UAS Aerial Solutions , LLC

5715 Oak Hollow Ln Oviedo, FL 32765

386

- 385

- 8436 info@turbineaircraftlogistics.com

July 23 , 2015

U.S. Department of Transportation Docket Management System

1200 New J ersey Ave., SE Washington, DC 20590

UAS Aerial Solutions Petition for Exemption to Operate Unmanned Aircraft Sy stem s for the Purpose of Aerial Photography, Filming

, Data Collection , and Training

.

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER

UAS Aerial Solutions

Attn: Carson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386

- 386

- 8436

carson @ uasaerialsolutions .comUAS Aerial Solutions 333 Exemption

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# TERMS OF REFERENCE:

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air
(Title 49, United States Code (49 USC) § 40102)

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation
facilities, equipment and services, airports or landing areas; aeronautical charts,
information and services; rules, regulations and procedures, technical informati on, and manpower and material

3. Operational Control: with respect to a flight, means the exercise of authority over
initiating, conducting or terminating a flight (14 CFR § 1.1)

4. Pilot in Command (PIC): the person who has final authority and responsibility for the
operation and safety of the flight; has been designated as PIC before or during the
flight; and holds the appropriate category class and type

- rating, if appropriate, for
the conduct of the flight (14 CFR § 1.1)

5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct
human intervention from within or on the aircraft (P.L. 112

- 95, Section 331)

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements,
including communication links and the component s that control the unmanned
aircraft, that are required for the pilot in command to operate safely and
efficiently in the national airspace system (P.L. 112

- 95, Section 331)

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air
Traffic Organization to an operator for a specific unmanned aircraft activity

8. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted)
visual contact between a pilot in command and an unmanned aircraft sufficient to

maintain safe operational control of the aircraft, know its location, and be able to
scan the airspace in which it is operating to see and avoid other air traffic or
objects aloft or on the ground

9. Above Ground Level (AGL)

10. Visual Flight Rules (VFR)UAS Aerial Solutions 333 Exemption

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6 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, UAS Aerial Solutions seeks to be exempted from the following Federal Aviation Regulations:

Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“ FAA”) general exemption authority under 49 U.S.C. § 44701(f), UAS

Aerial Solutions (“Petitioner or Operator ”) hereby petitions for exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 91.7(a), §§ 91.9(b)(2), §§ 91.103(b)(2 ), §§ 91.105, §§ 91.109, §§ 91.119(c), §§ 91.121, §§ 91.151, §§ 91.405(a), §§ 91.407, §§ 91.409(a)(1) §§ 91.409(a)(2) , and §§ 91.417(a) & (b)

.

Specific s ections of 14 CFR from e xemption is needed

• FAR 21 (Certification procedures)

• FAR 91.103(b)(2 ) (Preflight action)

• FAR 91.105 (Flight crewmem bers at stations)

• FAR 91.109 (Flight Instruction)

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings)

• FAR 91.151 (Fuel requirements)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

• FAR 91.417 (Maintenance records)

14 C.F.R. 21

– Subpart H Certification Procedures for products and parts,

Airworthiness Certificates

UAS Aerial Solutions seeks exemption from 14 C.F.R. 21

– Subpart H : Certification

Procedures/Airworthiness Certificates

. we seek exemption from th is FAR because the FAA has not yet set a certification standard for UAS. The UASs that will be operated under the exemption will be less then 55lbs, fly’s at speeds under 87 KTS, does not carry flammable fuels or explosives, carries no pilot or passengers, and operates within a

secured area within the limits set forth under approved COAs.

14 C.F.R. 91.103(b)(2) Preflight Action

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.103(b)(2) which states that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. We are seeking this exemption because the preflight action required under FAR 91.103(b)(2) that is applicable to manned aircraft is not applicable to UAS. UAS Aerial Solutions will preform preflight action prior to flight by use FAA approved weather sources to review weather conditions. Operations will only be

in VFR conditions. Aircraft operated by UAS are capable of vertical takeoff and landing, not require a runway. We will b e using performance data contained within the

manufactures user manual.UAS Aerial Solutions 333 Exemption

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7 14 C.F.R. 91.105

– Flight Crewmembers at Stations

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.105 because a UAS is not equipped with a crewmember station. The UAS is pilot e d from the ground with VLOS of

a PIC and VO by direct control via wireless transceiver by the PIC.

