffto conduct the sUAS operations. While these individuals will not hold commercial pilot licenses. The sUAS will not carry property for compensation or hire since they will be used solely to assist in evaluation ofthe crop 

### I Ranch 

### I Orchard 

### I Vineyard infrastructure and Fields in furtherance of [WELLS FARGO]'s client's primary business, the successful operation ofa infrastructure;....

however, the employees' operation ofthe sUAS will not be incidental to their employment with [WELLS FARGO], and they will be compensated for such work. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole control of [WELLS FARGO] clients. Accordingly, the risk would be limited to [WELLS FARGO] personnel, who will be appropriately outfitted in safety gear, and [WELLS FARGO] client's property on the ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on [WELLS FARGO]. Because the contemplated operations would not comply with §61.113(b)(1) and none ofthe other exceptions to paragraph (a) apply, reliefis needed from both paragraphs (a) and (b).

14 C.F.R. 91.119(c)



### §91.119 Minimum safe altitudes: General. Except when necessary for takeoffor landing, no person may operate an aircraft below the following altitudes: · 

## *** (c) Over other than congested areas. An altitude of400 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.


## ***** [WELLS FARGO] submits that the only reliefit requires from §91.119 is from the minimum altitudes listed in paragraph (c). Reliefis required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk ofcollision with another aircraft, safety can only be assured through the grant ofan exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, reliefshould not be needed from paragraph (a) because an emergency landing ofthe aircraft due to a power failure will not create an undue hazard to persons or property on the surface. As noted in the explanation ofwhy an exemption will not adversely affect safety, [WELLS FARGO] clients has exclusive use ofthe land over which the sUAS will be operated, and public access is restricted. It also has exclusive use ofsignificant portions ofland adjacent to the infrastructure and structures that will be the objects ofevaluation and analysis. [WELLS FARGO]'s Clients tightly control

access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk ofinjury is minimal. [WELLS FARGO] does not contemplate conducting operations over congested areas, so reliefis not requested from paragraph (b).

14 C.F.R. 91.121



### 14 C.F.R. §91.121 Althneter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departureairport 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 ofsafety will be achieved by the operator, pursuant to the Operations Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 

### §91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin 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 ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.



### ***** Operating the sUAS in a pre-defined area with less than 30 minutes ofreserve fuel does not raise the type ofrisk contemplated by §91.151, i.e., that an aircraft could run out offuel in the event it has to be flown to an alternate airport or circle the planned airport in the event ofunanticipated conditions. [WELLS FARGO] does not intend to use the sUAS for point-to-point flights and will
not operate the sUAS beyond visual line ofsight. Nor will the sUAS require an airport in order
to land. Rather, [WELLS FARGO] will operate the sUAS using pre-planned flight paths (taking into account weather conditions) designed to allow the sUAS to fly to the point ofintended landing. As such, there is no need for a time-based excess fuel requirement. Rather it should be sufficient to require only as much additional excess flight capacity as necessary to safely land the sUAS.

We believe that a 25% battery reserve is more than sufficient to meet this objective.

14 C.F.R. 91.405(a), 91.407(a)(1), 14 C.F.R. 91.409(a)(1)&(2) and 14 C.F.R. 91.417(a) & (b)


### §91.405 Maintenance required.

Each owner or operator ofan aircraft

- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter;



### *****

### §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, rebuilding, or alteration unless- (1) It has been approved for return to service by a person authorized under §43.7 ofthis chapter;


## ***** §91.409 Inspections.

(a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by §43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter.



### ***** §91.417 (a) & 

### (b)



### ***** [WELLS FARGO] believes that an exemption from these three maintenance requirements is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to service inspections required by §91.409(a). [WELLS FARGO] will maintain the aircraft as instructed in the owner's manual and ASTM F2909, where applicable, and will not operate the aircraft until it has reasonably determined that any needed repairs have been made. However, because ofthe technical impossibility ofmeeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address provided above should you have any questions or concerns.
Respectfully submitted,

[SIGNATURE AND TYPED NAME 

### I WELLS FARGO].



### Appendix A

Summary for Federal Register Publication Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in ther Federal Register should the FAA determine that publication is needed. Petitioner: Drone Fleet & Aerospace Management, Inc. ([WELLS FARGO]) Sections of 14 C.P.R. Affected: 333 Aircraft Exemption Status 14 C.P.R. §61.113(a) and (b) 14 C.P.R. §91.119(c) 14 C.P.R. §91.121 14 C.P.R. §91.151 14 C.P.R. §91.405(a) 14 C.P.R. §91.407(a) 14 C.P.R. §91.409(a) 14 C.P.R. §91.417(a)&(b) Description ofReliefSought:

Petitioner seeks relieffrom the requirements of333 Aircraft Exemption Status, 14 C.P.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations over [WELLS FARGO] Client's owned or controlled land, solely during daylight hours, to assist in the safe evaluation and analysis ofinfrastructure and operations. In general, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature ofoperations anticipated by [WELLS FARGO] requires that the sUAS be flown at relatively low altitudes. [WELLS FARGO] expects that in
most instances, the sUAS will be flown less than 75 feet from the highest structure along the path ofthe sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk ofinterference with other aircraft is minimal.Federal Register should the FAA determine that publication is needed. Petitioner: Drone Fleet & Aerospace Management, Inc. ([WELLS FARGO]) Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Description ofReliefSought:

Petitioner seeks relieffrom the reauirements of333 Aircraft_Exemotion Status. 14 C.F.R

..