February 5 , 201 6

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request under § 333 of the FAA Modernization and Reform Act of 2012 of the Federal

Aviation Regulations from 14 CFR Part 21; 14 CFR §§ 45.23(b); 61.113 (a) & (b); 61.315(a) & (c);

91.7(a); 91.9(b); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203; 91.405(a); 91.407(a)(1);

91.409(a)(2); 91.417(a) & (b).

Dear Sir or Madam,

Pursua nt to § 333 of the Federal Aviation Administration ( “ FAA ” ) Modernization and Reform

Act of 2012, Pub. L. No. 112

- 95 (2012), 126 Stat. 11 (the “ Reform Act ” ), the FAA ’ s general exemption

authority under 49 USC § 44701(f), and 14 CFR Part 11, UpUp Aerial Imag ing LLC. (hereinafter, the

“ Petitioner ” ), an owner and operator of small Unmanned Aircraft Systems ( “ UAS ” ), hereby petitions for

exemptions from 14 CFR Part 21, Subpart H (Airworthiness Certificates), 14 CFR §§ 45.23(b), 61.113(a)

& (b), 61.315(a) & (c), 9 1.7(a), 91.9(b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a)

& (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). The proposed exemptions, if

granted, would allow Petitioner to conduct commercial operations of smal l UAS for purposes to include:

aerial photography, aerial videography (marketing), precision agriculture, real estate, exterior structure

inspections, UAS training, and volunteer search and rescue missions under the conditions outlined herein

and as may be established by the FAA in granting the above requested exemptions.

As described more fully below, based on the small size of Petitioner ’ s UAS, the qualifications and

experience of Petitioner ’ s pilot, and the limited, controlled

- access environments within which Petitioner

will operate, the requested exemptions clearly fall within the safety parameters envisioned by Congress as

set forth in § 333 of the Reform Act. Additionally, the enhanced safety achieved by replacing significantly

larger manned aircraft carrying crew and flammable fuel with small UAS weighing less than 55 pounds

under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that

the UAS operations enabled by this petition are in the public interest. Thus, the requested exemptions

should be granted.

T HE NAME AND ADDRESS OF P ETITIONER :

UpUp Aerial Imaging LLC

Attn: David Wilkeson, Partner

4641 Canfield

- Niles Road

Canfield, OH 44406

330

- 333

- 1186

dave@upupvideo .comB ACKGROUND OF P ETITIONER

Petitioner is a multifaceted digital media, digital marketing, film, and video production company

founded by Rob Palowitz, David Wilkeson, and Nick Miller. Mr. Palowitz is also the owner of Palo

Creative, a n advertising and digital marketing company founded in 1999

. His experience spans over 25

years of target marketing, direct mail and graphics production. Mr. Miller is an experienced digital media

specialist and hobbyist UAS enthusiast being involved with every facet of up and coming technologies

.

Mr. Wilkeson is a career technology entrepreneur as well as a n FAA licensed private pilot since 1996 , and

has extensive experience as a hobbyist UAS pilot dating back to the mid

- 1980 ’ s

. The team ’ s combined

background in aviation , film, video, and photography production, and knowledge and experience with

UAS platforms provide a level of trust that will ensure the integrity and safety of all UAS operations

conducted by Petitioner pursuant to the requested exemptions.

Petitioner se eks to complement the years of successful marketing campaigns produced by Palo

Creative, as well as offer imaging services directly to other clients, and leverage Mr. Wilkeson ’ s aviation

skills and knowledge to offer the widest possible range of UAS servic es in a manner consistent with the

parameters set forth in § 333 of the Reform Act. Petitioner seeks the requested exemptions to permit

Petitioner to offer commercial UAS services for a variety of industries and applications, including:

• Aerial surveyi ng and mapping

• Precision Agriculture inspections

• Aerial photography

• Aerial videography and video marketing

• Real estate marketing and inspections

• Exterior structure inspections

• General construction and contracting

• Pipeline preparation or survey

• Interior manufacturing inspection or mapping

• Public entity support operations

• UAS training, and

• Volunteer search and rescue operations

Petitioner plans to conduct operations under the requested exemptions using the DJI In spire 1, DJI

Phantom 3 Profess ional , 3D Robotics Y6, and 3D Robotics Solo small UAS.

