This petition and revision is being submitted on our behalf without legal counsel or

consulting services.

Granting the present Petition of ExplAura LLC will further the public interest by allowing ExplAura to safely, efficiently, and economically perform agricultural surveying, sUAS operator training, real estate photography, product demonstrations, research and development, civil construction surveying, and marketing over certain areas of the
United States. Additionally, use of our fleet of sUAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. The benefits of ExplAura’s proposed operation of sUAS will be realized without implicating any privacy issues.

sUAS, as described from now on will include our fleet of unmanned aerial vehicles : Turbo Ace Matrix

- S Rotorcraft

DIJ S800 EVO Rotorcraft DJI Inspire 1 Skywalker X8 fixed wing aircraft Horten Ventis fixed wing aircraft

Benefit s to Mankind

1. The public will benefit from decreased congestion of t he NAS. ExplAura’s sUAS are battery powered and serve as a safe, efficient, and
economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed t o perform aerial acquisitions, an exemption allowing the use of sUAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by r educing the number of manned aircraft, operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The sUAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting ae rial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The p ublic will benefit from the safety and efficien cy o f ExplAura’s sUAS. Conducting aerial acquisitions with the sUAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery power and electric motors, the sUAS produce no air pollution, and is the most viable environmentally conscious alternative to the average Cessna 150 typically utilized for aerial video and photography, while burning ap proximately 5

- 10 gallons per hour ofleaded aviation fuel. Our sUAS, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than internal combustion engine s . By using the sUAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially re duced or completely eliminated. Aside from the lack of crew
members located on

- board the aircraft, the sUAS has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations. It should be noted that ExplAura also
carries full in surance with up to $2 million liability.

3. Performing aerial video and photography operations with sUAS will b ene fit the

e conomy. In addition to being safe and efficient, the sUAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the sUAS will allow United States based companies, like ExplAura, to remain competitive and contribute to growth of the U.S. e conomy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating our battery powered sUAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned airc raft. By operating sUAS, companies such as ExplAura, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial perfor mance of U.S. companies, through commercial use of the sUAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain compet itive both in the United
States and abroad.

4. There are no privacy i ssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, ExplAura’s proposed operation of sUAS will not implicate any privacy issues. Spec ifically, the sUAS will be operated only in compliance with all involved property owners as well as in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.Additional information

I. SAFE OPERATIONS

ExplAura Pilots have over 20 years of experience in model aircraft technology. We have a complete grasp of the limitations of these systems. Our experience in building, testing and flying these systems gives us full knowledge of safe ope rations. ExplAura is concerned with conducting safe operations. Last year upon learning the requirements for a 333 exemption, we took to the skies and became licensed pilots. As pilots, we fully understand the risks sUAS could impose on manned aircraft. We understand the different classes of airspace, and we have experience working with local airports. We rented a commercial pilot, and commercial mapping equipment to test aerial mapping from a Cessna. We found each method has its benefits, and that an 8lb s sUAS is much safer than a fully loaded Cessna with 2 souls on board.

II. AGRICULTURAL SURVEYING

With the projected increase in world population, producers must find a way to drastically increase agricultural output. sUAS are a feasible method to obta in information of agricultural cropland to determine optimum inputs that result in higher yields, cost savings to farmers, reduce environmental impact of excess fertilizers, and the overall benefit of society.

III. sUAS OPERATOR TRAINING

As the number of drone operators increases drastically, operators need to know safe operating procedures in the NAS. As licensed pilots, and lifelong model aviation enthusiasts, we will be able to provide our expertise to potential sUAS operators.

IV. REAL ESTATE PHO TOGRAPHY

To further the economic drive of commercial and residential real estate, aerial photos and video tours are a huge asset. Our central Iowa location has a large amount of new and old buildings entering the market. ExplAura would like to enter this market to help both sides of the sale share information of the properties.

V. PRODUCT DEMONSTRATIONS,Many potential contracts ask to see what they are paying for. These demo flights

would occur away from office buildings, most likely on an agriculture field, or landfill site. While live demonstrations are more powerful than video clips, they are very dependent on location and safety factors. These facts would remain primary to the location decision making process.

VI. RESEARCH AND DEVELOP MENT

We have possible airframes which would require research, development and testing. These actions would be performed at a local AMA field under their safety guild
lines.

VII. CIVIL CONSTRUCTION SURVEYING

Our sUAS provide engineers in the quarry , mine, and landfill industries, highly detailed and accurate data. This data will work to prevent material theft

, cross check inventories and monitor compaction rates. Our services will provide geologists and engineers the data needed to plan future minin g s ites, and improve existing sites.
This allows plant managers to make better business decisions , save company money, reduce waste and environmental impact all while flying a lightweight, unmanned,
electric vehicle.

VIII. AERIAL MARKETING VIDEOGRAPHY

Unmanned Aircraft System are often seen as superior to helicopters as an aerial video gathering platform due to the smaller footprint, personnel cost, reduced noise,
and a much smaller environmental and public safety impact. Granting ExplAura this
exempt ion will befit the local film making and marketing economy by lessening the cost and risk of using a full sized Rotorcraft.

Regulations from which the exemption is requested: 14 C.F.R. § 45.23(b)

14 CFR Part 21 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2)
14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b)14 CFR § 91.205(b)

14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b)

FAR section Subject Justification 14 CFR § 45.23(b) Requirement to display re gistration number on vehicle Insufficient space on veh i cle

14 CFR Part 21 Aircraft certification r equirements and proc e dures Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS 14 CFR § 91.7 (a) Airworthiness requir e ment Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to
be av ailable in the cockpit No one aboard to read ma nual 14 CFR § 91.103(b) Requirement for crew me mbers to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual co ntrols during flight instru c tion No one aboard to operate
controls
14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation
below these altitudes
14 CFR § 91.121 Altimeter settings No one aboard to read a ltimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel
14 CFR § 91.203 (a) & (b) Requirement for registr a tion
and airworthiness ce r tif icates to be onboard No one aboard to read ce r ti ficates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read
14 CFR § 91.215 Transponder requirement Vehicle has insufficient us eful load; will be opera t ed b elow ATC radar co v erage 14 CFR § 91.405 (a) Inspection requirements Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS 14 CFR § 91.407(a) (1) Inspection approval r equirements Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS14 CFR § 91.417 (a) & (b) Maintenance records r equirements Designed for manned ai rcraft; not suitable for off

the

- shelf sUAS