27 October, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 . ,...

Re: Application for Issuance ofSection 333 Exemption Dear Siror Madam, - -- '

..

Pursuantto Section

### 33~.ofth'e FAA-Modernization anq

### ~efo,rm Act of2012 (the "Reform · Act") and14 CFR,Pa·rt 11, Steve Young (A.pplicant), Private Pilot (cert# 3805867), and ownerof Petroleum Field Services, LLC ("PFS."), herebyappliesforan exemption from

. the listed Federal Aviation Regulations ("FARs") to allowcommercial operatiqn of designated UAS, provide<;! such operations are conducted within and underthe conditions outlined.herein oras may be established by the

### FAAas required bYSection_**~33.** Commercial operation ofa UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land sur:veying, engineering and other related professional activities.
2. Aerial inspection/photographyof residential/commercial structures undercontractwith the owners orlocal governmentauthority.
4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to oil and gas facilities, proposed development sites, reclamation projects, electrical power lines, wind turbines and cell towers.
5. Aerial video/photography or providing live video feed to assistwith search and rescue operations in cases ofan emergency or natural disasteronlywhen the local authorities or government has requested it by contract ordonation. The use ofthese unmanned aircraftwould be a much saferalternative to current practices throughout industry. Petroleum Field Services, LLC ("PFS") 

### IApplicant herewith applies forthe**issu~nce** of an exemption under Section 333 ofthe FAA Modernization and Reform Act of 2012 based many previously issued exemptions including Exemption 11110 issued to Trimble Navigation Ltd. (''Trimble") on December 10, 2014 in FAA bocket 2014-0367. The requested**ex~mption·**would allow**~FS**to operate the UX5, UXHP and the multirotorZX5 aircraft manufactured by Trimble or otherTrimble aircraft approved for commercial operations:under Exemption 11110, as amended.· PFS notes that the FAArecently authorized use ofthe Trimble aircraft by athird party in Exemption No. 11257, Regulatory Docket No. FAA-2014-0889, on April 2, 2015, under updated conditions, and PFS hereby confirms that it will accept such conditions as well as those setforth in Exemption No. 11240, Regulatory Docket No. FAA-2014-0894. The Trimble-drone ZX5 is a rotor aircraft weighing a maximum of 11 lbs. at takeoff (in any event, less than 55 lbs.), with payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be accomplished as set forth in the Operations Manual.
All the listed aircraft will be operated in accordance with the procedures set forth in the manufacturers operating manuals. The FAA has issued exemption grants in circumstances similar in all material respects to those presented in this petition. In Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), No. 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), No. 11112 to VDOS Global, LLC (see Docket No.**FAA-2014~0382),** and No. 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 ofsignificantly greater proportions carrying crew in addition to flammable fuel, gave the FAA good cause to find that the UAS operation at issue was in the public interest. To the extent necessary, applicant refers the FAA to its exemption request submitted in Docket FAA-2015-1192 for a listing of regulations (as amended by Exemption1111OA) forwhich an exemption is being sought; a demonstration ofthe public interest; and a showing ofan equivalent level of safety. Based on the foregoing and due to the precedent set by previously approved FAA exemptions for aerial data collection PFS requests that this request is granted. Finally, PFS and Applicant requestto be granted authorization to conduct commercial operations with all of its aircraft under this exemption be allowed to operate without a separate Certificate ofOperation ("GOA") in Class G airspace, at or below 400 feet AGL and at least 5 nautical miles from the geographic centerofan airport, unless a letter ofagreement with the airport's management is obtained. PFS acknowledges that undercurrent FAA guidance a separate Certificate ofWaiver orAuthorization ("GOA") is required to fly at altitudes in excess of400 feet AGL, and it will applyfor COAs where required. PFS will also file NOTAMsfor its flights, as required.

The name and contact information forthe applicant is: Steve Young- Private Pilot cert #3805867 and Petroleum Field Services, LLC 7535 Hilltop Circle Denver, CO 80221 Phone: (303) 928-7128 Steve@petro-fs.comPFS 

### IApplicant intends to operate the UX5 orthe UX5hp from Trimble and/ orthe ZX5 from time to time and would like to put this technology into effect no laterthan February 2016. PFS 

### I Applicant will operate it in strict compliance with the conditions set forth by the FAA and as described in the manufacturers operating manuals.

Ifyou have any questions, please contact the undersigned.

Respectfully,

Steve Young Petroleum Field Services, LLC 7535 Hilltop Circle Denver, CO 80221 Phone: (303)-928-7128 Steve@petro-fs.com

Applicant interprets Section 333 as placing a dutyon the Administrator not onlyto process applicationsfor exemptions under Section 333 but, ifhe determinesthatthe conditions set forth herein do notfulfill the statutory requirements forapproval, to craft conditions forthe safe operation ofthe UAS.