February 1, 2016

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Above 360, LLC Contact Person: Yvette Land 5 Franklin Avenue Gillette, Wyoming 82716

Phone: (307)299-6329

Re: Petition for Exemption underSection 333 ofthe FAA Modernization and Reform Act of2012 and 14CFR Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Please find enclosed the Petition for Exemption underSection 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11 ofthe Federal Aviation Regulations forAbove 360, LLC. Ifyou have any questions about our petition or ifyou need anyfurther information, please contact me by phone at (307)299-6329 orvia email atyaland89@gmail.com. Iwill be happyto assist you in any way I can. Thank you foryour consideration. Respectfully,

# ~\)~-~ Yvette Land Secretary, Above 360, LLC



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• February 

### 1, 2016
U.S. Department ofTransportation Docket Management System 

### 1200 NewJersey Ave., SE Washington, DC 

### 20590
Re: Request for Exemption underSection 

### 333 ofthe FAA Modernization and Reform Act of

### 2012 and 

### 14CFR Part 

### 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Above360, LLC, is a Limited Liability Company formed underthe State**law~** ofWyoming on January 

### 13, 2016. Pursuant to Section 

### 333 ofthe FAA Modernization and Reform Act of

### 2012 (the "Reform Act") and 

### 14CFR Part 

### 11, Above 

### 360, LLC requests exemption from the Federal Aviation Regulations outlined below in orderto legally operate an Unmanned Aircraft System (UAS) for commercial purposes in the National Airspace System.
Name and Address of Petitioner: Above 

### 360, LLC Contact Person:Yvette Land 5 Franklin Ave. Gillette, Wyoming 

### 82716 Phone: 

### (307)299-6329 Email: yaland89@gmail.com Proposed Operations Above 

### 360, LLC (hereinafter referred to as Above 

### 360 orthe Petitioner) proposes to utilize an UAS for the purposes ofcommercial aerial photography and videography inspections, surveying, and data collection in industrial settings such as mines, power plants, grain storage, and material conveyance. Examples ofspecific applications forwhich Above 

### 360 proposes to utilize the UAS are to inspect (via photography and/orvideography) conveyor systems, silos, power plant stacks, construction projects, boilers, and boilercooling towers which are at considerable heights or are in areas in which itwould be extremely difficult, dangerous, time consuming and/or costly for personnel to reach forthe same purposes. The photographs and/orvideos taken ofthe structures by the Petitionerwill be provided to a structural engineer for evaluation ofthe stability ofthe structure.
Public Interest Operations proposed by Above 

### 360 would be far safer and more cost effective for our customers and the public than using other methods. Safety issues thatjeopardize personnel in the industrial setting or the public in general could be easily identified and inspections could be performed morefrequentlythan ifthe inspections were performed in another manner. Examples ofsafety issues that could be identified include cracks in a silo's internal or exteriorwalls which compromise the integrity ofthe structure; damage tothe underside ofan elevated conveyor system; and damage in a power plant boilerfrom which super-heated steam could escape. All ofthese safety issues could prove to be injurious orfatal to personnel inthe area ifthey are not identified and mitigated. Methods used to dothe inspections

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• currently include personnel working in harnesses at considerable heights or in dangerous situations

. These areas are not accessible to regular aircraft. 

### Controlled Areas and Conditions and Small UAS Proposed Rulemaking Above 360 is very concerned with the safety of personnel and equipment in the areas in which it proposes to use an UAS. Thus its operation ofthe proposed UAS's will be in a manner consistent with the major provisions outlined in the Federal Aviation Administration's (FAA's) Small UAS Notice of Proposed Rulemaking (NPRM) as follows: 

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### LESS than 55 lbs.; The UAS will be operated in visual line-of-sight ofthe operator orthe visual observer; At all timesthe UAS will remain close enough forthe operatorto see it unaided by any device otherthan corrective lenses; The UAS will 

### NOT be operated over any persons not directly involved in its operation; The UAS will only be operated during daylight hours; The UAS operatorwill yield right-of-wayto other aircraft, manned or unmanned; A visual observer will be utilized; A first-person view camera will be utilized, but itwill not be relied upon to meetthe 11