R EQUESTED E XEMPTIONS

Petitioner requests relief from the following regulations:

• 14 CFR Part 21;

• 14 CFR § 45.23(b);

• 14 CFR § 61.113(a) & (b);

• 14 CFR § 61.315(a) & (c);

• 14 CFR § 91.7(a);• 14 CFR § 91.9(b)(2);

• 14 CFR § 91.103(b)(1);

• 14 CFR § 91.109(a);

• 14 CFR § 91.119;

• 14 CFR § 91.121;

• 14 CFR § 91.151(a);

• 14 CFR § 91.203;

• 14 CFR § 91.405(a);

• 14 CFR § 91.407(a)(1);

• 14 CFR § 91.409(a)(2);  14 CFR § 91.417(a) & (b)

E XTENT OF R ELIEF S OUGHT BY P ETITIONER AND R EASONS FOR S EEKING S UCH R ELIEF

14 CFR Part 21, Subpart H: Airworthiness Certificates

This section establishes the procedural requirements for the issuance of airworthiness certificates

and other airworthiness approvals . Given the size, weight, speed, and limited operating area associated

with the UAS to be utilized by Petitioner, an exemption from 14 CFR Part 21, Subpart H (Airworthiness

Certificates), subject to certain conditions and limitations, is warranted, and me ets the requirements for an

equivalent level of safety under 14 CFR Part 11 and § 333 of the Reform Act. 49 USC § 44701(f) and

§ 333 of the Reform Act both authorize the FAA to exempt aircraft, including UAS, from the requirement

for an airworthiness certificate upon consideration of the size, weight, speed, operational capabilities,

proximity to airports and populated areas, and operation within visual line of sight. The UAS operated

without an airworthiness certificate in the restricted environment and under the conditions and limitations

proposed by Petitioner will be at least as safe, or safer, than a conventional aircraft (fi xed wing or

rotorcraft) operating with an airworthiness certificate issued under 14 CFR Part 21, Subpart H, and not

subject to the proposed limitations and conditions.

The UAS to be operated by Petitioner (DJI Inspire 1, DJI Phantom 3 Professional, 3D Rob otics

Y6, and 3D Robotics Solo ) all weigh much less than 55 lbs. fully loaded, will be operated at a speed of no

more than 50 knots, will carry neither a pilot nor passengers, will carry no explosive or flammable

materials or fuel, and will be operated exclusively in predetermined, controlled

- access environments.

Petitioner ’ s UAS will use a radio frequency spectrum for operation and control that complies with Federal

Communications Commission ( “ FCC ” ) requirements, and will be operated only in accordance with the

procedures proposed herein and as may be established by the FAA.

Petitioner ’ s UAS will be equipped with redundant safety mechanisms allowing safe operation

after experiencing certain in

- flight failures. If a lost

- link event occurs, including loss of ground

communications or loss of GPS signal, Petitioner ’ s UAS will have the ability to perform a pre

- coordinated,

predictable, automated flight maneuver and return to a predetermined location within a designated security

perimeter for landing.

Unlike operations of other civil aircraft, operations under the requested exemptions will be tightly

controlled and monitored by both the pilot in command ( “ PIC ” ) and a Visual Observer ( “ VO ” ) in order

to ensure the Petitioner ’ s UAS remains within operational limi tations and to ensure the safety of

operations. These enhancements to current safety practices and regulations provide a greater degree of

safety to the public and property owners than conventional aircraft operations conducted by aircraft with

an airworth iness certificate. Lastly, there is no intrinsic credible threat to national security posed by UASdue to the size, speed, restricted operational environments, lack of explosive materials and flammable

fuels or other liquids, and inability to carry passeng ers or a substantial external load.

14 CFR § 45.23(b): Display of Marks

This section requires that “ [w]hen marks include only the Roman capital letter “ N ” and the

registration number is displayed on limited, restricted, or light

- sport category air craft 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, ” “ r estricted, ” “ light

- sport, ” “ experimental, ” or “ provisional, ” as applicable. ”

Even though the Petitioner ’ s UAS will have no airworthiness certificate, an exemption may be

necessary as the UAS will have no entrance to the cabin, cockpit, or pilot station on which the word

“ experimental, ” etc., can be placed. Also, given the size of Petitioner ’ s UAS, two

- inch lettering will be

impossible. Petitioner understands the need for markings and will mark all of its UASs in the largest

possible lettering on the UAS fuselage so that anyone observing Petitioner ’ s UAS will be able to see the

markings.

14 CFR § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command (PIC) and

14 CFR § 61.315(a) & (c): Sport Pilot Privileges and Limitations

These sections limit private pilots and sport pilots to non

- commercial operations. Because

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

level of safety of current operations by requiring the PIC opera ting Petitioner ’ s UAS to have a private

pilot ’ s or sport pilot ’ s license rather than a commercial pilot ’ s license to operate Petitioner ’ s small UAS.

