# ~ SKINNERLAWGROUP

July 28, 2015 Will S. Skinner 818.710.7708 direct

VIAFEDERAL EXPRESS

U.S. DepartmentofTransportation Docket Management System 1200NewJersey Ave., SE Washington, DC 20590 skinner@skinnerlawgroup.com

Re: ExemptionRequests SubmittedPursuantto Section 333 oftheFAA Modernization andReform Act of2012 and 14 C.F.R. 

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Dear Sir orMadam: Pursuant to Section 33 3 ofthe FAA Modemization and Reform Act of2012 ("FAA Reform Act") and 14 C.P.R. Part 11, Unmanned Aerial Enterprises, LLC. ("UAE"), a Califomia limited liability company, hereby requests exemptions from provisions of the Federal Aviation Regulations ("FAR"); namely portions of 14 C.P.R. Parts 45, 61, and 91 to allow commercial operations ofunmanned aerial vehicles in remote and rural areas ofthe United States, as further defined herein, by a Pilot-in-Command ("PIC") holding aprivate pilot certificate. 1 I. SUMMARYOF SECTION333 EXEMPTION REQUESTS 1. AeroVironmentPumaAE 2. PrecisionHawk 3. DJI S1000, S800 4. DJI S900 5. DJI F550 6. DJI F450 7. DJI Phantom 2

### + 8. Mulit-Rotor G4

1Public Law (P.L) 112-95, 126 Stat 11, February 14 2012

21600 Oxnard Street 

### I Suite 1760 

### I Woodland Hills CA 91367 

### I 818.710.7700 

### I 818.710.7701fax 

### I skinnerlawgroup.comU.S. Department ofTransportation DocketManagement System July 28, 2015 Page 2 II. AEROVIRONMENTPUMAAE EXEMPTION REQUEST The AeroVironment Puma AE ("Puma") is an all-environment, electric-powered, hand-launched, small UAS ("UAS"). Depending on its payload, it is capable of transmitting live airborne video images and location information to a Ground Control Station ("GCS"), conducting high-resolutionphotogrammetry, or LightDetection and Ranging ("LIDAR") data collection. When used for highresolution photographs and LIDAR data, the Puma stores the photographs and data via onboard non-volatile memory (i.e. "memory card" or equivalent). The Puma has a maximum weight of 15.5 pounds, a wingspan of9.2 feet, alength of4.7 feet, a minimum cruising speed of 36 ft/s and maximum speed of 69 ft/s. It is battery-powered with flight endurance between 2.0 to 3.5 hours, with operating range between -22°F to 122°F ambient temperature, and can be either hand or rail-launched. The Puma's omnidirectional antenna has a range of 6.2 miles, and its directional antenna has a range of 12.4 miles. 2 The Puma's capabilities make it ideally suited to conduct commercial operations in agriculture, aerial surveying, and remote-area patrols (i.e. patrols over non-congested areas) under Class E or Class G airspace within Visual Line of Sight ("VLOS"). Some Class D airspace may be used on a case-by-case basis and would be further defined during the Certificate ofAuthorization ("COA") process. The Pumareduces the needto operate manned aircraft, thereby decreasing the riskto the pilot, crew, and those on the ground as the Puma is simply carried as opposed to being flown to the site with a load offlammable fuel. The Puma is unique amid the exemption applications under Section 333 because it has received a restricted category type certificate from the FAA based on its acceptance for use by the US Military.3 Accordingly, the Puma has an unparalleled safety record. When its experience is considered within the proposed remote and/or rural areas, it is clear that the Puma has demonstrated, and will in this context again demonstrate, that it can operate safely within the confines ofthe National Airspace System ("NAS"). UAE'sexemptionrequestencompassesthe following regulations: 4

2 Formore detailed information on the Puma's specification, UAE directs the FAAto AeroVironment's type certificate data sheet QOOO18LA. UAE also incorporates by reference all ofthe materials submitted in support ofAeroVironment's application for a Restricted Category Type Certificate, Q00018LA, and Certificate ofWaiver orAuthorization, 2014-AHQ-100. 3FAA, Press Release, FAA ApprovesFirst Commercial UASFlights overLand(June 10, 2014), http://www.faa.gov/news/press _releases/news _story.cfm?newsid=16354. 4 Based on a recent legal interpretation, UAE does not believe that it needs an exemption from 14 C.F.R.§§ 91.9(b), 91.203(a), and 91.203(b) because the Puma's flight manual, airworthiness exemption, and registration certificate will be maintained at the pilot's control station. FAALegal Interpretation from Mark W. Bury, Assistant ChiefCounsel for International Law, Legislation and Regulations (August 8, 2014). Should the FAA determine that an exemption is required, UAE respectfully requests one on the basis that similar exemptions have been granted on numerous occasions. See Exemptions 8607, 8737, 9299, 9565, 9665, 9789, 9797 10167, 10602, 10700, and 32827.U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 3