### See-andavoid" requirement; The UAS will 

### NOT exceed 100 MPH; The UAS will 

### NOT exceed an altitude of500 feet above ground level; The UAS will only be flown when weathervisibility is at least 3 miles from control station; The UAS will 

### NOT be operated in Class A airspace; Any operations in Class B, C, Dand Eairspace will only be performed withthe required ATC permission; No person will operate more than one UAS atone time; The UAS will 

### NOT be operated in a careless or reckless manner; A preflight inspection will be performed on the UAS and documented by the operator priorto everyflight; The operatorwill 

### NOT operate the UAS if he/she knows or has reason to know ofany physical or mental condition that would interfere withthe safe operation ofthe UAS; The operatorofa UAS will be required to successfully complete a course onthe safe use ofan UAS; The operatorwill be vetted by theTransportation Security Administration (TSA); The operatorwill obtain an unmanned aircraft operator certificate; The operatorwill be required to successfully complete a recurrent course on the safe use ofa UAS every 2 years; The operatorwill be at least 17years ofage; The UAS will be made available tothe FAA (upon request) the UAS for inspection ortesting and any associated documents/records required to be kept underthe proposed rule; and The operatorwill report any UAS accidentthat results in injury or property damage within 10 · days ofthe accident

. In addition, the UAS will 

### NOT be operated within 5 miles ofany airports.

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• There are few, ifany, people in the areas in which Above 360 proposes to operate an UAS. Ifthere are personnel in the area theywill be evacuated, ifpossible. Ifit isn't possible forthem to leave, the visual observer will notifythem thatthe UAS will be in use and to be aware of its location. In addition, the visual observerwill monitortheir location to insuretheir safetywhile the UAS is in use. Proposed Unmanned Aircraft System (UAS) The Petitioner proposes to use two (2) types of UAS, the DJI Inspire T600 quadcopter and the DJI Phantom 3 Professional quadcopter:
The DJIInspire weighs approximately 7.51bs. fully loaded. Its maximum speed is 18 meters/second and its maximum flighttime is approximately 15 minutes with each battery. Its maximum ascent speed is 5 meters/second and its maximum descent speed is 4 meters/second. The OJI Inspire will be controlled via a remote controllerwith an IPAD or cell phone forvisuals through the gimbal and camera. The remote control is FCC Compliant upto 3.1 miles and CE Compliant upto 2.1 miles (unobstructed and free of interference). Its operating frequencies are 5.725-5.825GHz and 2.400-2.483 GHz. The gimbal and camera are a Zenmuse X5 with aType 4/3 CMOS sensor. See Attachment A, Inspire 1 Pro User Manual, for additional information.
The DJI Phantom 3 Professional weighs 2.82 lbs. fully loaded. Its maximum speed is 16 meters/second and its maximum flighttime is approximately 23 minutes with each battery. Its maximum ascent speec:f is 5 meters/second and its maximum descent speed is 3 meters/second. The Phantom 3 Professional will be controlled via remote control with an IPAD or cell phone forvisuals through the gimbal and camera. The remote control is FCC Compliant up to 3.1 miles and CE Compliant up to 2.1 miles (unobstructed and free of interference). Its operatingfrequency is 2.400 GHz-2.483 GHz. The camera has a Sony EXMOR 1/2.3" sensor. See Attachment B, Phantom 3 Professional User Manual, for additional information. Specific Sections ofTitle 14, Code of Federal Regulations, from which Petitioner is Requesting an Exemption:
14CFR Part 21, Subpart H: Airworthiness Certificates This section establishes the procedural requirementforthe issuance ofairworthiness certificates as required by 14CFR §91.203(a)(1).
Reason for Exemption: Given the size, weight, and speed ofthe UAS's Above 360 proposes to utilize and the limited
area and conditions in which they propose to operate, it is their opinion that obtaining an airworthiness certificate is not necessary. To meetthe intentofthe regulation Above 360 proposes to determine airworthiness ofthe proposed UAS's by requiring the pilot in command (PIC) to do a preflight check ofthe unitand mitigating any safety or mechanical concerns prior to each flight. The Petitioner believes their operation ofeither ofthe proposed UAS's withthe precautions outlined herein will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate. Thus, the Petitioner believes an exemption from this regulation, with the conditions outlined herein, is**w~rranted** and meetsthe requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333.
14CFR Part45.23(b): When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or

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• provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited," "restricted," "light-sport," 1'experimental," or "provisional," as applicable. 