Unlike a conventional aircraft that carries the pilot and passengers, Petitioner ’ s UAS are remotely

contro lled with no persons onboard. The area of operation will be controlled and restricted, and all flights

will be planned and coordinated in advance. The risks associated with the operation of Petitioner ’ s UAS

are so diminished from the level of risk associat ed with commercial operations contemplated by 14 CFR

Part 61 when drafted, that allowing operations of Petitioner ’ s UAS as requested with a private pilot or

sport pilot as the PIC exceeds the present level of safety achieved by 14 CFR §§ 61.113(a) & (b) an d

61.315(a) & (c).

14 CFR § 91.7(a): Civil Aircraft Airworthiness

This section prohibits any person from operating a civil aircraft unless it is in an airworthy

condition. As there will be no airworthiness certificate issued for Petitioner ’ s UAS, sho uld 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 UAS manufacturer ’ s manuals and use of safety checklists 1

prior to each flight, an equivalent level of safety will be provided. In accordance with the pertinent part of

1 See Appendix A14 CFR § 91.7(b), the PIC for all of Petitioner ’ s UAS operations shall be responsible for determining

whether the aircraft is in a safe conditio n for flight, including the use of pre

- flight safety checklists. 2

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements

This sections provides in pertinent part that “ [n]o person may operate a U.S.

- registered civil

aircraft ... 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 appro ved Airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof. ” Petitioner ’ s UAS, given their size

and configuration, have no ability to carry a physical flight manual on the aircraft. The equivale nt level

of safety will be maintained by keeping the flight manual at the ground control point where the PIC

operating Petitioner ’ s UAS will have immediate access to it.

14 CFR § 91.103(b)(1): Preflight Action

This regulation requires each PIC to tak e certain actions before flight to insure the safety of each

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will

be needed. Petitioner will comply with the other applicable procedures and requirement s stated in §

91.103(a) & (b). Specifically, the PIC will take all action including reviewing weather, flight battery

requirements, aircraft performance data, and landing and takeoff distances before initiating a flight. The

PIC will also account for all relevant site

- specific conditions in their preflight procedures. 3 Risks presented

by sun glare will be mitigated by the PIC ’ s and VO ’ s ability to see other air traffic and initiate a return

- to

home sequence if needed.

14 CFR § 91.109(a): Flight Instr uction

This section provides in pertinent part that “ [n]o 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. ” UAS, by their design, do not have fun ctional dual controls. Flight control is accomplished

through the use of a control box that communicates with the aircraft via radio communications. Given the

size and speed of Petitioner ’ s UAS, an equivalent level of safe training can be achieved withou t dual

controls because no pilot or passengers are aboard the UAS and all persons will be a safe distance away

in the event that the UAS experiences any difficulties during flight instruction. The FAA has approved

exemptions for flight training without f ully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. See Exemptions Nos. 5778K and 9862A.

14 CFR § 91.119: Minimum Safe Altitudes

2 Id.

3 Id.This section establishes minimum 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 altitudes prescribed for helicopters by the FAA . Similarly,

§ 91.119(c) provide s that, over other than congested areas, no person may operate an aircraft below an

altitude of 500 AGL, except over open water or sparely populated areas. As this exemption is for a UAS

that closely mimics the flight characteristics of a helicopter, and t he exemption requests authority to

operate at altitudes no higher than 400 feet AGL, an exemption may be needed to allow such operations.

As set forth herein, Petitioner ’ s UAS will never operate at higher than 400 feet AGL, nor beyond

visual line of sight ( “ VLOS ” ) of the PIC and VO, whichever is closer. It will, however, be operated in a

restricted area with individuals tasked with ensuring public safety, and where buildings and people will

not be exposed to operations without their pre

- obtained consent a nd training.

The equivalent level of safety will be achieved given the size, weight, and speed of Petitioner ’ s

UAS as well as the restricted environments within which they will be operated. No flight will be taken

without the permission of the property o wner. Because of the advance notice to the property owner and

the participants in the UAS operation, all affected individuals will be aware of the planned flight

operations. Compared to flight operation with manned aircraft or rotorcraft weighing far more than

Petitioner ’ s UAS and the lack of flammable fuels onboard, any risk associated with Petitioner ’ s operations

is far less than that presently presented by conventional aircraft operating at or below 500 feet AGL. In

addition, the low

- altitude operations of Petitioner ’ s UAS will ensure separation between Petitioner ’ s UAS

operations and the operations of conventional aircraft that must comply with § 91.119. Furthermore, the

manufacturer of some of Petitioner ’ s UAS, DJI, has implemented Firmware updates th at limit UAS flights

around airports, along with distance and elevation limits.

