U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, SE Washington, D.C. 20590 August 10 , 2015

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR 91.7(a); 91.9(B)(2); 91.103; 91.109; 91.119 (c); 91.121; 91.151(a)(1); 91.203(a)(b); 91.405(a); 91.407(a)(1); 91.409(a)(1)and (2); 91.417(a)&(b); 45.23(b); Part 21; 61.113(a) & (b)

Dear Sir or Madam:

Pursuant to the FAA Moderni zation and Reform Act of 2012 ( Reform Act), and the procedures contained
in 14 C.F.R. 11, Xtreme Aeropix , Inc . ( “ Aeropix ” ) , an owner and pilot of small unmanned aircraft, hereby applies for an exempt ion from the Federal Aviation Regulations (FARs) listed above so that Aeropix may operate its small unmanned aircraft / lightweight unmanned aircraft system s ( s UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA); as long as such operations are conducted within and under the conditions outlined herein or as may be established by t he FAA as

r equired by Section 333. As detailed in this document, the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is 1) limited, 2) predetermined, and 3)

access controlled . The use of sUAS in these app lications will help enhance the safety, quality, and efficiency of many similar activities which are currently performed manually. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’ s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the petitioner is: Xtreme Aeropix Inc. Anthony Jones / President

26 43 George Washington Memorial Hwy

Suite B Yorktown, VA 23693

757

- 806

- 6412 Email tony.j@XtremeAeropix.com

It is the request of Aeropix for exemptions listed above in order to legally and safely operate the DJI Inspire 1, DJI Phantom 3 Professional, 3D Robotics X8 + , and 3D Robotics Aero

- M UAS , in the National Airspace System, supporting construction, insurance, utility

, telecommunications , and agriculture applications through aerial photography and videography.



### Description of Flight Operations

A eropix will primarily utilize its UAS for construction and agriculture mapping applications. UAS mapping is performed in a slow and methodical manner with flight profiles planned and programmed in advancewhile maintaining LOS and override capability during flig ht. Although mapping applications and

environmental risks can differ greatly, the mechanics of flight planning and execution remain very

similar. The use of sUAS can reduce the risk to workers while inspecting, surveying, or monitoring

installation of work that requires ladders, scaffolds or other potentially hazardous means of elevated

access. Aeropix will obtain permission to access these secure and/or remote sites by the property owners/managers prior to conducting flight operations. Flight operations wi ll be performed at low altitudes and always within VLOS. Most mapping flights are conducted under 200 feet AGL. Construction site mapping benefits the public by providing more consistent and detailed over site of costly construction projects. In addition t o providing accountability and saving the public money, the same outputs can be used to conduct safety surveys or detect structural or environmental concerns much sooner. Agricultural mapping services benefit the public by helping increase crop yield while lowering environmental impacts of chemicals and water usage.

Another purpose for Aeropix ’s exemption request is to conduct manual flight inspections for special applications, such as cellular tower equipment checks and structural damage assessment s for i nsurance companies . In these applications, Aeropix will receive written consent to access these Secure / Sterile sites by the property owners / managers prior to conducting flight operations

. S ite access allows Aeropix to perform all inspections at low altitude and always within VLOS. Most inspection flights will be under 200ft. AGL, and all flight operations will remain below 400 f ee t AGL.

Aeropix will cordon off aerial photography/videography site s to add a buffer t o keep the public / n on

participants safe. This will be done by using cones and signs advising of the possible hazard. Not only is public safety of utmost concern but also the safety of the climbing crews tasked with routine inspection
of the towers. Aeropix and its UAS operations w ill alleviate the day to day height exposure of inspection services and allow them to concentrate on service and repairs. Climbers have one of the highest incidents of death in the labor force. UAS used to inspect cell towers allow s the cell carriers to enhance operability to its clients; reducing down time and increasing signal strength by proactively inspecting towers and making repairs before failures or damages occur. UAS operations in support of insurance claim inspections w il l help reduce the number of falls and deaths associated with this type of operation.

