**Aerial Concepts LLC**  **Section 333 Exemption Petition**

Re: Exemption Request Pursuant To Section 333 of th e FAA Reform Act of 2012 Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Aerial Concepts LLC , operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photograph y for the media and advertising industries for pre

- planned, controlled area, photographic and surveying services, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by

the Federal Aviation Administration (FAA) a s required b y §333

. Aerial Concepts’ current operation of sUASs for commercial purposes has been halted to comply with recently enacted federal aviation regulations pertaining to sUASs. As described more full y below, the requested exemption would permit the operation of small, unmanned and relativel y inexpensive multi

- rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- site safet y personnel controlling access, and 4) would provide increased safet y and enh ancements to clients' business operations. The name and address of the applicant is: Aerial Concepts LLC ATTN : Brad Gibson Ph: (918) 691

- 3420 Email: bradgibson@aerialconceptsok.com Address: 6924 S 67 th East Avenue Tulsa , OK 74133 Web: www.aerialconceptsok.com Aerial Concepts LLC respectfully requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regulations: 14 CFR 21; 14 CFR 91, et seq., 14 CFR 45.23 Aerial Concepts also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 45.23(b); 14 CFR Part 21;14 CFR 61.1 13 (a) & (b); 91.7 (a); 91.9(b)(2);91.103(b);91.109;91.119;91.121;91.151(a); 91.203(a) & (b); • 91.405 (a) 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b).**I. The Extent of Relief**  **Aerial Concepts LLC Seeks and**  **the Reason It Seeks Such Relief**

Aerial Concepts submits this application in accordance with the Reform Act, 112 P.L . 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft sy stems) and operating to prevent Aerial Concepts contemplated commercial photograph y, Photographic mapping, and other flight operations within the U.S. national airspace s ys tem. The Reform Act in §332 provides for such integration of civil UASs into our national airspace sy stem as it is in the public's intere st to do so

. Aerial Concepts lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industries, the light dut y UASs used by Aerial Concepts are ideal recipients of exempt ion by

the intent of the Reform Act. Considerations for relief include a combination of sUAS phy sical characteristics, safety features, and safe practices identified in §333: • sUAS weight, • sUAS overall size, • sUAS speed over ground, • sUAS flight zone characteristics,

- Non

- operation near airports (civilian or military),

- Tightl y controlled operation in populated areas, Specific consideration is outlined below. • Operation of the UAS by VLOS. • Coordination by

a minimum of two ( 2 ) persons, two (2) staff members of Aerial Concepts and one (1) safet y official from the client. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural re quirements for the issuance of airworthiness certificates as required b y FAR §91.203 (a) (1). Given the size and limited operating area associated to sUASs, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under P art 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §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, o perational capability , and proximity to airports and populated areas of the particular sUAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the co nditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed. The sUAS to be operated by Aerial Concepts is less than 11kg. with maximal payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustible fuels, and operates exclusively within a secured area. Unlike other civil ai rcraft, operations under this exemption will be tightly controlled and monitored by both the pilot (PI C), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety

issues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liaisons to the on

- site safet y officials. These enhancements to current safety practices and regulations, which already appl y to civil aircraft, provide a greater degree of safe ty to the public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastl y, application of these same criteria demonstrates that there is no intrinsic credible threat to national securit y posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category

aircraft or experimental or 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 more than 6 inches high, the words "limited;' "restricted;' "light

sport;' "experimental;' or "provisional;' as applicable

. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUAS, two

- inch letteri ng will be impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space. The equivalent level of safety will be provided b y having the sUAS marked on its fuselage as required b y § 45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. Further marking s include the use of flashing green LED illumination on the underside of the sUAS frame , which stands at contrast against a blue or white sky

.14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot i n Command.

§61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring a ground crew member to have a private pilot's lice nse rather than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all f lights are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested wi th a private pilot in the ground crew exceeds the present level of safety achieved b y 14 C.P.R. §61.1 13 (a) & (b). 14 C.P.R. §91.7(a) : Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airwo rthy condition. As there will be no airworthiness certificate issued for the aircraft, shoul d this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safet y check lists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Ai rcraft. §91.9 (b) (2) provides: No person may

operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or an y combination thereof. The sUAS, given its size and configuration has no ability to carry a ph ys ical flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10 167, 10167A, 10602,32827, and 10700. 14 C .F.R. §91.103: Preflight action

. This regulation requires each PIC to take certain actions before flight to insure the safet y of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircra ft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created wi th the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to.14 C.P.R. §91.109: Flight instruction

