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February 1, 2016 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 20590 Central Virginia Aerial Solutions, LLC 4132 Richmond Hwy lynchburg, VA 24501 Kyle Falwell: {434} 851-1992 Kyle@bonairbrokerage.com ! ;**~** '

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Additional Services Request to Exemption No. 12781, Regulatory Docket No. FAA-2015-1450 Dated September8, 2015, grantedto Central Virginia Aerial Solutions, LLC. Dear Sir or Madam: Central Virginia Aerial Solutions (CVAS) was granted exemption from several provisions ofthe Federal Aviation Regulations (FAR) in accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 on September 8, 2015, under Exemption No. 12781 (Regulatory Docket FAA 2015-1450). CVAS was authorized to operate small lightweight DJI unmanned aircraft systems (UASs) (detailed below) commercially forthe purpose ofprivate property mapping and surveys in airspace regulated bythe Federal Aviation Administration (FAA). CVAS was granted this exemption under Part 21; §§ 45.23(b); 61.113(a) and (b); 61.133(a); 91.7(a); 91.9(b)(2); 91.109{a); 91.119; 91.15l{a); 91.203(a) and (b); 91.319(a)(l); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) ofTitle 14, Code of Federal Regulations (14 CFR part 11).
The purpose ofthis letter is to requesttwo additional services to be added to our exemption: Search and Rescue Emergency Services The public interest in grantingthis exemption request is served by, among others, the following:

• The use of UASs improves public safety and reduces risk by alleviatingthe public's exposure to danger and emissions associated with conventional aerial methods that are very heavy, fast, and carry passengers, flammable fuel and cargo. • Since UASs being operated are very small and contain no flammable fuel; in the remote event ofan accident, will cause no damage or injuries.



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• Given thatthe costto conduct an inspection using a UAS is considerably less than available alternatives, this importanttask can be accomplished which will benefit everyone. • CVAS use of UAS's in lieu ofcomparatively hazardous operations nowconducted with fixed wing and rotary conventional aircraft, the FAA can have confidencethatthe operations will achieve at least an equivalent level orgreater level ofsafety. Approval of this exemption would thereby enhance safety and fulfil the Secretary of Transportation's responsibilities underSection333(c) ofthe Reform Act to "establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."
CVAS will also work closely with the local FSDO to monitorand report drone operatorsthat are notcompliantwith the FAA exemptions required. The OJI UASs systems consist of lightweight battery operated aircrafts, an integrated state of the art ground station system and communications equipment. The aircrafts carry an onboard high resolution camera (with first person view) that allows us to conduct precision aerial photography and video. This technology will assist the Pilot in Commands (PIC) in providingthe upmost safety procedures and the public will benefit from these services. CVAS services will help the commercial industry and not bring harm to any person in the air or on the ground. Kyle Falwell, The co-owner ofCVAS is an ATP pilot with Type ratings in the CE 500 and CE525 aircraft. Kyle will personally oversee all operations ofsafety. His extensive aviation background will on aid in the safety ofall CVAS operations. The aircrafts ofCVAS will be operated in the field ofview with both a PIC and aground-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following additional restrictions:
• All operations will occur in Class G airspace (below