14 C.F.R. §45.23(b) 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §61.133(a) 14 C.F.R. §91.7(a) and (b) 14 C.F.R. §91.109(a) 14 C.F.R. § 91.119 14 C.F.R. § 91.151(a 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(2) 14 C.F.R. § 91.417(a)

Section 333'sMandate andtheFederalAviationAct Grant of this exemption application for use of the Puma in agriculture, precision aerial surveys, and patrols, pursuant to the exemption requested herein, will advance the Congressional mandate in Section 3 3 3 ofthe FAA Reform Act to accelerate the introduction of UAS into the NAS. Section 333 directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe FAA Reform Act. To make that determination, the Secretary must evaluate which types ofUASs do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofseveral criteria:



### • • • The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in closeproximity to airports andpopulated areas; and Operation ofthe UAS withinvisual line ofsightofthe operator

. FAA Reform Act§ 333(b)(1). Once the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." !d. § 333(c) (emphasis added).5 The Federal AviationAct expressly grants the FAAthe authority to issue exemptions. 49 U.S.C. §44701(f). This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, from the requirements that all civil aircraft must have a current airworthiness certificate, 49 U.S.C. § 44711(a), and those used in commercial service mustbe piloted by commercial pilots. 14 C.F.R. §§ 91.61.113(a) and (b), 61.133. The grant ofthe requested exemption is in the public interest based on (i) the clear direction in Section 333 of the FAA Reform Act; (ii) additional authority in the Federal Aviation Act, as amended; (iii) the strong equivalent level of safety surrounding the proposed operations; and (iv) the significantpublic benefit, including enhanced safety and cost savings associated with utilizing UASs for agriculture,

5UAE submits that this provision places a duty on the Administrator not only to process applications for exemptions under Section 333, but for the Administrator to supply conditions for the safe operation of the Puma if he deems the conditions proposed herein require modification necessaryto allow approval.U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 4 aerial survey photography, and patrolling. Accordingly, UAE respectfully requests thatthe FAA grantthe requested exemptionwithout delay. Airworthiness The Puma is safe for operation in the NAS under the conditions listed herein. The FAA has deemed the Puma safe because the US Military has accepted it for use. The US Military has flown the Puma since 2007, amassing over one million flight hours onthe AeroVironment family ofUAS. Based onthe US Military's acceptance ofthe Puma, the FAA issued the Restricted Category Type Certificate QOOO18LA and also recently granted AeroVironment a Certificate ofWaiver or Authorization to conduct commercial operations overland inAlaska. Shouldyou deem necessary, UAE is preparedto submit, in support ofthis application under separate cover and with a request for confidentiality, the following documents: the FAA-approved Airplane Flight Manual ("AFM") for the Puma, acceptedMay 20, 2014 by the FAA; the Puma's Maintenance Manual dated July 18, 2013; the North Slope Standard Operating Procedures Manual ("SOP") dated May 2014;6 the AV Training Conduct Support Document dated May 4,2012; and the AeroVironment Remote AreaUAS Operations Safety Case Assessment dated September 13,2014. Mandatory Operating Conditions UAE proposes that the grant ofthe exemptionbe subject to the following mandatory conditions, which are basedupon operating conditions set forth for operation ofUAS by public entities pursuantto Certificates ofWaiver orAuthorization, the conclusions ofthe Remote AreaUAS Safety Case Assessment, and with additional restrictions:

• All operations to occur in Class E or Class G airspace over areas with a population density of 360 persons per square mile or less.7 Some Class D airspace may be used on a case-by-case basis and would be further defined during the COAprocess. • Operations to be conducted over private or controlled-access property to limit the number ofpersons not associated withthe operationsplaced atrisk. • Permissionfrom land owner/controllerrequired before commencing any flight.