. §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls sUASs and remotely piloted aircraft, by

their design , do not have full y functional dual co ntrols. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and fo r flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided b y the fact that neither a pilot nor passengers will be carried in the aircraft and b y the size and speed of the aircraft. Enhancing this safet y is the technology inherent in the remote controls utilizing digital communications , which is paired to the sUAS making it nearl y impossible to unintentionally or intentionally

have the control communications interrupted. 14 C.F.R. §91.119: Minimum safe altitudes

. §91.119 establishes safe altitudes for operation of civil aircraft. §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 altitude s prescribed for helicopters b y the FAA. As this exemption is for a sUAS that closel y mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may

be needed to allow such operations. As s et forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. It will however be operated in a restricted area with securit y officials tasked with ensuring public safet y, and where buildings and people will not be exposed to operations without their pre

obtained consent and training. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight operation will be taken without the permission of the propert y owner in the case of private propert y or local officials i the case of public property or private propert y with public interests. Because of the advance notice to the property owner and participants in the re mote sensing activity , all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 11kg of Aerial Concepts sUASs proposed herein and the lack of flammable fuel, an y risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with §91.119. 14 C.F.R. §91. 121 Altimeter Settings

. §91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to th e elevation of the departure airport or an appropriate altimeter setting available before departure."As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may

be needed. An equivalent level of safet y will be achieved by the operator, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The PI C and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height. 14 C.F.R . §9 1.15l (a): Fuel Requirements for Flight in VFR Conditions

. §91.151 (a) prohibit s an individual from beginning ‘ a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the fi rst point of intended landing, and, assuming normal cruising speed

- (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.’ The battery

powering the sUAS provides approximately 15 minutes of po wered flight in hover mode with out payload

. Aerial Concepts sUAS will not be able to meet the 30

- minute reserve requirement in 14 CPR §91.151. Operating the small UAS, in a tightly controlled area where only people and propert y owners or official rep resentatives who have signed waivers will be allowed, with less than 30 minutes of reserve power, does not engender the ty pe of risks that Section 9l.l51(a) was intended to alleviate given the size and speed of the small UAS. Aerial Concepts believes that an equivalent level of safety can be achieved b y limiting flights to » 10 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS toils planned landing zone from any where in it s limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and10808. 14 C.P.R. §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may

operate a civil aircraft unless the airworthiness ce rtificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS full y loaded weighs no more than llkg and is op erated without an onboard pilot. As such, there is no ability

or place to carry

certification and registration documents or to display them on the sUAS. An equivalent level of safet y will be achieved b y keeping these documents at the ground control point where the pilot fl yi ng the sUAS will have immediate access to them, to the extent they

are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9 78 9, 9789A, 9797, 9797A, 9816A and 10700.14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

. 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...;' and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply

to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety w ill be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of an y maintenance performed. Moreover, the operator is the person most familiar with the aircraft and bes t suited to maintain the aircraft in an airworth y condition to provide the equivalent level of safet y. An exemption granted to Aerial Concepts would permit its operation of lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited airspace. Aerial Concepts utilizes local business' safet y officers in specificall y determined areas (designed flight zone) to mitigate injury

and propert y damage while fulfilling clients' goals. Technical enhancements to current sa fet y controls will allow Aerial Concepts to operate exceeding current safet y specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department of Transportation. Further, Aerial Concepts conducts its operations in compliance with protocols described herein or as otherwise established by the FAA. **II. Commercial and Public Benefits**
We at Aerial Concepts believe that granting this exemption request furthers the public interest by providing safe (b y way of an unmanned s ys tem) and efficient means to meet technical problems solvable by

elevated data collection instruments. Aerial Concepts client base are t ypi cally small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection other Public Interest A erial videograph y for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to the petitioner would allow him to provide this service at a much lower cos t. Further more , the petitioner indicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation of his UAS will minimize ecolo gical damage and promote economic growth by providing information to companieslooking to relocate or build in the Tulsa , OK metro area by photo graphic, video graphic or lidar

based surveying. By moving these functions onto sUAS based aircraft, the potential for loss of life or propert y is diminished due to the greater control in a smaller and safer aircraft that holds no persons. Second, there are no reactive or combustible materials on board the sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of Aerial Concepts UASs allow the PI C to avoid hazards. Lastl y, due to the nature of the remote sensing instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and the object(s) undergoing scrutiny . Accordingly , Aerial Concepts UASs have operated and will continue to operate at and above current safety levels. A. The costs and benefits of your proposed action to society in general and specific groups within society