Some of t he operations listed above require flight within 100 f ee t of buildings and structures. Aeropix has instituted several safety measures to limit and avoid collision or damage to such buildings or structures and / or minimize risks and exposures:

- Written permission from property / building owners outlining operations and describing potential

hazard s.

- General Liability insurance to cover any damages.

- All flight operations follow operation manual, guidelines and procedures listed herein.

- Manual UAS operations within 50 feet of a structure requires the Visual Observer (s) to be positioned in

manne r that allows reliable distance to hazard approximations and remain in constant communication
with the pilot

.

Aeropix ’ exemption w ill permit its operation of lightweight ( less than 55 lbs.), UAS in tightly controlled and limited airspace. Predetermined, s pecifically marked areas of operation, cordoned off locations and corresponding enhancements to operate within current safety parameters and new ones to be implemented by the FAA Exemption relief.Safety is paramount for Aeropix . We wish to help integrate UAS into the NAS by performing our services

with the utmost concern for the safety of our pilot s, the general public and property. To achieve this

, Aeropix has instituted several flight parameters, conditions, guidelines and limitations to adhere to before, during and after flight operations all of which are outlined in the UAS Pilot’s Operating

Handbook . These conditions are based off of Part 333 exemptions that have already been approved by the FAA and have been integrated into our operations:

- Th e UAS wil l not exceed a ground speed of 3 0 knots.

- All operations will remain below 400 ft AGL.

- The UAS will weigh less than 55 lbs.

- All operations will remain in visual line of sight (VLOS).

- All flight operations requiring dedicated camera control wil l utilize a separate V isu al O bserver (VO). Th e VO will provide additional situational awareness and support sense and avoid functions, always with

verbal communications with the Pilot in C ommand ( PIC ).

- The pilot must follow the procedures as outli ned in the UAS Pilot’s O perat i n g Handbook . ( Protocols &

Procedures for UAS Operations, UAS Manufacturer’s User Manual s , and UAS Flight & Maintenance Logs ).

- Prior to each flight

, the PIC must inspect the UAS to ensure it is in a condition for safe operation

.

- Any UAS that has undergone maintenance or alterations that would affect the UAS operation or flight characteristics must undergo a functional test flight in accordance with operators manual.

- The PIC must follow the manufacturer's UAS aircraft / component , maintenance, overhaul, replacement, inspection and life limit requirements.

- Prior to operations , the PIC will undergo UAS specific training for type (multi

- rotor /plane/wing ) make

and model aircraft and log hours appropriately. The PIC will also maintai n proficiency and currency (every 90 days) with UAS in a manner consistent with 14 CFR 61.51(b).

- PIC & VO will have successfully completed a qualification proc ess, as outlined in the Protocols & Procedure for UAS Operations

. Completion of this qualificat ion process will be documented by the Chief

Pilot

.

- The UAS will not be operated directly over any person, except authorized and consenting flight personnel.

- The PIC & VO will ensure that no persons are allowed within 1 00 f ee t of the flight area except those consenting flight personnel

.

- If UA S loses communication or experiences a loss of sufficient GPS signal, the UAS must return to a pre

determined location within the security perimeter and land or be recovered in accordance with operator's manual.

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with operators manual.

- All aircraft will be identified by a serial number, registered in accordance with 14 CFR part 47, and have

identification ( N

- Number) markings in accordance with CFR part 45(c). Markings will be as large as possible.

- All pilot s will comply with all manufacturers Safety Bulletins.

- Before conducting operations, the radio frequency spectrum used for operation and control of UAS will

com ply with Federal Communications Commission (FCC).

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground station during all operations.

- The UAS will remain clear and yield the right of way to all other manned ope rations and activities at all

times.- All operations will be conducted under visual meteorological conditions (VMC) and no night operations

as defined in 14CFR 1.1.