14 C.F.R. 91.109

– Flight Instruction

UAS Aerial Solutions seek exemption from 14 C.F.R. 91.109 because UAS are not configured to have dual controls. Becaus e the FAA has not yet created rules pertaining to UAS flight instructors, we are requesting that our experienced UAS pilots can preform instruction to qualify our new pilots on our UAS.

14 C.F.R. 91.119

– Minimum Safe Altitudes

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.119 due to COA restriction on operations at altitudes that would allow compliance with 91.119. Safe operations of UAS depends on operators conducting operations below altitudes that manned ai rcraft are operating in , as a sense a nd avoid solut ion has not yet been developed. All of our UAS operations will be conducted at altitudes below 400ft AGL

, or at or below attitudes as allowed under the COA used for operations.

14 C.F.R. 91.121

– Altimeter Settings

UAS Aerial Solutions seek s exemption from 14 C.F.R. 91.121 because UAS do not use

traditional barometric altimeters to calculate altitude. Our UAS’s, when the motors first

start, the altitude readout on the controller, viewable by the pilot, is automatically set to 0

feet AGL. Alt itude by the UAS is consistently calculated and displayed to the pilot via the controller by both GPS data and barometric aiding. All rules currently pertaining to UAS are applicable in AGL attitudes, therefor, good cause exist for exemption from this

regu lation.

14 C.F.R. 91.151

– Fuel Requirements for Flights in Visual Flight Rules (VFR)

Conditions

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.151 due to the typical restrictions on flight time due to battery capacity. Most UAS’s we will operate will have battery endurance of 30 minutes or less. Because the UAS always is within line of sight from its takeoff location, the time to return to that location to land is no more t hen 3 minutes. We will begin navigating the UAS to it’s landing location wh en the battery level

reaches 30 % capacity, the UAS will be landed prior to the battery level reaching 20%. In the event the pilot failed to have the UAS landed by 20% battery capacity, the system will automatically initiate safe landing sequence and return to the marked landingUAS Aerial Solutions 333 Exemption

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8 location and auto land. Note: the automatic safe landing sequence can be interrupted anytime by the PIC and manually landed under to control of the PIC.

14 C.F.R. 91.405 , 91.407, 91.409, and 91.417

– Maintenance Required, Operations after maintenance, Inspections, maintenance record s

.

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.405

, 91.407, 91.409, and

91.417 because the FAA has developed no required mai ntenance inspection standard, inspection interval , or authorized perso nnel to preform maintenance for UAS. We are asking to use manufacture recommended maintenance practices and inspection intervals

in lieu of regulations that pertain to manned aircraft. We are asking that our PICs be allowed to preform maintenance and inspe ctions in accordance with the manufactures user or maintenance manual. Our PICs will record maintenance in a paper or electronic airframe logbook in a format that complies with FAR 91.417 (a) (1).

Public Best Interest

UAS!Aerial!Solutions believes!with!exe mption!from!the!requested!regulations!it!can! serve!the!public!best!interest!by!providing! filming!and!data!collection services!at!a! fraction!of!the!cost!that!would!exist!preforming!the!same!services!in!manned! aircraft.!With!helicopter!rental!cost!well!over! two!hundred!dollars!per!hour,!using!a! UAS!will!accomplish!these!same!tasks!with!more!then!a!98%!reduction!is!operating! cost.!The!public!will!bef it!from!this!because the!end!consumer!will!be!charged! considerably!less!for!a!better!quality!product.!Safety!is! the!top!goal!of! UAS!Aerial!