14 CFR § 91.121: Altimeter Settings

In pertinent part, this section requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set to “... the elevation of the departure airport or an appropriate

altimeter setting available before departure. ” As Petitioner ’ s UAS may not have a barometric altimeter,

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

achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator, and

prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the

PIC. The PIC will a lso ensure effective pairing with multiple GPS sources to guarantee accurate detection

of altitude.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This section prohibits a person from beginning “ a flight in an airplane under VFR c onditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing, and, assuming normal cruising speed — (1) during the day, to fly after that for at least 30

minutes; or (2) at night, to f ly after that for at least 45 minutes. ”

The battery powering Petitioner ’ s UAS provide approximately 12

- 15 minutes of powered flight

in hover mode without payload. Thus, Petitioner ’ s UAS will not be able to meet the 30 minute reserve

requirement containe d in 14 CFR § 91.151(a). Operating Petitioner ’ s UAS in a tightly controlled area

where only people or property owners or official representatives who have signed waivers will be allowed,with less than 30 minutes of reserve power, does not engender the type of dangers that § 91.151(a) was

intended to alleviate given the size and speed of Petitioner ’ s UAS. Petitioner believes that an equivalent

level of safety can be achieved by prohibiting Petitioner ’ s PIC from beginning any flights unless,

considering the wind and forecast weather conditions, there is enough available power for Petiti oner ’ s

UAS to conduct the intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manufacturer, whichever is greater. This restriction would be more than

adequate to return the Petitioner ’ s UAS to its planned landing zone from anywhere in its limited operating

area. FAA has granted similar exemptions; see e.g. Exemption Nos. 2689F, 5745, 10673, and 10808.

14 CFR § 91.203(a) & (b): Civil Aircraft: Certifications Required

This regulation provi des in pertinent part that “ (a) ... 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 certificate required by paragraph (a) of this section ... is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. ”

Petitioner ’ s UAS fully loaded weighs less than 55 pounds and is operated without a pilot

, passengers, or crew onboard. As such , there is no is ability or place to carry certification and registration

documents or to display them on Petitioner ’ s UAS. An equivalent level of safety will be achieved by

keeping these documents at the ground control station where the PIC will have imm ediate access to them,

to the extent they are applicable to Petitioner ’ s UAS. FAA has issued numerous exemptions to this section;

see e.g. Exemption Nos. 9565, 9665, 9789, 9789A, 9797, and 10700.

14 CFR § § 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (2), a nd 91.417(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 sections and Part 43 apply only to aircraft with an airworthiness c ertificate, these

sections will not apply to Petitioner. Petitioner will strictly adhere to the safety and maintenance

procedures included in all applicable UAS manufacturer ’ s instructions and operating manuals. To the

extent such information is not inclu ded in the guidelines as developed by the manufacturers, Petitioner

will undertake to develop and document maintenance, overhaul, replacement, and inspection

requirements, and procedures to document and maintain maintenance records with regards to Petition er ’ s

UAS. 4 An equivalent level of safety will be achieved because Petitioner ’ s UAS are very limited in size

and will carry small payloads and operate only in restricted areas for limited periods of time. If mechanical

issues arise, Petitioner ’ s UAS can lan d immediately and will be operating from no higher than 400 AGL.

The Petitioner will ensure that its UAS are in working order prior to initiating each flight, perform regular

maintenance, and keep a log of any maintenance performed. Moreover, Petitioner i s the person most

familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition in order to

ensure safe operations.

4 See Appendix B , Appendix C , and Appendix DE QUIVALENT L EVEL OF S AFETY

Petitioner proposes that the exemptions requested herein apply to civil aircraft that have the

characteristics and that operate within the limitations listed herein. Petitioner ’ s requested exemptions will

not adversely affect safety, and Petitioner ’ s propo sed operational limits will provide for at least an

equivalent or even greater degree of safety than for similar operations conducted using conventional,

manned aircraft, due to the size, speed, and limited operating area of Petitioner ’ s UAS.