### 400' AGL) • Operations will be operated over private property, commercial property, or property (not federal or state) with permission ofthe land owner • The aircraft will not operate within SNM ofany airport or heliport (unless wellcoordinated with the FAA and airport/heliport (detailed flight plans)) • Operations will be limited to day, visual meteorological conditions • Aircraftwill remain within Visual Line ofSign at no greaterthan Y2 NM ofthe PIC at all times • Whilethe aircraft is airborne, the VO will be positioned within voice distance tothe PIC The PIC and VO will meetthe requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete all necessary maintenance set forth bythe FAA or manufacturer.
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We submitthatthe combination ofthe aircrafts light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, the FAA can have confidence thatthe operation will have an equivalent or greater level ofsafety ofmanned aircraft performing similar operations. CVAS is dedicated to safety and believes the company will not bring any harm tothe public (air orground). CVAS proposes to operate the DJI UASs Phantom 2, Phantom 2+, and the Inspire 1. The petitioner states that given the size, weight, speed and limited operating area associated with the aircraftto be utilized bythe applicant, an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted and meetsthe requirements for an equivalent level ofsafety under 14 CFR Part 11 and Section 333 of P.L. 112-95 (Section 333}. The petitionerfurther states that UAS operated without an airworthiness certificate in the limited environment and underthe conditions and limitations proposed bythe petitionerwill be at least as safe, or safer, than aconventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificated issued under 14CFR Part 21, Subpart Hand not subject tothe proposed conditions and limitations. The petitioner states thatthe unmanned aircraft (UA} to be operated underthis request is a rotary-wing aircraft, with the smallest aircraftweighing 2.5 lbs (largest weighing 7.6 lbs) fully loaded, flies at a maximum speed of29 knots (not recommended), carries neither a pilot nor passengers, carries no flammable fuels, and operates exclusively within a pre-disclosed area. Operations underthis exemption will be tightlycontrolled and monitored by both the operator, spotter, and local public safety requirements. DJI Aircraft Specs: CVAS operates thefollowing UAS Phantom 2(1): Serial Number: PH645195943 Weight: 2.5 pounds Max Speed: 29 knots Flight Time: 25 minutes Battery: 3S LiPo, 5200mAh, 11.1V Operating Frequency: 2.4GHz ISM (range 1000 meters) 

### Note: We onlyoperate with 100% line of sightto theAircraft(we do notlose visual oftheaircraft) First Person View: Yes Phantom 2 Vision + (2): Serial Number: PH645199878 Serial Number: PH645240161 Weight: 2.7 pounds Max Speed: 29 knots Flight Time: 25 minutes 31PageBattery: 3S LiPo, 5200mAh, 11.1V Operating Frequency: 5.728-5.85 GHz First Person View: Yes Inspire (1): Serial Number: W13DCJ28050067, W13DCA18020091, W13DCB16020084 Weight: 7.6 pounds Max Speed: 31 knots Flight Time: 18 minutes Battery: LiPo(6S, 10000mAh"'15000mAh, 15C(Min)) Operating Frequency: 2.4GHz ISM (range 1000 meters) 

### Note: We onlyoperate with 100%line of sightto theAircraft(we do notlose visual oftheaircraft) First Person View: Yes Phantom 3 Advance: Serial Number: P77DCH17010801 Weight: 1280g Max Speed: 16 m/s FlightTime: 21 minutes Battery: Lipo (2s, 6000 mah) Operating Frequency: 2.4 GHz- 2.482 GHz 

### Note: We onlyoperate with 100% line of sightto the Aircraft(we do notJose visual ofthe aircraft) First Person View: Yes UAS Pilot In Command The petitioner asserts that operations ofthe OJI should not be required to hold a commercial or private pilot certificate. However I ChiefSafety Officer does. The petitioner notesthat unlike a conventional aircraftthat carries a pilot, passengers, and cargo, the OJI UASs are remotely controlled with no passengers or property ofothers on board. The petitioner proposes that operator requirements should take into accountthe characteristics ofthe particular UAS. The petitioner states thatthe OJI UASs have high degree ofpre-programmed control and various built-in technical capabilities that strictly limitthe potential for operation outside ofthe operating conditions set forth in its petition for exemption. CVAS will not allowthe PIC to fly any aircraft without at least 40 hours oftrainingflighttime with the exact aircraft used forthe business. The company has several privatetesting areas that are in a remote location with novertical obstructions. This allows the PICs for CVAS totest 41Page• . r

all the systems and understand fail safe featurestothe fullest extent before conducting business with the UAS. CVAS's PICs are well versed in all the safetyfeatures on the DJI aircrafts. They have spent countless hours perfectingthe pre-flight, flight, and post flight procedures. CVAS's PICs can perform all necessary maintenance on the DJI aircrafts and iffor some reason they are not able tofix aircraftto safety specifications, theywill seek assistance with the strict parameters ofthe FAA and the DJI Flight Operational Manuals.

The name and contact information ofthe applicants are: Central Virginia Aerial Solutions, LLC 4132 Richmond Hwy Lynchburg, VA 24501 Kyle Falwell: (434) 851-1992 Kyle@bonairbrokerage.com

CVAS is prepared to modifyoramend any part ofthis request to satisfythe need for an equivalent level ofsafety. We lookforward to workingwith youroffice. Please contact us any time ifyou require additional information or clarification.
Sincerely,



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