James E. Mackler Attorney 615.238.6312 (Direct Phone) 615.248.4668 (Direct Fax) jmackler@bonelaw.com

{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) June 2 4 , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE, West Building Ground Floor, Room W12

- 140, Washington, DC 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.40 9(a)(1) and (2); 91.417(a) & (b).

PETITION FOR SUMMARY EXEMPTION

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, Power Consulting Associates , LLC, (“ PCA ”) an operator of Small

Unmanned Aircraft (UA) hereby applies for an exemption from the listed Federal Aviation

Regulations ("FARs") to operate an unmanned aircraft system (UAS) to conduct inspections of

energy infrastructure, such as transmission and dist ribution lines and substations.

. PCA is eligible

for a summary exemption for aerial data collection

. 1

QUICK REFERENCE SUMMARY:

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 (parti culate measurement, etc.), or any other gathering of data by instruments

aboard the UA. See exemption #. 11482.{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) • Types of aircraft to be flown:

o DJI Phantom 2

o DJI Inspire

• Technical manuals are all currently available online at the following URLs:

o Phantom 2: http://www.dji.com/product/phantom

- 2/download

o Inspire 1: http://www.dji.com/product/inspire

- 1/download

• The operations will be for aerial data collection to conduct inspections of energy

infrastructure

. 2

• PCA already agree s to all the restrictions listed in Exemption # 113 26 granted to PPC

Electric Utilities Corporation for Aerial Data Collection on April 1 6 , 2015. Those

restrictions are listed below. Based upon the FAA’s recent guidance, this petition is

eligible for summary exemption and should be granted immediately.

PCA requests that the publication and comment procedures be waived in accordance with

14 C.F.R. § 11.87 which states :

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of

my petition for exemption?

The FAA may not publish a summary of your petition for exemption and request

comments if you present or we find goo d cause why we should not delay action on your

petition. The factors we consider in deciding not to request comment include:

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously.

(c) Whether our delaying action on your petition would affect you adversely.

(d) Whether you filed your petition in a timely manner.

Corresponding to the above sub

- sections, PCA has good cause to request the FAA to

waive the comment period and not delay action on the petition because:

2 Exemption 11326 to PPC Electric was for “aerial data collection ” intended “ to conduct inspections of energy infrastructure, such as transmission and distribution lines and substations.”{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) (a) PCA would not set any precedent. PCA agrees to the SAME exact limitations as

Exemption # 113 26 , except we are proposing to operate the DJI line of products listed

above. These are commonly used aircraft. For example:

i. Exemptions # 11347 and 11306 were for the DJI Phantom 2.

ii. Exemption #11342 was for the DJI Inspire 1

. (b) The relief requested is iden tical to that granted, without publication for comment, in

Exemption # 113 26

. The FAA has also issued grants of exception in circumstances

similar in all material respects to those presented in this petition in exemption #

11062 to Astraeus Aerial, 11109 to Clayco, Inc, 11112 to VDOS Global, LLC, and

11213 to Aeryon Labs, Inc.

(c) Delaying the granting of this petition would adversely affect the public, the FAA,

and PCA

. The public, as well as the FAA, would be better served by the FAA

quickly granting this petition and thereby freeing up limited FAA resources and

allowing FAA inspectors to dedicate their time and attention to much higher

priorities. Moreover, PCA is adversely affected by the above listed regulations.

Finally, the enhanced safety achieved us ing an unmanned ai rcraft with the

specifications described in this petition 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 fin d that the UAS operation that

would be enabled by this exemption is in the public interest.

(d) The petition has been filed in a timely manner.