- The UAS will not be operated by the PIC from any moving device or vehicle.

- The UAS wil l not be operate d within 5 nautical miles of an airport reference point unless a letter of agreement with that airport’s management is obtained or otherwise permitted by an issued COA.

- Accidents will be reported to the National Transportation Safety Boa rd (NTSB) per instructions

contained on the NTSB website.



### REQUESTS FOR EXEMPTION BY PART AND SUBPART

14 CFR 21, Sub Part H A irworthiness Certificates Entitled Airworthiness Certificates, set forth requirements for procurement of necessary airworthiness certificates in relation to FAR 91.203(a)(1). The size, weight and enclosed operational area of Aeropix’ UAS permits exemption from Part 21 because Aeropix’ UAS meet an equivalent level of safety pursuant

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both pieces of the legislation permit the FAA to exempt UAS from the airworthiness certificate requ irement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Aeropix’ UAS meet or exceed each of the elements.

14 CFR 45.23(b) Marking of the Aircraft Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. Aeropix’ UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft. Regardless, Aeropix will mark its UAS in the largest poss ible lettering by placing the " N "number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working

with the UAV will see the markings. The FAA has previously issued e xemptions to this regulation through

Reference Exemption No 10167 and 10700

14 CFR 61.113(a)(b) Private Pilot Privileges and Limitations / PIC Private pilots are limited to non

- commercial operations. Aeropix can achieve an equivalent level of safety as achieved by current Regulations because Aeropix’ UAS do not carry any p ersonnel . Further, while helpful, a pilot license will not ensure remote control piloting skills, though Aeropix’ pilot vetting
and trainin g program will require prospective PICs to demonstrate airman knowledge and proficiency prior to PIC certification

. Applying manned commercial pilot certification requirements does not significantly add to the safety of sUAS operations. Further, the risk i n operation of Aeropix ’ UAS (<30 kts and <55 lbs) is far less than the risk levels inherent in the commercial activities outlined in CFR 61. Thus, allowing Aeropix to conduct operat ions with internally trained and certified pilot s in co mmand will

achieve e quivalent level of safety to manned aircraft.

Reference Exemption No. 12357

14 CFR 91.7(A) Civil A ircraft Airworthiness Certificate Prohibits the operation of a civil aircraft without an airworthiness certificate. Aeropix requests exemption based on previous Exemption No. 11138 . The FAA has ruled that similar make and model of aircraft (UAS) do not require an airworthiness certificate.14 CFR 91.9 (B) (2) Aircraft Flight Manual in the aircraft

Requires an aircraft flight manual in the aircraft. As there are n o pilots or passengers, and given the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in
Reference E xemption No. 10700 and 32827

14 CFR 91.103 Pre

- Flight No approved Airplane Flight Manual are maintained on board the aircraft. Aeropix asserts that an equivalent level of safety will be achieved by the PIC taking all preflight actions set forth in the operating documents, including reviewing weather, flight battery requirements, landing and take

- off distances, and aircraft performance data before initiation of flight.

14 CFR 91.109 Flight Instruction

D ual controls are not available for flight instructi on.

14 CFR 91.119(C) Minimum Safe Altitudes States that no person may operate an aircraft below the following altitudes: over other than congested

areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

Aeropix will not operate any UAS over an altitude of 400 AGL. The majority of the operations proposed

will be conducted between 50 to 200 feet AGL as this usually provides the best angle of capture for the type of photography and videography operations proposed.

The UAS ’ utilized for this exemption are of exceptionally light weight and are not capable of speeds over
5 0 knots. The UAS are all equipped with GPS guided auto pilot with a return home function in case of loss of control by the PIC and is powered by sealed batteries thereby reducing the chance of post impact fire to nearly zero.

There will be cases when the 500 foot distance from s tructures will need to be exempted. (Example: Aerial Video of a 2 story home roof to determine and/or document extent of storm damage.) In this type of operation every assurance will be made to keep persons outside of a reasonable, safe, clear area of oper ations and will only be conducted with the express permission of the property owner.