The UAS Peti tioner plans to operate are small, multi

- rotor rotorcraft, each weighing much less than

55 pounds including their payload. They will operate, under normal conditions, at a speed of no more than

50 knots. Operations will be performed by a fully qualified and trained UAS PIC, as outlined below, to

ensure that Petitioner ’ s UAS will “ not create a hazard to users of the national airspace system or the

public. ” Given the small size of Petitioner ’ s UAS and the pre

- planned, controlled

- access environment

within wh ich they will operate, Petitioner believes that these operations fall squarely within that zone of

safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of

UAS to commence immediately. Also, operation in a secur ed, pre

- defined area will prevent the possibility

of a national security issue. The operation of Petitioner ’ s UAS by knowledgeable aviation professionals

with experience in the national airspace system ( “ NAS ” ) will serve to enhance safety, add to the publi c

benefit, and reduce environmental impacts related to current methods of aerial operations of the kind

proposed by Petitioner.

The limitations and conditions to which Petitioner agrees to be bound when conducting

commercial operations under this petiti on include but are not limited to the following, at a minimum:

1. Safety will be the first and foremost consideration for all of Petitioner ’ s UAS operations.

2. Petitioner will conduct operations using only the DJI Inspire 1, DJI Phantom 3 Professional, 3D

R obotics Y6, and 3D Robotics Solo UASs, each of which weighs less than 55 pounds fully loaded.

3. Petitioner ’ s UAS PIC will be required to be an FAA licensed airman with at least a Sport Pilot

certificate and hold at least an FAA Third Class Medical certifica te or valid driver ’ s license.

4. Petitioner ’ s UAS PIC will be responsible at all times for the safe operation of each flight

conducted pursuant to the requested exemptions.

5. All flights will be operated within VLOS of the PIC at all times.

6. All operations wi ll utilize a visual observer ( “ VO ” ). The VO will be used to maintain VLOS with

the UAS so long as the PIC also always maintains VLOS capability, and the PIC and VO will at

all times remain close enough to be able to communicate verbally during flight opera tions. The

PIC will be responsible for ensuring that the VO can perform the duties required by the VO.

7. The UAS will operate at no more than 50 knots, and in no case will UAS be operated at airspeeds

greater than the maximum operating airspeed recommended by the UAS manufacturer.

8. This exemption, if granted, and all other documents needed to operate Petitioner ’ s UAS and

conduct operations in accordance with the limitations and conditions as set forth herein and as

established by the FAA will at all times b e kept with the PIC at the ground control station and

will be immediately available upon request.

9. Petitioner ’ s UAS will utilize GPS navigation, failsafe, return

- to

- home ( “ RTH ” ), and/or flight

abort safety features.

10. The PIC will be prohibited from beginning a flight unless, considering the wind and forecast

weather conditions, there is enough available power for Petitioner ’ s UAS to conduct the intendedoperation and to operate after that for at least five minutes or w ith the reserve power recommended

by the manufacturer, whichever is greater.

11. Flights will be operated at an altitude at or below 200 feet above ground level ( “ AGL ” ) under

normal conditions, and will never exceed 400 feet AGL.

12. Petitioner will not allow its PIC to operate unless the PIC demonstrates the ability to safely operate

Petitioner ’ s UAS in a manner consistent with how the UAS will be operated as proposed herein,

including evasive and emergency maneuvers and maintaining a ppropriate distances from persons

and property, and including familiarization with applicable airspace restrictions and the UAS

operations manuals.

13. Operations will only be conducted under Visual Flight Rules ( “ VFR ” ) conditions.

14. Petitioner ’ s UAS will only be operated within a pre

- planned, controlled

- access flight perimeter

sized so as to allow the PIC and VO to maintain VLOS with the UAS at all times during flight

operations.

15. A briefing will be conducted in regard to each planned UAS operation, and the sa fety thereof,

prior to operation at each new location.

16. All persons not directly involved with UAS flight operations will be prohibited from entering the

flight perimeter unless there exists therein barriers or structures sufficiently robust to protect

non participating persons from the UAS and/or debris in the event of an accident.

17. All UAS operations will be conducted over private or controlled

- access property with permission

from the property owner or property controller or their respective au thorized representative.

Permission from the property owner or controller or their authorized representative will be

obtained prior to each operation.

18. If the UAS loses communications or loses its GPS signal

, it will have the capability to return to a

pr e

- determined location within the flight perimeter.

19. The PIC will have the power, and the duty, to abort all flight operations in the event of unpredicted

obstacles or emergencies.