Solutions and!the!pubic!as!a!whole.!We!can!offer!services!in!a!much!safer!manner!to! the!public!with!our!unmanned!aircraft!then!we!could!with!our!manned!aircraft.!If! the!service!we!provide!was!accomplished!in!a!manned!helicopter,! the!risk!of!flying! at!low!attitudes!inherently!increases!the!risk!to!the!public!in!the!event!of!a! mechanical!difficulty.!The!UAS!has!very!few!moving!parts,!greatly!decreasing!the! likelihood!of!a!mechanical!failure.!However,!even!in!the!event!of!a!mechanica l! problem!with!a!UAS,!the!likelihood!of!damage!or!injury!to!persons!or!property!is! very!low!due!to!the!UAS’s!very!light!w eight!(under!55 lbs),!no!flammable!fuels! carried!on!board,!and!plastic!propellers.!This!exemption!can!also!be!found!in!public!

interest!a s!it!is!very!quite!comparatively!to!a!manned!aircraft,!low!energy!usage,!and!

zero!carbon!emissions.!

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provi ded by the rule from which you seek the exemption.

Equivalent(Safety(to(Regulations(Pertaining(to(Manned(Aviation(

UAS!Aerial!Solutions is!uniquely!capable!of!providing!a!level!of!safety!at!least!equal! to!that!provided!by!the!rule!from!which!we!seek!an!ex emption. Below!are!UAS Aerial Solutions 333 Exemption

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9 qualifications!and!procedures!that!show!the!ability!to!operate!UAS!with!an! equivalent!level!of!safety!to!manned!aircraft:

• Carson!Lee,!the!chief!pilot!for!both!manned!and!UAS!operations!at! UAS!Aerial!

Solutions ,!has!13!years!of!manned!av iation!experience!with!over!5000!hours! of!flight!time!accrued!in!manned!aircraft!and!h undreds!of!hours!piloting UAS! for!hobby!use. Carson!also!holds!an!FAA!Flight!Instructor!certificate!for! single/multi!engine!and!instrument. Carson!also!holds!a!FAA!issued Airframe! &!Powerplant!mechanic!certificate!with!Inspection!Authorization.!

• Because!the!FAA!has!not!developed!inspection!and!repair!methods!with!UAS,!

we!will!follow!the!manufactures!recommendation!for! inspection!intervals! and!repair.

• UAS,!while!highly!tech nically!advanced,!are!very!simple!in!design!with!very! few!moving!parts reducing!to!possibility!of!failure

.!

• The! UAS we!will!operate is!capable!in!the!event!of!lost!link!to!return!to!a! designated!safe!location!and!auto!land.!

• Return to designated point auto matically with a low battery that is dynamically updated depending on UAS distance from the designated landing point

.

• Most of the UAS we will operate will weigh less then 10lbs, however non e of our UAS will weigh over 55lbs including payload

.

• No flammable fuels carried onboard

.

• UAS flights will be conducted in VFR conditions.

• UAS flight operations will be conducted during daylight hours

.

• PICs designated will have accrued 25 hour total time operating UAS , with a

mi nimum of 5 hours in make and model of UAS to be used for commercial operation

.

• UAS flights will terminate before the battery has reached 20% capacity

• A pre

- flight inspection will be conducted of the UAS prior to each flight in

accordance with manufactures recommendation

.

• UAS will be conducted 400 fe et and below AGL, under altitudes of manned aircraft operations

.

• UAS operations will not be conducted within 500 feet of nonparticipating persons, vessels, vehicles, or structures without permission from those persons or

owners.

• The operator to insure PIC s are complying with the operations manual and exemption requirements logs all UAS flights that can be review ed by

management to insure safe operations

.

• Prior to UAS flight, we will review FAA aeronautical sectional charts and airport facility directory to insure that no flight operation will come withi n 5NM of an airport with a control tower, 3NM of an airport not having an operational control tower but having a published instrument approach procedure, 2NM of an airport not having an operational control tower or instrument approach procedure, orUAS Aerial Solutions 333 Exemption

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10 2NM of a heliport having an instrument approach procedure without having an appropriate authorization from the ATC controlling facility and airport manager.