### Reason for Exemption: Due tothe size ofthe UAS's Above 360 will be operating and the fact thatthere is no cabin, cockpit or pilot station in the UAS it is not possible to label the UAS's as outlined in this section. Above 360 will ensure compliance with § 45.29(f) to meetthe intent ofthe regulation by displayingthe registration number in the largest practicable lettering. Thus, the Petitioner believes an exemption from this regulation, with the conditions outlined herein, is warr.anted and meets the requirements for an equivalent level ofsafety under 14 CFR Part 11 and Section 333. 

### 14 CFR Part 61.113(a) and (b) prescribe that: (a) no person who holds a private pilot certificate may act as a pilo't in command ofan aircraft that is carrying passengers or propertyfor compensation or hire; nor may that person, for compensation or hire, act as a pilot in command ofan aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation for hire. 

### Reason for Exemption: Given the size, weight, and speed ofthe UAS's Above 360 proposes to utilize; the limited area and conditions in which they propose to operate; and the fact that no passengers will be on board, the.Petitioner asserts that a pilot in command (PIC) who holds a pri:vate, recreational or sport pilot certificate and avalid driver's license could operate either ofthe proposed UAS's at a levelthat is at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) being operated by a PIC with a commercial pilot's license. Additionallythe PIC will possess a current FAA airman medical certificate. Thus, the Petitioner believes an exemption from this regulation, with the conditions outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333. 

### 14CFR Part 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthycondition; 

### Reason for Exemption: Given the size, weight, and speed ofthe UAS's Above 360 proposes to utilize and the limited
area and conditions in which they propose to use them, the Petitioner proposes to determine airworthiness ofthe proposed UAS's by requiring the PIC to do a preflight check ofthe unit and mitigating any safety or mechanical concerns priorto each flight. Thus, the Petitioner believes
an exemption from the requirement for an airworthiness certificate, with the conditions outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333

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• 14CFR Part 91.9(b)(2) prohibits operation of US registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or anycombination thereof.; 

### Reason for Exemption: Given the size ofthe UAS's Above 360 proposes to utilize it is not possible for a flight manual to be carried in the unit. The Petitioner proposes to meet the inte.nt ofthis requirement by insuringthat the appropriate user manual 

### will be kept with each UAS forthe PIC to reference at time of use. Thus, the Petitioner believes an exemption from this regulation, with the conditions outlined herein, is warranted and meetsthe requirements for an equivalent level of safety under 14 CFR Part 11 and Section 333.


### 14 CFR Part 91.103 Preflight action; This regulation requires preflight actions including communicatingwith ATC, determining runway lengths and runway slopes at intended airports, researching information from flight manuals, etc. 

### Reason for Exemption: Given thatthe UAS's Above 360 proposes to utilize will not be operated in or around airports, will not be using any runways, and do not have flight manuals, the Petitioner asserts the majority ofthis regulation is notapplicable to their proposed UAS's. To meetthe intentofthe regulation the Petitioner proposes to take all preflight actions as set forth in the user manual appropriatetothe UAS being utilized. These preflight actions will include doing a preflight check ofthe UAS, assessing weather conditions, flight battery requirements, and area necessary for safe landing ofthe aircraft. Thus, the Petitioner believes an exemption from this regulation,

. with the conditions outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333. 

### 14CFR Part 91.105 Flight crewmembers at stations: This regulation outlines the requirements forflight crewmembers in aircrafts. 

### Reason for Exemption: No crewmembers or passengers will be flying in the UAS's Above 360 proposes to utilize, thus, the Petitioner believes an exemption from this regulation is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11and Section 333. 

### 14 CFR Part 91.109 Flight instruction: This regulation requires, in pertinent part, that no person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fullyfunctional dual controls. 