. As described above, Aerial Concepts past customers have been small to medium business seeking a remote sensing solution to specific issues. Examples include aerial inspection of residential and commercial buildings to survey current conditions, s urveying of large land lots, visual and photographic evidence of land locked properties, collection of video and images for tree removal services in remote, private areas, and searching for missing cattle in dense foliage areas. The impact to societ y, fin ancial and otherwise, would be extremely minimal. Indeed, it's been demonstrated that sUASs have the ability to drastically increase the information available to policy makers at a fraction of the cost of measuring this data b y terrestrial means. One such i mpact would be inconvenience to directly proximal and non

- essential personnel that would be displaced from public or business owned property if it is deemed to be unsafe. In this case we relay our needs for a f1ight zone with the requirement that it be saf e from casual intrusions and allow the business time to shift operations in order to minimize potential safety issues. This is best performed with the aid of safet y personnel that actively steer non

- essential persons around the flight zone.
B. The effect of an exemption for Aerial Concepts on the quality of the natural and social environments

. Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an onboard pilot, time

- consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civilian or military airports, and detrimental effects to theenvironment caused b y operating a combustible fuel based, large scale aircraft, with restrictions

on the proximity

to the target for remote s ensing. Ill. Flight Capabilities and Characteristics of Aerial Concepts UASs pursuant to 112 P.L . 95 §333 (a), concerns for public safet y are mitigated by the overall capabilities and characteristics of the sUAS. Aerial Concepts utilizes four (4) counter
- rotating propellers paired oppositely to each other for balance, control and stability . The total s pan of the sUAS is less than 1.2 meters allowing for stable flight or landing even with the sudden onset of detrimental environmental conditions. The sUAS's have a maximal unit+ payload mass of 11kg, including cinematic/photographic or other surveying equipment. Aerial Concepts sUAS is designed to primarily hover in place to capture photographic data and then operate at less than a 35 knot maximum sp eed to the next point of interest. They are capable of vertical and horizontal operations but, in practice, is operated onl y within unaided VLOS of the PI C. In addition to the PI C, Aerial Concepts employ s a spotter (VOS role) and a technician (secondary

VO S and on

- site personnel liaison) , which are within unaided verbal communication range. These personnel are supplemented b y safety officials provided b y the client. More characteristics have been outlined in the enclosed supplemental materials. We also otherwise minimize pedestrian access in the flight zone of the client's grounds. In the event of visual loss with the UAS, the PI C can change flight controls from Cartesian (X,Y,Z ) based controls to radial (r,a ,h) based controls which allows the PI C to utilize one controller axis to recall the VAS to the PI C' s position without concern to the current heading of the sUAS. In the event of loss of sight of the sUAS into an area containing hazards or possible hazards, the spotter has a heads

- up - display contai ning a live video feed which can be used to locate the UAS while it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by

GPS coordinates in hover mode in "

- '2Skph wind gusts at rv25 feet representing an extreme environmental condition beyond the range of conditions within the scope for sUAS operation. All of Aerial Concepts sUASs utilize L iPo (lithium poly mer) battery

based power sources, decreasing safety

risks from more easil y combustible, fuel based, power sources. Flight times generall y last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without payload is 15 minutes, however practical safe operation limits this to 10 to giv e ample time to control the sUAS to a safe landing zone

. Aerial Concepts further restricts flight time by not operating its sUASs with less than twent y five percent battery

capacit y. Further safet y management sy stems in place include a GPS mode that allows Aerial Concepts sUASs to hover in place if communication with the PI C is lost andoptionally follow a set of way

points at a set speed and height to a 'home base' pre

- designated safe landing zone. In the event of UN

- foreseen motor(s) failure, the s ys tem wi ll enter into a controlled descent while allowing full use of all UAS flight controls by the PI C. All commands sent via remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's real time 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity . This assures that if one sy stem is compensated a safe and successful landing can still occur.
**III .**  **Emergency Pr**  **oce du**  **r es**  In the event of emergencies related to the operation of the UAS, Aerial Concepts LL C has enacted various equipment and t actics to minimize issues during flight. They include:

• Lo ss of Remote Signal

- The flight package features an optional enhanced fail

- safe s ys tem , which returns the UAS to the home base way point via the same path taken to the point of lost signal.

- The UAS will then perform a hover over this waypoint and then a controlled landing. • Lo ss of GPS S ignal

- The sy stem will operate in assis ted mode with three (3) GPS satell i tes
.

- The flight package features an optional enhanced fail

- safe s ys tem, which returns the UAS to the home base way point via the same path taken to the point of lost signal.

- In the event of signal loss with the three (3) G PS satellites, manual mode can be activated or the flight package can be programmed to perform a controlled landing to the home base way

point.

- Ground based height ranging is prefo r med b y a separate s ys tem and so l oss of the GPS single will not impact a controlled and safe landing. • Lo ss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the sy stem will enter into a controlled spin where all controls ar e trans l ated based on the current orientation and will behave as normal operation to the PI C to ensure a safe landing.