Petitioner’s contact info:

Bone, McAllester Norton, PLLC
Attn: James Mackler
Phone: 615

- 238

- 6312
Email: jmackler@bonelaw.com Address: 511 Union Street, Suite 1600, Nashville, Tennessee 37219{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) Power Consulting Associates, LLC Attn: David Grooms, President and CEO
Phone: 615

- 645

- 9344 Email: david.grooms@pca

- llc.biz
Address: 2616 Grissom Drive , Nashville, Tenne ssee 37204

Regulations from which the exemption is requested:

• 14 C.F.R. § 61.23(a) and (c)

• 14 C.F.R. § 61.101(e)(4) and (5)

• 14 C.F.R. § 61.113(a)

• 14 C.F.R. § 61.315(a)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.119(c)

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)(1)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(1) & (2)

• 14 C.F.R. § 91.417(a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing

Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law directs

the Secretary of Transportation to consider whether certain unmanned aircraft systems may

operate safely in the national airspace system (NAS) before completion of the rulemaking

required under Section 332 of the FAA Moderniz ation and Reform Act. In making this

determination, the Secretary is required to determine which types of UA do not create a hazard to

users of the NAS or the public or pose a threat to national security in light of the following:

• The UA’s size, weight, sp eed, and operational capability;

• Operation of the UA in close proximity to airports and populated areas; and,

• Operation of the UA within visual line of sight of the operator (VLOS). 3

If the Secretary determines that such vehicles "may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such aircraft in the

national airspace system." Id. § 333(c) (emphasis added). 4

3 FAA Modernization and Reform Act of 2012 at § 333(a).{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is defined

under § 40101 of the Act that includes UAS’s, from the requirement that all civ il aircraft must

have a current airworthiness certificate.

“The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if

the Administrator fi nds the exemption in the public interest.” 49 U.S.C. § 44701(f). See also 49

U.S.C. § 44711(b).

OPERATING DOCUMENTS

PCA will operate only within the limitations below and the performance parameters se t
forth in the aircraft manuals and in the proprietary technical documents that will submitted under

separate cover:

• Flight Operations and Procedures Manual (FOPM).

• Aircraft Flight Manual (AFM) for the DJI Inspire 1.

• Aircraft Flight Manual (AFM) for the DJI Phantom 2

.

• Qualification Manual for the Pilot In C ommand.

• Qualification Manual for the Visual Observer.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein applies to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These limitations

provide for at least an equivalent or even higher level of safety to operations under the current

regulatory structure.

These limitations and conditions are identical to Exemption # 113 26 except for the

difference in aircraft. P CA agrees to be bound when conducting commercial UA operations. The

list of limitations and conditions include the following:

4 Applicant interprets this provision to place the duty on the Administrator to not only process applications for

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 1. Operations authorized by this grant of exe mption are li m ited to the DJI line of aircraft

listed above when weighing less than 55 pounds including payload. Proposed operations

of any other a i r c ra f t will requi r e a new petition or a p e tition to a m end this e x e mption.

2. Operations f or the purpose of closed

- set m otion picture and television filming are

not per m itt e d.

3. The UA m a y not be operated at a s p eed excee d ing 87 knots (100 m iles per hour). T h e

exe mption holder m ay use either groundspeed or calibrated airspeed to deter m ine

co mpliance with the 87 knot speed restrict i on. In no case will the UA be operated at
airspeeds greater than t h e m ax i m u m UA operating airspeed recommended by the aircraft

m anufacturer.

4. The UA m u st be operated at an altitude of no m o re than 400 f eet above ground level

(AGL). Altitude m ust be reported in feet AGL.

5. The UA m u st be operated within visual line of sight (VLOS) of t h e PIC at all ti m es. This

req u ir e s the PIC to be able to u s e hu m an vision unaided by any device other than

correcti v e lenses, as specified on the PIC’s FAA

- issued air m an m edical certifi c ate o r U.S.

driver ’ s li c ense.

6. All oper a ti o ns m ust utilize a vis u al o bserver (VO). The UA must be op e rated within the

visual line of sight (VLOS) of the PIC and VO at all ti m es. The VO m ay be used to

satisfy the VLOS require m ent as long as the P IC always maintains VLOS capability.

The VO and PIC m ust be able to c o mmunicate verbally at all ti m es; ele c tronic

messaging o r texting is not per m itted d uring f lig h t operations. The PIC m ust be

designated before the flight and cannot transfer his or her designation for the duration of

the flight. T he PIC m ust ensure t h at the VO can perform the duties required of the VO.