• All UAS operation will be conducted within VLOS from the PIC and VO

• We!are!highly!filmier!with!FARs,!aeron autical!charts,!NOTAM!research!and! filing,!TFRs,!etc.!!We!will!conduct!preflight!planning!to!review!all!necessary! information,!including!but!not!limited!to:!reviewing!VFR!sectiona ls!to!insure! remaining!clear!of:! prohibited/restricted/MOAs/warning!areas;!ai rspace! other!then!class!G!(unless!a!COA!has!been!granted).!Review!of!TFRs,! NOTAMs,!and!submitting!a!NOTAM!for!our!proposed!flight!as!required.!UAS Aerial Solutions 333 Exemption

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11 I. Petition Summary

If granted, this ex emption would allow pilots named in UAS Aerial Solutions operations

manual to act as PICs to operate small UAS (under 55lbs) with an attached camera and or

sensors for the pu rpose of aerial photography, filming

, data collection , and training

. With

a combination of factors below, the operator can operate th e UAS in a manner equal to the safety standards set forth by the FARs for civilly manned aircraft :

• No flammable fuels with be carried

• Return to designated poin t in the event of a lost control link

• Return to designated point automatically with a low batt ery that is dynamically updated depending on UAS distance from the designated point

• Low weight (under 55LBS)

• Slow speed

• No passengers to be carried

• Experience d crew members

• Stringent maintenance program

The operator will be operating the UAS for the purp ose of providin g photographs, video,

data collection , and training to the public on an on demand bases

. The safety that can be achieved operating a small (under 55lbs), carrying no passengers or crew, carrying no

flammable fu els, and no poll ution from operation , can be found to be in public interest.

II. Exemptions Requested

The operator is requesting relief from the following FAA regulations:

• FAR 21 (Certification procedures)

• FAR 91.103(b)(2) (Preflight action)

• FAR 91.105 (Flight crew members at stations)

• FAR 91.109 (Flight Instruction)

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings)

• FAR 91.151 (Fuel requirements)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

• FAR 91.417 (Maintenan ce records)

III. Unmanned Aircraft System s

UAS Aerial Solution intends to operate both the DJI Inspire 1

, as well as the DJI

Phantom 3 Professional & Advanced

. UAS Aerial Solutions will comply with the pre

-UAS Aerial Solutions 333 Exemption

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12 flight procedures , flight operations

, and mainte nance procedures detailed in the following documents that will be attached to this exemption request:

UAS Aerial Solutions Operations Manual Inspire 1 User Manual v1.2 Inspire 1 Maintenance Manual v1.0 Inspire 1 Safety Guidelines v1.0

Phantom 3 Profession al User Manual v1.2

Phantom 3 Advance d User Manual v1.2 Phantom 3 Safety Guidelines v1.0

IV

. Operational Procedures DJI Inspire 1

1.1 The UAS the operator seek s e xemption for is manufactured DJI and the model

is the Inspire 1 is a 6.47 lb multi

- rotor (4 rot ors) UAS with approximately 18 minutes of endurance. The Inspire 1’s purpose is to carry a small camera as its payload. The Inspire 1 has the ability to be controlled by a single crewmember acting as pilot in command by wireless remote control on a 2.4GHz band having a transmitting distance of 2km (1.08nm).

1.2 The Inspire 1 UAS is equipped with lost link protection (referred to as

“Return To H ome ” (RTH) in the Inspire 1 User Manual), allowing the UAS to automatically climb vertically to a safe altitude to cle ar obstacles; then proceed to a pre

- designated point to automatically land. At anytime the UAS and the controller reestablish link, the PIC can cancel the RTH and resume

contro l of the UAS. In the event of lost GPS signal, control to the Inspire UAS

is not lost. Since all operations will be conducted under Visual Line of Sight

VLOS the PIC can control the aircraft back to a safe location to land.

1.3 Because the Inspire 1 UAS does not have the endurance to meet the requirements of FAR 91.155(b), the operator i s requesting exception from this regulation and substituted with the following standard: All flights will be terminated at or prior to the battery level reaching 20%.

1.4 The operator will register the UAS IAW FAR part 47. The operator’s UAS

will have identifi cation m akings in accordance with FAR 45(c)

. The Inspire 1 UAS is too small to practically display registration markings IAW FAR 45.29(a) though (e). The registration marks will be affixed as large as practical IAW FAR 45.29( f).