See Protocols and Procedures for UAS Operations section

.

Aeropix will implement procedures and policies to ensure that any person in the general vicinity of operations will be aware of such operations and ensure that all non

- essential personnel are cleared of the area of operations. See Protocols and procedures Section 3.

14 CFR 91.121 Altimeter Settings Aeropix requests relief from 91.121 for the following reason. The UAS is equipped with GPS derived altitude capability, however due to the limited altitude requested in this exemption, the FAA has previously granted Exemption for these types of operations. Reference Exemption No.11138

14 CFR 91.151(a) Fuel for Flight;No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast

weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds (a)(1)During the day to fly for at least 30 minutes. Aeropix requests relief from 91.151(a) due to the fact that the UAS is equipped with a battery and remaining charge indicator system. The UAS ha ve a flight capability on full charge of approximately 15

- 40 minutes depending on sUAS in use, camera , and wind/speed variables. Aeropix will limit flight operations based on minimum voltage thresholds monitored by the PIC to ensure appropriate reserve battery charge and equivalent level of safety. Should the PIC fail to land the aircra ft prior to reaching minimum voltage limits, the aircraft will autonomously return to its home point and land.

14 CFR 91.203(a)(b) Carrying of civil aircraft C ertifications and Registrations Provides for the carrying of civil aircraft certifications and r egistrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at the Aeropix flight operations center.

14 CFR 91.405(a) Maintenance required Aeropix requests relief in part from 91.405(a)(1) based on the Protocols and Procedures

Section on Maintenance and Maintenance Records

. Also R eference Exemption No. 11138

14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration Aeropix requests relief from 91.407(a)(1) based on the Protocols and Procedures Section on Maintenance, Return to service after maintenance, and Maintenance records.

Reference Exemption No. 11138

14 CFR 91.409(a)(1)(2) Inspections Aeropix requests relief from 91.409(a)(1)(2) based on the Protocols and Procedures

Section on Inspections. Reference Exemption No. 11138

14 CFR 91.417(a)(b) Maintenance records Aeropix requests relief from 91.417(a)(b) based on the Protocols and Procedures Section on Maintenance records

.



### Protocols and Procedures for UAS operations

A. Qualifications and Proficiency

1. UAS must be operated by a current Pilot in Command for that model aircraft, as certified by

the Chief Pilot. UAS Pilot in Command certifications shall be required to complete a training curriculum as determined by the Chief Pilot.

2. Pilot in Command trai ning shall include, as a minimum:

a. Aeronautical knowledge test. Successfully completing an FAA approved ground school shall satisfy this requirement.

b. Satisfactory demonstration of knowledge and flight proficiency for the applicable UAS model and application s as determined by the UAS Flight Instructor. Pilot inCommand certification records shall specify which UAS and applications have been successfully completed.

c. Proficiency on each UAS will be maintained consistent with 14 CFR 61.51(b).

d. Satisfactory completion of bi e nn i al aeronautical knowledge testing.

e. Recent flight experience and proficiency requirements for each type of UAS

certification shall be maintained consistent with 14 CFR 61.57.

f. Prior to operations for which exemption is requested, the Pilot in Command must have accumulated and logged a minimu m of 10 hours of total time as a UA V pilot

with at least 5 hours on the make and model to be used. The Pilot in Command must have logged a minimum of 3 takeoffs and landings in the preceding 90 days and a total flight time of 1 hour . Flight hours shall be logged in a manner consistent

with 14 CFR 61.51.

B. Medical Conditions

1. In lieu of a medical certificate

, Aeropix will require that each pilot and visual observer have a

valid driver’s license and are trained in the functionality and procedures for initiating a
“Return to Home” command.