### Reason for Exemption: The UAS's Above 360 proposes to utilize are operated by remote control and do not have dual controls. Additionally, theywill never be carrying any crew or passengers. However, any training done with the proposed UAS's will be done underthe direct supervision by the appropriately trained PIC. Thus, the Petitioner believes an exemption from this regulation, with the conditions outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11and Section 333

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• 14CFR Part 91.119(c) prescribes, in pertinent part, that except when takeoffor landing, no person may operate an aircraft belowthe following altitudes: (c)

## Overotherthan congestedareas. An altitude of 500 feet above the surface, except over open water orsparsely populated area. In those cases, the aircraft may not be operated closerthan 500 feetto any person, ve'ssel, vehicle orstructure. 

### Reason for Exemption: With particular regard to the requirementto be 500 feet away from vessels and structures, Above 360 proposes to utilize the UAS's specificallyto inspect industrial structures (i.e. silos, conveyors, and boiler cooling towers, etc.) and vessels (i.e. boilers, watertanks, etc.) for dangerous compromises in the structures orvessels themselves. This 500 feet requirement will not allowforthe detailed photographs and/orvideos required forthe structural engineerto determine the stability ofthe structure. These structures are 

## industrial, being constructed almost exclusively ofconcrete and steel. They are located in very sparsely populated locations. There is little (ifany) risk ofdamage to the structure should one ofthe proposed UAS's gettoo close. Especially given the size ofthe proposed UAS's (one weighing 7.5 lbs. and the other weighing under 31bs.) These structures and vessels are generally inspected very infrequently due tothe hazards involved in putting personnel in close enough proximityto dothe inspections in person. It is in the public's interest forthe FAA to grantAbove 360 an exemption to this 500 feet distance requirementto structures and vessels because frequent inspections can identify major issues with them which may otherwise go unnoticed. Infrequent (or nonexistent) inspections can result in catastrophic structural failures which may endanger both people and property. See Attachment Cfor information on these types offailures, including information from MSHA on structural failures and three (3) examples offatal accidents involving silo collapses. Two (2) ofthese accidents occurred in 2015.
To meetthe intent ofthis regulation the PIC will carefully assess the location to be inspected to insure any hazards involved in the UAS approach are mitigated as much as possible. Except for personnel essential to the inspection, the area around the inspection location will be vacated to at least 500 feet away. The UAS will always be maintained at a distance at least 5 feet from the structure orvessel being inspected. The PIC and visual observer will give specific attention to insuring this distance is maintained. The UAS will be maintained at least 500 feet awayfrom vehicles and people not essential to the inspection. The Petitioner asserts that by following these precautions and underthe limited conditions proposed bythe Petitioner, operatingthe proposed UAS's will be at least as safe, orsafer, than a conventional aircraft (fixed wing or, rotorcraft) operating atthe distances required bythis regulation. In addition, the Petitioner believes thatthe safety benefit gained in using an UAS versus a human forthe suggested purposes far outweighs any concerns overthe proximitythe UAS will be in tothe structures or vessels being inspected.
The FAA's Small UAS Notice of Proposed Rulemaking establishes a limitof500 feet above ground level and requires the PIC to maintain avisual line ofsight withthe UAS they operate. Given these proposed guidelines, the size ofthe UAS's Above 360 proposes to utilize, the limited conditions and areas in which Above 360 proposes to use the UAS's and the purposes for which Above 360 proposes to use the aircrafts, the Petitioner asserts that an exemption from this regulation, underthe conditions and with the limitations outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333. Page 

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• 14CFR Part 91.121 Altimetersettings This regulation outlines the required settings forthe altimeteron an aircraft.
Reason for Exemption: The altimeterdescribed in the regulations is specific to aircraftthat are flying at higher alti.tudes than what is proposed by Above 360. To meetthe intent ofthis regulation, the altimeteron each ofthe UAS's proposed bythe Petitionerwill be set to NOT exceed 500 feet above ground level. This is the altitude limit proposed in the Small UAS Notice of Proposed Rulemaking. The PIC will monitorand control the altitude throughout each flightvia the remote control. The Petitionerasserts that byfollowing these precautions and underthe limited conditions proposed bythe Petitioner operatingthe proposed UAS's will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an altimeterset as outlined by this regulation. Thus, the Petitioner asserts that an exemption from this regulation is warranted and meets the requirements for an equivalent level ofsafety under 14 CFR Part 11 and Section 333.
14CFR Part 91.151 Fuel requirementsforflights inVFR conditions: This regulation prescribes that: (a) No person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2} At night, to fly afterthatfor at least 45 minutes