1.5 The operator is requesting relief from FAR 91.121 because the Inspire 1 UAS is not equipped with a standard adjustable ba rometric altimeter system. The

I nspire 1 UAS c ollects altitude information from t wo sources: GPS and

barometric a iding . Upon powering one the Inspire 1

, the syste m will reset the altitude readout on the controllers base station to 0 feet above ground level (AGL). The PIC then will reference the digitally displayed altitude on the

controller in AGL for the duration of the flight.UAS Aerial Solutions 333 Exemption

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13 1.6 Because of the small size, low weigh t, slow speed, and limited operating area of the Inspire 1 UAS, the operator is requesting relief from CFR part 21(h) (airworthiness certificates). The operator has d etermined that it can operate

t he Inspire 1 or Phantom UAS to an equivalent level of safet y set forth under part 21 of the CFRs and meets the requirements set forth in the 333 exemption.

1.7 Prior to flight the Inspire 1 UAS will be determined to be in an airworthy condition IAW the pre

- flight checklist outlined in attached Ins pire 1 User

Manual V 1.0

. The operator is requesting exemption from required inspections

of FAR 91.409 (a)(1) and (2) and will adopt the manufactures recommended inspections program as outlined in the attached Inspire 1 Maintenance Manual

v1.0

. B ecause the FAA has not establish ed an inspection standard for UAS as have been established for manned aircraft under FAR 43.13 appendix D, the operator is r equesting an exemption from the maintenance scope and detail of FAR 43.13 appendix D and replaced with the manufactures recommended

maintenance program detailed in the attached Inspire 1 Maintenance Manual

v1.0. The operator will follow the manufactures recommended inspection interval to preform comprehensive maintenance of the Inspire 1 every 50 flight hours or 200 flights, whichever comes first.

1.8 The operator will adopt maintenance record requirements set forth under FAR

91.417. Maintenance and inspection records will be maintained in a single airframe paper or digital logbook.

1.9 The DJI Inspire UAS operates on the 2.4GHz frequency ban d for both UAS control as well as video downlink. Both the Inspire 1 UAS as well and the UAS remote controller comply with part 15 of the FCC rules (see page appendix A, page 62 of the DJI Inspire user manual). The Inspire 1 is equipped with a vision posit ioning system along with a sonar system in order to be able to fly inside a building and still remain stable. The Inspire 1’s primary payload is a small X3 model FC350 camera mounted with a Zenmuse X3 gimbal.

1.10 Refer to the attached Inspire 1 User Manual V1 .0 for more detail on the Inspire 1 UAS.

2. IV. Operational Procedures Phantom 3 Professional and Advanced

2.1 The UAS the operator seeks exemption for is manufactured by DJI and the

model s are the Phantom 3 profession and Advanced. The DJI Phantom 3 is a

2.82 l b multi

- rotor (4 r otors) UAS with approximately 23 minutes of

endurance. The Phantom 3 ’s purpose is to carry a small camera as its payload.

The Phantom 3 has the ability to be controlled by a single crewmember acting as pilot in command by wireless remote control on a 2.4GHz band having a transmitting distance of 2km (1.08nm).

2.2 The Phantom 3 UAS is equipped with lost link protection (referred to as “Return To Home” (RTH) in the Phantom 3 User Manual), allowing the UAS to automatically climb vertically to a safe altitude to clear obstacles; thenUAS Aerial Solutions 333 Exemption

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14 proceed to a pre

- designated point to automatically land. At anytime the UAS and the controller reestablish link, the PIC can cancel the RTH and resume control of the UAS. In the event of lost GPS signal, control to th e Inspire UAS is not lost. Since all operations will be conducted under Visual Line of Sight

VLOS the PIC can control the aircraft back to a safe location to land.

2.3 Because the Phantom 3 UAS does not have the endurance to meet the requirements of FAR 91.15 5(b), the operator is requesting exception from this regulation and substituted with the following standard: All flights will be terminated at or prior to the battery level reaching 20%.