7. This exe m ption and all docu m ents needed to operate the UAS and conduct its

operations in accorda n ce with the conditions a n d li m itations stated in t h is grant of

exe m ption, are hereinafter referred to as the operating docu m ents. 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,{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 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 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

f unctional 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 co mponents, ite m s, or equip m ent. 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.{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial,

private, r ecreational, 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

PI C 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 t he 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 currenc y must be logged in a manner consistent with 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 consi stent 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 flig hts, 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 def ined 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 m a y not operate within 5 nautical m iles of an airport refere n ce p oint (ARP) a s

denoted in the current F AA Airport/Faci l ity Directory (AFD) or for airports not denoted

with an ARP, the center of the airport sy m bol as denoted on the current

FAA

- published aerona u tic a l ch a rt, u nless a letter of agree m ent with t h at airpo r t’s

m anage m ent is obt a i ned or otherwise per m itted b y a COA issued to the e xe m ption

holder. The letter of agree m ent with the a i rport m anage m ent must be m ade available to

the Ad m i nistrator or any law enforce m ent official upon request.{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 17. The UA m a y 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 m iles from the PIC.

18. If the UAS loses com m unications or loses its GPS signal, the UA m ust return to a

pre

- deter m ined location within t h e p rivate or co n t rolled

- acce s s property.

19. The PIC m u st abort the f light in the event of unpredicted obstacles or e m ergencies.

20. The PIC is prohibited fr o m beginning a flight unless (con s idering 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 m anufacturer if greater.

21. Air Traffic Organizati o n (ATO) Certificate of Waiver or A utho r ization (COA). All

operations shall be conducted in accord a nce with an ATO

- issued COA. The

exe mption holder m ay apply for a new or a m ended COA if it intends to conduct

operations that cannot be conducted under the ter m s of the attached COA.

22. All aircraft operated in accor d a n ce with this exemption m ust be identified by serial

nu m ber, registered in accordance with 14 CFR p a rt 47, and have identification

( N

− Nu m ber) m arkings in accorda n ce with 14 CFR part 45, Subpart C. Markings m ust be

as large as practica b le.

23. Docu m ents used by the operator to ensure t h e safe operation and flight of the UAS and

any docu m e nts required under 14 CFR §§ 91.9 and 91.203 m u st be available to the PIC

at the G round Control Station of the UAS any ti m e the aircraft is operating. These

doc u m ents m ust be m ade availa b l e to the Ad m i nistrator or any law enforcement official

upon request.

24. The UA m u st re m ain clear and give w a y to all m anned aviation operations and acti v ities

a t all ti m es.

25. The UAS may not be operated by the PIC from any m oving 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 p r otect nonparticipating persons

from the UA and/or de b ris in the eve n t of an acci d ent. The o p erat o r m ust ensure

that nonparticipating persons re m ain under s u ch protection. If a situation arises{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operatio n s m ust cease im m ediately in a m anner ensuring the safety

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struc t ures has granted per m ission

for operating closer to those objects and the PIC has m ade a safety assess m ent of

the risk of operating closer to those objects and deter m ined that it does not

present an u ndue hazard.

c. The PIC, VO, operator trainees or e s sential pers o ns are not c o nsidered

nonparticipating persons under this exe mption.

27. All operati o ns shall b e conducted o v er pri v ate o r contr o lle d

- access pro p erty with

per m ission from the property owner/contr o ller or authorized representative. Per m ission

from property owner/co n t roller o r authorized rep r esent a tive w ill b e obtained for each

flight to be conducted.

28. Any incident, accident, or flight operation that tr a nsgress e s t h e later a l or v ertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA ' s UAS Integration O ff i ce (AF S

− 80) within 24 hours. Accidents m ust be

reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: w ww.ntsb.gov

.

STATUTORY CRITERIA PROVIDED IN SECTION 333

The Federal Aviation Act (49 U.S.C.§ 44701 (f)) and Section 333 of the Reform Act both

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that

the UAS operated without an airworthiness certificate and under the restrictions proposed will be

at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate wi thout the restrictions and conditions proposed.