- In the event of multiple rotor or motor failure, the flight package can be configured to perform a safe landing or attempt operation to a home base way point.

- Note : Behavior of the landing location is highl y dependent on the position and number of rotors/motors that are affected. • Lo ss of Ground Control Software

- This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.**IV. Reasons Why an Exemption to**  **Aerial Concepts Will Not Adversely Affect Safety** 

**Standards** Aerial Concepts contends that operation of it's sUASs will not "create a hazard to users of the nation al airspace s ys tem or the public:' as stated in 112 P.L . 95 §333 (b). Given the diminutive size and weight of Aerial Concepts sUASs, combined with their operation in cordoned off and well

- controlled areas, Aerial Concepts sUASs falls within Congress's contemplated safet y zone. Aerial Concepts sUASs have an established safety record bolstered b y multi

- point preflight checklist, awareness of their surroundings and intimate knowledge of the behavior of the sUAS platform in many

weather conditions. TI 1is sa fet y record and implemented operational practices demonstrate an awareness of public safety. Aerial Concepts operations routinely provide a level of safety

at least equal to existing rules, and in nearl y every instance, exceeds existing rules. Aerial Conc epts has worked very closel y with the regional vendors and support for this unit to create a tightl y integrated and highl y tolerant platform that has been tested thoroughl y by a vendor with a proven record for safety and solid designs. Aerial Concepts als o continues to work closely with organization s to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to the aviation and transportation . Aerial Concepts does not operate its UASs on or near airports and ge nerally has only operated its fleet on private grounds with cordoned off areas or areas under the control of the propert y owner I client with assistance by safety officials employed by

the business. Aerial Concepts determines the areas needed to fulfill th e clients' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby groups and recently

codified b y relevant FARs. Aerial Concepts has standardized the following practices to ensure safe operation of it s UASs:

 Work wi th on

- site personnel to plan flight goals
 Work with on

- site personnel to restrict access to non
- essential persons
 Operation by unaided VLOS operation only
 Operation in phases 10 minutes in length,
 Operation to minimal 25% battery power,
 Operation of device to GPS aid ed readout to 300ft at maximum,
 Numerous pre

- programmed fail

- safes that ensure specific behavior per issue
 Three main roles supplement ed by on - site safety personnel,
 Em ploy controlled lifecycle management of components to guard against multiple failures
 Preform a site check day(s) before flight to identify potential issues
 Subscribe to relevant local weather and safety alerts
 Expertly choose data collection instruments and accessories to minimize flight re quirements or expertise
 Aerial Concepts has experience in similar fields and has adapted this experience in it's use of UASs to increase safety.In combination to the ever

- expanding knowledge repositories from hobbyists and experts alike,

Aerial Concepts is constantly evolving it s practices when there is a clear benefit to operations or increased safety

element.
**V. Summary**  Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Aerial Concepts {applicant) seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 91.103{b); 91 .109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate commerciall y a small unmanned vehicle (11kg or less) in elevated photographic and remote sensing operations. Appro val of exemptions allowing commercial operations of sUASs in the media industry will enhance safety

by reducing risk associated with conventional aircraft operations and other means of elevated remote sensing involving persons. The public benefit served b y approval of this petition is increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than 1lkg and powered b y sealed batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed data. The operation of small UASs, weighting less than 55lbs., conducted in the strict conditions outlined above, will provide an equivale nt level of safet y supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. As identified and described herein, Brad Gibson , and his company Aerial Conc epts LLC, is an experienced, recognized media services professional in the various ph otographic and videograph y industries. Mr. Gibson and his company have been producing and delivering media and technical solutions for th e media service industry for two ( 2 ) ye ars with a spotless safet y record. The FAA has been given the authority to issue the exemption to Aerial Concepts pursuant to the Federal Aviation Act, 85 P.L . 726 (1958), and as such, we humbl y seek your consideration and approval of this petition.
Note: All irregu l ar behavior has root cause anal ys is performed before UAS operation is resumed.**VI. Supplements** 

The following links are supplements related to the operation of the UASs in operation under the control of Aerial Concepts LLC and are specifically related to the SteadiDrone Quad4: http://www.steadidrone.com/support/QU4DQuickstartGuide.pdf http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_Guide_v1.26_en.pdf http://www.steadidrone.com/support/check.jpg http://www.steadidrone.com/support/PeriodicMaintenanceChecklist.pdf http://www.steadidrone.com/support/QU4DAirframeAssemblyGuide.pdf

Respectfully

submitted,

Brad Gibson Aerial Concepts LLC 6924 South 67 th East Ave Tulsa, OK 74133

- 1725 918

- 691

- 3420