2.4 The operator will register the UAS IAW FAR part 47. The operator’s UA S will have identification makings in accordance with FAR 45(c). The Phantom

3 UAS is too small to practically display registration markings IAW FAR 45.29(a) though (e). The registration marks will be affixed as large as practical IAW FAR 45.29(f).

2.5 The ope rator is requesting relief from FAR 91.121 because the Phantom 3 UAS is not equipped with a standard adjustable barometric altimeter system.

The Phantom 3 UAS collects altitude information from two sources: GPS and barometric aiding. Upon powering one the Phantom 3 , the system will reset the altitude readout on the controllers base station to 0 feet above ground level (AGL). The PIC then will reference the digitally displayed altitude on the controller in AGL for the duration of the flight.

2.6 Because of the s mall size, low weight, slow speed, and limited operating area

of the Phantom 3 UAS, the operator is requesting relief from CFR part 21(h) (airworthiness certificates). The operator has determined that it can operate

the Phantom 3 UAS to an equivalent level of safety set forth under part 21 of the CFRs and meets the requirements set forth in the 333 exemption.

2.7 Prior to flight the Phantom 3 UAS will be determined to be in an airworthy condition IAW the pre

- flight checklist outlined in attached Phantom 3 User

Manual V1.0 . The operator is requesting exemption from required inspections

of FAR 91.409 (a)(1) and (2) . DJI had not yet published a maintenance manual for the Phantom 3 UAS, however after review by our Airframe and Powerplant mechanic with Inspection Aut horization, we have determined that DJI’s Inspire 1 Maintenance Manual can be adopted without any changes and archive the appropriate level of safety. We are requesting approval to adopt the inspection checklist outlined in the Inspire 1 Maintenance Manual for our

Phantom 3 UAS. Because the FAA has not established an inspection standard

for UAS as have been established for manned aircraft under FAR 43.13 appendix D, the operator is requesting an exemption from the maintenance scope and detail of FAR 43.13 a ppendix D and replaced with the

manufactures recommended maintenance program detailed in the attached Inspire 1 Maintenance Manual v1.0. The operator will follow the manufactures recommended inspection interval to preform comprehensive

maintenance of the D JI Phantom every 50 flight hours or 200 flights,

whichever comes first.UAS Aerial Solutions 333 Exemption

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15 2.8 The operator will adopt maintenance record requirements set forth under FAR 91.417. Maintenance and inspection records will be maintained in a single airframe paper or digital logbook

. 2.9 The DJI Inspire UAS operates on the 2.4GHz frequency band for both UAS

control as well as video downlink. Both the Phantom 3 UAS as well and the UAS remote controller comply with part 15 of the FCC rules (see page appendix A, page 62 of the DJI Inspire user manual). The Phantom 3 is equipped with a vision positioning system along with a sonar system in order to be able to fly inside a building and still remain stable. The Phantom 3 ’s primary payload is a small 

### Sony EXMOR c amera mounted with a gimbal.

2.10 Re fer to the attached Phantom 3 User Manual V1.2 for more detail on the

Phantom 3 UAS.

3. Unmanned Aircraft PIC

3.1 The operator has designated Carson Wade Lee, Airline Transport Pilot (ATP) as the chief pilot for its UAS operations. Carson currently holds 13 y ears o f flight experience with over 5000 flight hours in manned aircraft. Carson holds an Airline Transport Pilot Certificate for both single and multi

- engine land

aircraft . Carson also holds an Airframe & Powerplant FAA mechanic certificate with Inspectio n Authorization under FSDO

- 15. Carson also has 3 years of experience with hundreds of hours operating UAS for recreational

use. 3.2 The operator is requesting that the operators chief UAS pilot be allowed to designate any UAS pilot to act as a PIC for UAS Aeri al Solutions with the following experience requirements:

• Hold an FAA sport, recreational, private, commercial, or airline transport pilot

certificate.

• Hold a state issued drivers license or a FAA first, second, or third class m edical.

• Meets the flight re view requirements of FAR 61. 56.

