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### U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

January 21 , 2016

Dear Sir/Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 327 UAV Survey Consu lting LLC.( referred to as 327 USC ) operating and providing a service with the use of Small Unmanned Aircraft S ys tem (sUAS) equipped to conduct aerial photography and videograph y survey s for various industries, hereby applies for an exemption from the F ederal Aviation Regulations (FARs) listed below to allow operation of our sUAS commerciall y in airspace regulated b y the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by

the FAA as required by

Section 333. of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to allow operation of sUAS commerciall y in airspace regulated by the FAA so long as such operations are conducted with and under the conditions outlined herein or as may be established by

the FAA as required b y Section 333. This exemption will permit 327 UAV SURVEY CONSUL TI NG LLC. to operate its various Unmanned Aircraft Vehicl es (“UAV”) aerial video and photography inspections of electrical infrastructure, precision agricultural, storm restoration projects, civil locations, real estate residential/commercial and inspections, construction and educational and training events, whi le keeping the documents required by the regulations at the ground control station and immediately

accessible to the pilot in command. Furthermore, the exemption will relieve 327 UAV SURVEY CONSUL TI NG LLC.,. from the airworthiness certificate standards and the requirement to have a certificate of airworthiness issued for its UAV.2

This exemption will also permit any required markings concerning the operational status of its UAV to be display ed on the main section of the unmanned air craft.

The requested exemption would permit 327 UAV Survey Consulting LLC to pursue its commercial interests in providing services to consumers interested aerial dat a capture using a sUAS in the following areas: Electrical infrastructure, Storm restoration projects
Preci sion agricultural
Real estate residential/commercial
Construction sites Pipeline inspections Educational and Training events
Accident reconstruction

327 USC , states that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photograph y and videograph y will take place wil l be captured. Additionally , 327 USC pilots hold FAA Commercial and Priva te Pilot L icenses and valid driver’s license Medical Certificates and if observers are not qualified pil ots, they

will be trained by

327 USC pilots to understand the proper roles of an observer, communication pr ocedures, proper visual scan techniques, operations at non

- towered airports, and appropriate sections of the Aeronautical Information Manual.3

Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 ( b) 14 C.F.R. 61.113(a) and ( b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R . 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

327 USC , a survey

and research compan y possesses over 10 y ears of electrical industry training and knowledge

. Providing an expertise to Central and Eastern States electrical utilities consisting of projects in: inventory

and reliability inspections and recommendations to construction ty pes providing details of equipment, structures. Log gi ng all findings in digital spreadsheet which also include s photo documentation of utility assets . 327 USC, a participate in s to rm restoration projects, safely conducting a survey of decimated circuits providing power to commercial and residential custom ers. 327 USC , with this ex emption use of a s UAV a functional tool to be used in survey platform of aerial photograph y and videogra phy

. This would save time and monies toward safety

of personnel, reliability

and restoration efforts providing aerial view of damaged assets so power can be restored a few day s or hours to the public. Conducting preventative maintenance aerial inspections with a UAV will be detrimental to the success of reliability issues increasing compliance to 95 %. Safet y Fi rst A lways the motto a 327 USC , alway s following safe protocols established b y FMRA. During operations of preflight / flight/ post operations.4

**A.** 327 USC , developed refined safet y protocols to follow while operating a UAV in public air space providing a better understanding of the interpreted value of how the aircraft reacts to environmental variables.
**B.** Safety

Guidelines
Pre

- Flight Safet y Protocols
1. Check surroundings for Pedestrians, Commercial/Residential properties, vehicular, air and land traffic, obstructions, and environmental hazards.
2. Check

- in with local authorities/agencies to inform them of operations in their area.
3. Check with visual observer to ma intain communication and line of sight via voice

. 4. Check geographical area of the designated flight path for active Airports and restricted or private airspace.
5. Alway s have onsite emergency plan and contacts available for any occurrence of abnormal operatio ns. 6. Insure all involved in UAV field site adhere to safety protocols throughout full duration of flight mission.

327 USC , created a flight log containing information such as flight location, weather and environmental info, flight issues, statistics of all flight matrices from pre to post flight, and an y findings on subject of inspection.
327 USC , created a maintenance log spreadsheet that serve s as a record of all changes to aircraft configuration or settings. Ex.

- Changing out propellers, replacement of E lect ronic Speed C ontrollers ( ESC ’s ) , or any other issues that could affect flight safet y for the aircraft or public

We are petitioning for exemption to enable 327 USC , to operate a DJ I Inspire 1 Pro multi

- rotor equipped with a three

- axis gimbaled camera , Walkera Talia H 500 a multi

- rotor equipped with a three

- axis gimbaled camera. T he sUAS all weigh less than 10 lbs., have a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each sy stem also has the failsafe function of the autopilot sy stem, which means when the communication between the Main Controller and the transmitter is lost, the sy stem wil l automatically

trigger Return to Home and will land safel y.5

The previousl y mention specifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Standards:  The petitioner will only operate its sUAS in line of sig ht of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operator’s manual. Such operations will insure that the sUAS will "not create a hazard to users of the na tional airspace s ys tem or the public."  When fly ing sUAV within 3 miles of an airport, airport operators will be no tified and the operator will give the right of way to avoid fl yi ng in the proximity of full

- scale aircraft.  Maximum flight time for eac h operational flight will be 22 minutes.  Flights will be terminated at 25% battery power reserve should that occur prior to the 22

- minute limit.  The sUAV will be programmed so that it will not be operated at an altitude of no more than 4 00 feet AGL, and not more than 200 fe et above an elevated platform from which filming is planned.  Minimum cre w for each operation will consist of the sUAS Pilot and the Visual Observer.  The sUAS PI C' s (Pilot in C ommand) will be an FAA licensed airman holding a FAA Private Pilot or Com mercial Certificate and FAA Medical Certificate/ and or Valid driver’s license  The sUAS operated b y the petitioner weighs less than 55 pounds, including the pay load (i.e. camera, lens, and gimbal).  The sUAS will operate at speeds of no more than 55 knots.  Given the small size of the sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safet y requirements.

Add itionally , the fact that the 327 USC operator hold FAA Pilot certificates demonstrates that they have a high regard to safe operations with an understanding of FARs, pre

- flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards. Un der th e requested exemption 327 USC ensures that all operators have completed a small unmanned aircraft sy stems (UAS) education and training program including all applicable regulations and guidance documents; including aeronautical backgro und information such a s charts, Notice To Airman (NOTAMS) and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerody namics; Weather factors; Airmanship and Decision

- making and Safe Operating Procedures.6

We respec tfull y request exemption under Section 333 to enable 327 USC to operate safe, low

risk commercial sUAV operations for the activities stated. 327 USC at all times will respect the space and privacy

of citizens and proper ty

. Similar exemptions have been gra nted to other operations, including Exemptions No. 11295, 11472, 13944, 14347, 12853A, 14318, 12646 Thank y ou

**327 UAV Survey Consulting LLC.** Jon C. Taliaferro CEO 123 Millcreek Drive Dover, DE. 19904 (302) 480

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