The Requested Exemptions Promote the Public Interest

The enhanced safety achieved by replacing significantly larger manned aircraft carrying

crew

, passengers, and flammable fuel with small UAS carrying no passengers

, crew

, or

flammable fuel under the specific guidelines and procedures proposed by Petitioner gives

FAA good cause to find that the UAS operations enabled by this petition are in the public

interest. Moreover

, by replacing the manned aircraft traditionally used for the kinds of

operations proposed by Petitioner with small UAS, Petitioner will be a ble to provide aerial

operations services at a greatly reduced cost, making these kinds of services available to a greater

range of businesses and consumers

, thereby enhancing the utility of aerial operations and

benefitting the economy as a whole. Simil arly

, the small

, electric battery

- powered UAS

utilized by Petitioner will benefit the public as a whole by greatly reducing the pollution

and ecological impact associated with traditional aircraft and rotorcraft operations

. Congress and t he FAA

, through passage of the Reform Act and in numerous Exemptions

(see e

. g. Exemption No. 11 062)

, have already recognized that UAS provide a greater degree of

flexibility and safety than traditional manned aircraft when used within certain operational limits

and for the kinds of operations proposed herein by Petitioner. Granting Petitioner exempti on tooperate its UAS commercially furthers economic growth and public safety while limiting the

ecological impacts of aerial operations. Thus

, FAA has good cause to grant this petition.

Conclusion

For the forgoing reasons

, the e xemptions requested by Petitioner herein should be granted and

Petitioner should be permitted to conduct commercial UAS operations in accordance with

the limitations and conditions proposed herein and as established by the FAA.

Respectfully submitted

,

David Wilkeson, Partner

UpUp Aerial Imaging LLC

## APPENDIX A Preflight Checklist

ENVIRONMENTAL :

□ Check for people, animals, property in the flight vicinity.

□ Nofy any bystanders or nearby property owner of your intentions.

□ If flying FPV, discuss flight plan with your check

‐ pilot.

□ If flying in controlled airspace, notify airspace authority of your intentions.

□ First Aid / Safety Kit on hand, stocked, readily accessible, and visible to anyone in the area

HARDWARE / EQUIPMENT :

== VISUALLY INSPECT THE AIRFRAME ==

□ Cracks (especially in high stress areas like joints)

□ Loose or damaged screws / fasteners / bands / straps / ties

□ Loose or damaged wiring

□ Loose or damaged connections (solder, plugs, etc)

□ Inspect prop mounts & screws & apply slight counter pressure on arms to check for loosened construction

□ I nspect/clean camera lens and ensure that cameras are secured

□ Ba ery /batteries fully charg ed, properly seated & secured

□ Remove props and test fail

‐ safe behavior (if applicable)

□ Props are smooth and free of damage/defect (check blade, surface, & hub)

□ Tighten prop adapters (careful not to over tighten which may damage prop)

□ Ensure voltage alarm is connected

□ Ensure arming/idle timeout is properly configured (6

‐ 15 seconds is generally acceptable)

□ Check whether the right model is selected in the transmitter (if applicable)

□ Check your RC transmitter shows the right range and c entering for all sticks

□ If desired, perform range test

PRE

‐ FLIGHT :

== POWER UP ==

□ Ba eries charged & secured

□ Posion quad in a level, safe location for takeoff

□ If using onboard video recorder (i.e., Gopro), turn on camera

□ All transmitter controls move freely in all directions

□ All transmitter trims in its neutral position

□ All transmitter switches in correct position (typically away)

□ Transmi er throttle to zero

□ Radio transmitter on

□ Connect /power on battery to airf rame

□ Ensure led indicators & audible tones are all correct

□ Timer on (if applicable)□ Scan for nearby people or animals

□ Stand clear

‐ audibly, loudly announce the word "CLEAR!"

□ Arm flight controller

== PRE TAKEOFF ==

□ Increase throttle slightly listening for any abnormalities

□ Short 20

‐ 30 second hover at 3

‐ 5 feet

( Listen for any weird vibrations or anything that sounds loose)

Version 1.1

## APPENDIX B Sample Maintenance Log

UpUp Aerial Imaging LLC – UAS Maintenance Log

DATE UAS ITEM (Motors, ESC, etc.) NOTES (maintenance performed, etc.)

## APPENDIX C Sample Battery Log

UpUp Aerial Imaging LLC – UAS Battery Log

DATE BATTERY FLIGHT TIME NOTES (Charge Time, etc.)

## APPENDIX D Sample Flight Log

UpUp Aerial Imaging LLC – UAS Flight Log

DATE UAS BATTERY FLIGHT AREA FLIGHT TIME NOTES (Client, Purpose of flight, etc.)