. (b) No person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least 20 minutes.
Reason for Exemption: The total flighttime forthe DJI Inspire 1 Pro T600 is**appro~imately** 15 minutes with each battery. The total flighttime forthe DJI Phantom 3 Pro is approximately 23 minutes with each battery. This beingthe case 

### it is not possible for Above 360 to meetthis requirement. Both of the proposed UAS's have "low" and "critical" battery level warnings. In addition, both ofthe proposed UAS's have "Low Battery Return to Home" features when the battery is depleted to a pointwhere it mayaffectsafe landing and "Failsafe Return to Home" features when the remote control signal is lost. The Petitioner believes with these precautions and underthe limited conditions proposed by the Petitioner, operatingthe proposed UAS's

# will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwithin the fuel requirements outlined bythe regulations. Thus, the Petitioner believes an exemption from this regulation is warranted and meets the requirements for an equivalent level ofsafety under 14 CFR Part 11 and Section 333.
14CFR Part 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and currentairworthiness certificate; and (2) an effective US registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft Registration Application as provided for in§47.13(c)

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• Reason for Exemption: Given the size, weight, and speed ofthe UAS's Above 360 proposes to utilize and the limited
area and conditions in which they propose to operate,the Petitioner believes that obtaining an airworthiness certificate is not necessary. To meetthe intent ofthe regulation Above 360 proposes to determine airworthiness ofthe proposed UAS's by requiringthe PIC to do a preflight check ofthe unitand mitigating any safety or mechanical concerns priorto each flight. Documentation ofthese preflight checks shall be kept with the UAS. The Petitioner believes their operation ofeitherofthe proposed UAS's with the precautions outlined herein will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate. Thus, the Petitioner believes an exemption from 14 CFR Part 91.203(a)(1), underthe conditions outlined herein, is warranted and meets the requirements for an equivalent level ofsafety under 14CFR Part 11 and Section 333.
Given the size ofthe UAS's Above 360,proposes to utilize there is no room within either unitfor any documentation. To meetthe intent ofthis requirement the Petitionerwill register all of their UAS's with the FAA and a copy ofthe documentation related tothe registration ofeach UAS will be kept with that UAS. Thus, the Petitioner believes an exemption from 14CFR Part 91.203(a)(2), underthe conditions outlined herein, is warranted and meets the requirements for
an equivalent level ofsafety under 14 CFR part 11 and Section 333.


### 14CFR Part 91.203(b} prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate ora special flight authorization issued under 

### § 91.715 is displayed atthe cabin
orcockpit entrance so that it is legible to passengers or crew

. 

### Reason for Exemption: Given the size ofthe UAS's Above 360 proposes to utilize there is no room within either unitfor any documentation. In addition, no passengers or crew will be flying inside either unit. Thus, the Petitioner believes an exemption from 14CFR Part 91.203(b) is warranted and meets the

### requir~ments for an equivalent level ofsafety under 14 CFR part 11 and Section 333. 

### 14CFR Part 91.215(b} outlines the requirements for aircraft to have an ATC Transponder and Altitude Reporting Equipment and Use. 

### Reason for Exemption: The UAS's Above 360 proposes to utilize do not come equipped with atransponder and currently notransponders existthat could be installed ontothe proposed UAS's. The Petitioner believes that in the controlled areas and underthe limited conditions proposed bythe Petitioner, operati'ng the proposed UAS's will be at least as safe, orsafer, than a Gonventional aircraft (fixed wing or rotorcraft) operating with an ATC transponder and altitude reporting equipment. Thus, the Petitioner believes an exemption from 14CFR Part 91.21S(b) is warranted and**meet~** the requirements for an equivalent level ofsafety under 14CFR part 11 and Section 333. 