2. In the event that the PIC experiences condition that impacts (or could impact) their ability to safely c ontinue flight operations, the PIC or VO will immediately initiate a Return to Home command and secure all flight operatio ns until conditions return to safe state as determined by the PIC

.

C. Preflight Inspection of UAS

1. UAS preflight procedures outlined in the associated manufacturer user manual will be followed

in a checklist manner.

2. The Pilot in Command will certify that a complete preflight inspection has been accomplished with the date, time, and signature in the UAS logbook.

3. Preflight checks may vary according to aircraft but shall include inspection and/or verification of
the aircraft, transmitter, batteries, motors, rotors, landing gear, camera, and gimbal mounts.

4. The Pilot in Command shall ensure that weather conditions, area safety and security, and contingency planning has been adequately considered and incorporated into the operations plan prio r to flight.

5. The Chief Pilot is responsible for ensuring that preflight procedures reflect the most recent guidance and that each Pilot in Command accomplishes required preflight checks prior to each flight.

D. Safety and Security

1. The Pilot in Command shall ensure that the operational area for the purposes of UAS flight remain clear of all nonessential personnel at all times while the UAS is in flight. Additionally, the

Pilot in Command shall be responsible for ensuring all nonessential personnel shall be req uired to remain clear of flight operations.

2. Physical barriers and/or signs will be used as necessary to restrict access in the vicinity of flight
operations. The applicable safe distance may vary according to aircraft, altitude, and speed

parameters.3. In the event of a breach by nonessential personnel into the operations area during flight, the

Pilot in Command shall immediately terminate flight operations until the breach and any

associated cause has been corrected.

4. The UAS area of operation is defined as the horizontal flight path(s) of the UAS as well as the vertical flight path with an associated area of uncertainty proportional to aircraft size, weight, speed, and altitude.

5. All nonessential personnel shall be maintained a minimum distance of 50 fee t away from a relatively stationary aircraft and 100 feet away from the flight path of any aircraft operating above 10 feet/sec.

E. Limitations of Operations

1. The UAS shall only be operated during daylight hours.

2. The Pilot in Command shall maintain the abili ty to regain flight control when operating in a pre

programmed flight mode.

3. The UAS shall remain within radio controller communication range at all times. The UAS shall have a Return to Home (RTH) feature set to initiate an automated recovery upon loss of control signal. Return parameter settings shall be verified by the Pilot in Command during preflight

checks.

4. No operations are allowed if the RTH function and/or autopilot are suspected to be
malfunctioning.

5. The UAS shall be operated within VLOS. A Visual Observer in direct communication with the

Pilot in Command may be used to extend the VLOS while operating in pre

- programmed flight mode providing flight control signal connectivity is maintained and the UAS flight path can be monitored via telemetry while VLOS is obstructed from the Pilot in Command and a RTH feature

is enabled in the event of a loss of communications scenario.

6. A Visual Observer shall be utilized during flights requiring manual camera and/or gimbal
operation

, pre

- programmed mode where VLOS may be temporarily obstructed , or manual flight within 50 feet of a physical hazard

. 7. The UAS will have an altitude restriction of 400ft AGL.

8. The UAS will not be operated at a speed exceeding 30 Knots (50.6 fps, 15.4 mps)

9. All applicable operations manuals shall be available to the Pilot in Command on location.

10. The Pilot in Command must inspect and ensure that aircraft and ground control stations are in airworthy condition prior to each operation; if airworthiness is in question, all operations will be

susp ended until necessary repairs have been made and adequately tested.

11. An operational flight test shall be performed following any maintenance or alteration which could affect UAS operation or flight.

12. UAS maintenance shall be conducted in accordance with the manufacturer’s documented guidance.

13. All aircraft use, maintenance, and alteration activity shall be recorded in the aircraft records; including total flight hours, description of work performed, and the signature of the person authorizing return to service

. 14. The Chief Pilot shall ensure that each UAS aircraft complies with all Manufacturer’s Safety

Bulletin’s and that all pilot s are kept informed of applicable updates.15. UAS must be operated by a current Pilot in Command for that model aircraft, as certified by the

Chief Pilot.