• Meets the recent flight experience for PIC of FAR 61.57 (UAS takeoff/landings)

• Has accrued 25 hour total time operating UAS

• Has a mi nimum of 10 hours operating similar model UAS

.

• Has a minimum of 5 hours make and model of U AS

3.3 The PIC will designate a Visual Observer (VO) prior to any flight to be conducted. Any VO to be used by the PIC must be authorized by the UAS chief pilot. Further, the VO shall be familiar with UAS operations to the extent their designated role as VO r equires. The VO will be require to be able to communicate with the PIC verbally at all times.

3.4 It will be the PICs responsibility to review weather conditions, flight battery requirements, and UAS performance limitations prior to conducting the flight.UAS Aerial Solutions 333 Exemption

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16 4. UA S Operating Procedures

4.1 All UAS flight operations will be conducted during daylight hours.

4.2 All UAS operations will be conducted in VFR conditions.

4.3 No UAS operation will be conducted with less cloud clearance or visibly then is allowed by FAR 91.155.

4.4 No U AS flight operations will be conducted beyond the visual sight of both

the PIC and the VO.

4.5 No UAS flight operation will be conducted above a vertical height of 400ft

AGL

. 4.6 NO UAS flight operations will be conducted within highly populated areas.

4.7 The PIC wil l not fl y the UAS at speeds to exceed 87 KTS ground speed.

4.8 The PIC will insure that no person, other then those who agree to participate in the operation and are trained in UAS operational safety , are within 500ft of

horizontal distance from the UAS during flight operations

. 4.9 The PIC will insure that the UAS in flight comes no closer then 500ft of vehicles or structures, with the exception of those that are a part of the operation

. UAS Aerial Solutions will obtain a signed consent form from the

owner or autho rized representative of any vehicle or structure the UAS in flight will come within 500ft of.

4.10 Prior to any UAS flight operation the PIC will consult current FAA aeronautical sectional charts and airport facility directory to insure that no flight operation will come within 5NM of an airport with a control tower, 3NM of an airport not having an operational control tower but having a published instrument approach procedure, 2NM of an airport not having an operational control tower or instrument approach proce dure, or 2NM of a heliport having an instrument approach procedure without having an appropriate authorization from the ATC controlling facility and airport

manager

. 4.11 PIC will remain clear and yield right of way to all manned aircraft operations of all cate gory and classes.

4.12 The PIC prior to conducting UAS flight operations will review current aeronautical charts, TFRs, and NOTAMS to insure that no flight operations will be conducted within an active restricted area, prohibited area, warning
area, or TFR.

4.13 P rior to UAS operations for the motion picture or television industry, the operator will comply with regulations set forth in FAA order 8900.1, Volume 3, chapter 8, section 1 (Certificate of Waiver for Motion Picture and

Television Filming).

4.14 Operator will obtain an Air Traffic Organization (ATO) certificate of waiver or authorization (COA) prior to conduction UAS operations that a COA is required

. 4.15 Operator, as required by the COA, will request a NOTAM be filed for the UAS operation at least 48 ho urs in advance, but not more than 72 hours in

advance.UAS Aerial Solutions 333 Exemption

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17 Additional(Information,(Views,(or(A rguments( to(Support(our(Request

Turbine!Aircraft!Logistics!views!our!long!experience!aviation,!working!closely!with! the!local!FAA!FSDO!highly!qualifies!us!to!b e!granted!exemption!from!the!requested! FAR’s.!With!the!above!provided!information,!we!are!able!to!bring!a!far!higher!level! of!safety!to!our!operations!that!few!section!333!exemption!holds!will!be!able!to! offer.!With!our!manned!aircraft!relationship!with!th e!FAA,!we!feel!confidant!we!will! be!well!capable!of!adjusting!to!new!regulations!and!procedures!as!they!are!issued!by!

the!FAA.!

Exercising(the(P rivileges( of(Requested(Exemption(O utside(the(United(States

UAS!Aerial!Solutions!at!this!time!is!not!seeking!to extend!the!privileges!of!this! exemption!beyond!the boarders!of!the United!States!of!America.!

Sincerely,

Carson W. Lee

President

UAS Aerial Solutions , LLC