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an

onboard pilot, there is no ability or place to carry certification and registration documents or to{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) display them on the unmanne d aircraft. An equivalent level of safety will be achieved by keeping

these documents at the ground control point where the pilot flying the UA will have immediate

access to them. Given the size of the unmanned aircraft, the FAA registration number will be

displayed on the airframe in as large a font as possible.

14 C.F.R. § 61.23(a) & (c): M EDICAL C ERTIFICATES

Exemption # 11221, # 11284, #11326 and many others have provided that a U.S.

driver’s license could be used in lieu of the medical certificate.

14 C.F.R. § 61.101( e )(4) & (5): R ECREATIONAL P ILOT P RIVILEGES AND L IMITATIONS & 14

C.F.R. § 61.315( a ): S PORT P ILOT L IMITATIONS

.

Exemption # 11221, # 11284, #11326 and many others have provided that the “PIC

must hold either an airline transport, commercial, private, recreational, or sport pilot

certificate.” Likewise, PCA is also performing commercial UAS work and is asking for the

same restrictions which have been previously deemed to provide an equivalent level of safety

as the burdensome regulations.

14 C.F.R. § 61.113 (a): P RIVATE P ILOT P RIVILEGES A ND L IMITATIONS : P ILOT I N

C OMMAND

.

Sub

- sections 61.113(a) limit private pilots to non

- commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent

level of safety of current operations by requiring the PIC operating the airc raft to have a

private pilot's license rather than a commercial pilot's license to operate this small UAS.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely

controlled with no living thing on board.

14 C.F.R. § 91.7 ( a ): C IVIL A IRCRAFT A IRWORTHINESS

.

As already noted, t he Phantom 2 and DJI Inspire 1 have been previously approved in

many past exemptions, including # 11784 . Therefore, this aircraft should not be required to

have an airworthiness certificate based upon the FAA’s previous determinations.

14 C.F.R. § 91.119: M INIMUM S AFE A LTITUDES{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119

(d) allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescrib ed for helicopters

by the FAA.

Because of the lack of flammable fuel, any risk associated with these operations is

far less than those presently presented with conventional aircraft operating at or below 500

AGL. In addition, the low

- altitude operations of the UAS will ensure separation between

these small UAS operations and the operations of conventional aircraft that must comply

with Section 91.119.

14 C.F.R. § 91.121: A LTIMETER S ETTINGS

This regulation requires each person operating an aircraft to main tain cruising altitude by

reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate

altimeter setting available before departure." As the UAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety

will be achieved by the operator, pursuant to the operating manuals.

14 C.F.R. § 91.151( a ): F UEL R EQUIREMENTS FOR F LIGHT IN VFR C ONDITIONS

Section 91.151 (a) prohibits an individual from beginn ing "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 of intended landing, and, assuming normal cruising speed

- (1) During the

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes."

Applicant believes that an equivalent level of safety can be achieved by prohibiting the

PIC from beginning a UAS flight unless (considering wind and forecast weather conditi ons and

assuming normal cruising speed) “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.” Exemption # 11 326 , at page 5.

14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): M AINTENANCE

I NSPECTIONS{01245115.1 }

Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) These regulations require that an aircraft operator or owner "shall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of

this chapter" 5 and others shall inspect or maintain the aircraft in compliance with Part 43. Given

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. An equivalent level of safety wil l be achieved because

these small UAS’s are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. Moreover, the operator is the person most familiar

with the aircraft and best suited to mainta in the aircraft in an airworthy condition to provide the

equivalent level of safety. Lastly, the petitioner will operate in accordance with the manuals

submitted confidentially which will provide an equivalent level of safety as the burdensome

regulations.

CONCLUSION:

The operation of PCA using a small UAS, weighing less than 55 lbs., conducted under

the proposed restrictions outlined above, will provide an equivalent level of safety supporting the

grant of the exemptions requested herein.

If I can be of any assistance to further expedite this petition, please do not hesitate to

contact me at (615) 238

- 6312 or at my email jmackler@bonelaw.com

.

Sincerely yours,

____________________ James E Mackler, Esq.

5 14 C.F.R. § 91.405(a).