### Relating to Maintenance
14CFR Part 91.405(a} requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart Eofthe same part and shall between required inspections

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• except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed in part43 ofthe chapter.


### 14 CFR Part 91.407(a)(1) prescribes, in pertinent part, that no person mayoperate any aircraftthat has undergone maintenance, preventive maintenance, rebuilding oralteration unless it has been approved for return to service by a person authorized under§ 43.7 ofthis chapter. 

### 14 CFR Part 91.409(a)(1) and (2) Inspections prescribes, in pertinent part, that except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, with the preceding 12 calendar months, it has had (1) An annual inspection in accordance with**pa~** 43 ofthis chapter and has been approved for return to service by a person authorized by43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 

### 14 CFR Part 91.417(a) and (b) Maintenance records This regulation outlines, in pertinent part, what maintenance records are required and the length of time forwhich the records shall be retained. 

### Reason for Exemptions Given the size, weight, and speed ofthe UAS's Above 360 proposes to utilize and the limited
area and conditions in which they propose to operate, the Petitioner believes these regulations
are excessive and place undue burden on the Petitioner. To meetthe intentofthe regulations the Petitioner proposes the following conditions and precautions:

• The PIC will perform a preflight inspection to determine thatthe UAS is in a condition for safe flight. This inspection will include a review ofall systems to determine ifany components, items or equipment needs repair or maintenance. Ifany repairs or maintenance are required they must be done priorto beginning the scheduled activities. The inspection, any findings from that inspection and any required maintenance and/or repairs will be documented in the UAS's Flight Notebook priorto the initiation ofthe scheduled activities;
• Ifan UAS has undergone maintenance or alterations that affect its operation orflight characteristics, it must undergo a functional test flight priorto conducting further operations. This testflight must be conducted by the PIC with the visual observer in attendance and at least 500 feet from any person orstructureto insure no person or property are endangered. Any maintenance oralterations and the test flight will be documented in the UAS's Flight Notebook;
• The PIC will conduct a post-flight inspection after each flight to determine ifany maintenance is required. This inspection will be documented in the UAS's Flight Notebook; and
• The PIC shall follow the UAS's manufacturer's guidelines regarding maintenance, overhauls, replacement, inspection, and life limit requirements forthe aircraft and aircraft components.
The Petitioner believes that with these maintenance guidelines the UAS's will be at least as safe,
or safer, than a conventional aircraft (fixed wing or rotorcraft) being maintained as required by these regulations. Thus, the Petitioner believes exemptions from 14 CFR Part 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2) and 91.417(a) and (b), underthe conditions outlined herein, Page 

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• are warranted and meetthe requirements for an equivalent level ofsafety under 14CFR part 11 and Section 333. 

### Summary In summation Above 360 respectfully requests exemptionsfrom thefollowing regulationswith the conditions outlined above:. · 

# • 14 CFR Part 21, Subpart H; 

# • 14CFR Part 45.23(b); 

# • 14CFR Part 61.113(a) and (b); 

# • 14CFR Part 91.7(a); 

# • 14 CFR Part 91.9(b)(2); 

# • 14CFR Part 91.103; 

# • 14CFR Part 91.105; 

# • 14 CFR Part 91.109; 

# • 14 CFR Part 91.119(c); 

# • 14CFR Part 91.121; 

# • 14CFR Part 91.151; 

# • 14CFR Part 91.203(a); 

# • 14CFR Part 91.203(b); 

# • 14 CFR Part 91.215(b}; 

# • 14 CFR Part 91.405(a}; 

# • 14 CFR Part 91.407(a)(1); 

# • 14 CFR Part 91.409(a)(1} and (2}; and 

# • 14 CFR Part 91.417(a) and (b)

. Considering the public safety benefits thatAbove 360's services can provide; the limited scope in which they intend to operate; and the precautionary measures they intend to take to insure the safety ofthe personnel and property around which theywill operate; the Petitioner believes it is in the public's interestto grantthis petition.
Please contact us ifyou have any questions or concerns aboutthis request orthe conditions outlined herein and we will be happyto provide you with greater detail. We greatly appreciate yourtimely consideration ofthis request.

Jo Fischer

resident, Above 360, LLC

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