16. No UAS operations shall occur within 5 nautical miles of an airport except under the following

conditions.

a. All flights within 5 nautical miles of an airport shall remain under 200 feet AGL.

b. No UAS operations above 100 feet AGL shall occur within 1 nautical mile of an airport reference point as denoted on a current FAA chart.

c. All flights within 5 nautical miles of an airport shall require programmed altitude and range limitations preventing an uncontrolled fly

- away situation.

d. All flights within 5 nautical miles of an airport shall require a Visual Observer in constant

communi cations with the Pilot in Command

.

F. UAS Airworthiness

1. The PIC shall ensure that the UAS is in an airworthy condition before each flight.

2. Airworthiness shall be determined by a preflight inspection in accordance with the UAS

manufacturer’s operating documen ts and any and all applicable Federal Aviation Regulations, and any additional requirements as defined by the Chief Pilot

. 3. The PIC shall document each preflight inspection by date, Aircraft total Flight time to date, any discrepancies noted, and signature and certificate number. Any discrepancy noted shall be addressed before UAS operation.

G. UAS Maintenance and Records

1. Each UAS shall have its own and separate maintenance log book.

2. Maintenance log books shall updated by the pilot following each flight

. 3. A ll failed preflight inspection checks shall be recorded in these logbooks.

4. All flight log entries signoff shall include at least the following information: date of operation,
Aircraft Total time, aircraft serial or operating number, PIC signature and certif icate number. Example:

31JUL 15, XAX801, ACFTT 50.1 hours, Preflight inspection completed, No defects noted, Jim
Smith, PIC , XA PIC 0001

5. Manufacturer documents, handbooks, user manuals, supplements, Safety Bulletins, etc., shall be the only approved documen ts for performing repairs, maintenance, inspections, overhauls, or replacement of life limited components.

6. Any required maintenance, inspection, alteration or repair must be completed by an approved repair authority . At the completion of this work the approved person must make an entry in the aircraft log book that at least includes: Date, Aircraft serial or operating number, brief description of the discrepancy, inspection, alteration or repair, the reference material used as guidance for the repair, s tatement approving the aircraft for return to service, and signature of person who completed the work. Example:

3 1 JUL1 5 , XAX801, ACFTT 50.1 hours, replaced number 3 m otor with new m otor, All testing completed satisfactory . Aircraft return ed to service by Ed Smith, Chief Pilot.

7. Maintenance records shall be kept with the UAS at all times and shall be made available to any authorized agency or the Administrator upon request.H. Pilot in Command Requirements

1. The Pilot in Command shall have accumulated and logged a minimum of 5 0 flight cycles and 10 hours of UAV flight time before performing any operation for which exemption is requested.

2. The Pilot in Command shall have at least 5 hours in make and model before performing any operation for which exemption has bee n requested.

3. The Pilot in Command shall perform a pre

- flight inspection before each flight is conducted.

4. The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptions of the exemptions requested by the pilot . In those cases the Pilot in Command shall adhere to company operating standards or Federal Aviation Administration Limitations placed
upon exemption s, whichever is more stringent.

5. The Pilot in Command must have 3 takeoff and landings within the preceding 90 days.

6. The Pilot in Command must maintain a record of flight information to establish currency and that he or she meets the requirements of this section.

7. The Pilot in Command will utilize eye protection in the event that sun glare would reduce VLOS
operations.

I. V isual Observer Responsibilities and Requirements

1. A Visual Observer shall be utilized during flights requiring manual camera and/or gimbal
operation, pre

- programmed mode where VLOS may be temporarily obstructed, or manual flight within 50 feet of a physical hazard.

2. The Visual Observer shall maintain verbal communication with the PIC at all times during UAS
operation.

3. The Visual Observer shall maintain Visual Contact with the UAS at all times.

4. In the event that Visual Contact is lost the VO will notify the PIC who will immediately cease operations and land the aircraft.

5. The Visual Observer shall also help the PIC maintain area of operations security and ensure that all nonessential persons remain clear of the area of operations. In the event of a breach by unauthorized person(s) the VO shall notify the PIC and operations will cease immediately.

6. The Visual Observer shall also assist the PIC in looking for other aircraft traffic near the operations area. If another aircraft, manned or unmanned, is observed near the operations
area, the VO will notify the PIC immediately

. 7. If a manned aircraft is detected near UAV operations, the PIC will c ease operations and land the UAV immediately

. The PIC shall assess the situation and safety risks associated wit h c ontinued flight operation s in the vicinity of other unmanned aircraft before determining if the UAV should

be landed.

8. The VO will utilize eye protection in the event that sun glare would reduce VLOS operations.

J. Reporting of Incidents and/or Accidents Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported within 24 hours to:

FAA UAS Integration Office (AFS

- 80) Accidents: National Transpo rtation Safety Board www.ntsb.gov

### Unmanned Aircraft Systems and Uses

A. Aeropix will operate the following aircraft:

a. DJI Inspire 1

b. DJI Phantom 3 Professional

c. 3D Robotics X8

d. 3D Robotics Aero

- M

B. Th ese shall be the only system s operated by Aeropix

. C. The Inspire 1, Phantom 3, and X8 are each of ultra

- light weight

, quad

- rotor design with built

- in

return to home features fo r flight.

D. The Aero

- M is a light weight, foam based plane (under 10 lbs) with a built

- in return to home feature for flight.

E. The manufacturer s ha v e built in several features to make operations safer: in the event of lost signal

the aircraft will return to its pre

- determined location within the security perimeter and land; PIC has ability to take over / abort flight manually in the event of loss to G PS; and the UAS has built

- in software that limits operations near airports and restricted airspace.

F. Aeropix has attached the hyperlinks for the operating and user documents for the system as additional supplements for this petition. No modification to the factory system is to be utilized other

than the dorsal surface area of the aircraft will be painted a bright safety orange to help manned

aircraft see the unit while in flight.

G. Please see attached supplemental documents. 

# 1. http://www.dji.com/product/inspire

- 1/download

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

- 3/download

3. http://3drobotics.com/kb/x8/

4. http://3drobotics.com/kb/aero

- m/

The Public Interest

The request for this exemption is in the Public Interest as there are many consumer applications for the services that can be provided by UAS. It is clear that the Congress of the United States, the business sector, and the consumer want to integrate UAS into the NAS and utilize their unique and cost effective capabilities. It is also in the Public Interest that many of the low level flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant and environmentally friendly unmanned aircraft that can operate at a fraction of the cost to both the pilot and consumer. These aircraft can be operated without risk of loss of life or limb, and without significant financial impact to the pilot or any person or property on the ground in the event of the loss of an aircraft. Utilizing these UAS will create a safer more productive work environment, reduce environmental pol lution and have a positive impact on the local community which is in the Public Interest. Finally

, Aeropix believes that granting this exemption would help to further by Administrators process of integration of UAS systems and possibility help to create ad ditional regulations and guidance to be used as these systems become more widely utilized.

### Abbreviations

VLOS

- VISUAL LINE OF SIGHT

PIC

- PILOT IN COMMAND

VO

- VISUAL OBSERVER

UAS

- UNMANNED AIRCRAFT SYSTEM

NAS

- N ATIONAL A IRSPACE S YSTEM

Please forward any questions or concerns to the address or email below. Sincerely, Anthony Jones / Pr esident Xtreme Aeropix Inc. 2643 George Washington Memorial Hwy

Suite B
Yorktown

, VA 2 3693

757

- 806

- 6412
Email: tony.j@XtremeAeropix.com