6The North Slope SOP identifies requirements and describes procedures for the AeroVironment Digital Imaging and Mapping team to coordinate, plan, and conduct imaging operations for services in support ofBP Exploration Alaska Nmih Slope, Alaska. AeroVironment's submission of the North Shore SOP indicates how seriously it takes the safety of its Puma operations. AeroVironment intends to supplement its application with a Standard Operating Procedures manual for operations in other remote areas as soon as possible. 7 See Section 2.2.5 ofthe AeroVironment Remote Area UAS Operations Safety Case Assessment dated September 13, 2014 for an explanation ofthe "remote area" definition. The benefits ofoperating in "remote areas" are discussed in further detail in the Section below entitled "Proposed Operations Locations."U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 5

• Operationsto occur during Visual FlightRules Meteorological Conditions. • Aircraftto remain withinVLOS. • Operationsto occur during daylighthours. • Above GroundLevel ("AGL") altitude to be restrictedto 400 feet. • Flights over sensitive infrastructure such as pipelines or roads will be minimizedto reducethe time the infrastructure is placed at risk. • Flights over sensitive infrastructure will be offset appropriately for the wind at the time offlight to reducethe riskto the infrastructure. • Launch and recovery areas will be cordoned off to limit access only to personnel associated withthe flight operation. • A dedicated Visual Observer (usually, but not always the PIC) will be utilized to Maintain overall operation situational awareness; maintain VLOS and scan for intruder traffic; monitor all radio communication to include "Guard" in accordance with any COA; and report on Common Traffic Advisory Frequency ("CT AF") and other frequencies as appropriate. • All operations conducted in vicinity of airport to remain more than 2.5 NM from • Centerline azimuth ofrunway centerline measured from runwaythresholds. • Operatorwill file aNoticeto Airman ("NOT AM") for eachflight. • All required authorizations and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other governmental agencies. Proposed Operations Locations UAE proposes to operate in areas where the population density is less than 360 people per square mile. Operating in these "remote areas" lowers the risk posed to third parties to 1 x 10-9

. Section 2.2.5 of the AeroVironrnent Remote Area UAS Operations Safety Case Assessment dated September 13, 2014 describes the methodology for determining the suitability ofoperational areas for these proposed commercial operations. Operations in such sparsely populated areas and at low altitudes do notcreate hazards for users ofthe NAS orthe public. OperatorRequirements UAE proposes that operator requirements should take into account the characteristics ofthe particular UAS. The Puma is an inherently stable, light-weight aircraft that weighs 15.5 pounds and will be operated in remote areas. The safety concerns addressed by requiring a commercial pilot certificate are simply not present. Moreover, the Pumahas an advanced autopilotthat flies the aircraft, while managing altitude and flight path within the intended flight envelope at all times when that flight mode is engaged. The autopilot limits maneuvering to minor airspeed, altitude, and rate-of-tum changes. These limits are hard coded into the autopilot and define the aircraft's normal flight operating envelope. The autopilot manages pitch, bank,U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 6 and throttle to maintain target airspeed, target turn rate, and target altitude. For inflight modes that do not use GPS, the operator manually guides the flight path by controlling target airspeed, target altitude, and target turn rate directly. In flight modes that use GPS, the autopilot controls target turn rate to fly to waypoints. The system does not allow commands that are outside ofthe nom1al operating envelope, andthe operator never affects control surface movements directly.8
LowRiskIndex The Pumais a modular structure, comprised ofcomposite materials, several ofwhich disassemble onimpact to decrease risk ofinjury to people, absorb energy, and reduce damage to the Puma during landing. To that end, the Puma's wing is composed of Styrofoam laminated with a thin layer of Kevlar that disassembles into its subcomponents uponimpact. The Puma Autoland feature enables landings in confined areas. Once Autoland begins, power is cut to the motor, the gimbaled payload is stowed (ifinstalled), and the stabilator deflects fully trailing-edge upward. As a result, the aircraft pitches nose-up, with wings level, and begins a descent to the ground with approximately a 1:1 glide ratio. The pilot can steer during the Autoland phase, ifrequired. Impact with the ground usually causes the Puma's components to separate. As noted above, this helps alleviate the impact ofthe landing and protects the airframe. During water landings, lanyards prevent separated parts from floating away from the fuselage, whichtoo will float. Landing pads onthe bottom ofthe fuselage also provide impact protection. During Loss ofLink ("LOL"),9the Puma has three options-finish the programmed flight, land immediately, or go to a rally point. Iflink is re-established during LOL, the aircraft operator can simply press the enter button on the hand controller to resume the indicated flight mode or change to a desired flight mode. Setting the LOL action prior to launch is a mandatory check on the pre-flight check list. During loss ofGPS, the pilot should use the Puma's last known bearing or tenain association to fly toward a landing site or select a suitable landing site and command the Puma to autoland. Given these safety features, UAE proposes that operators ofthe Puma should not be required to possess a commercial pilot certification. Instead, operators should be requiredto meetthe following criteria:

• Possessprivatepilot ce1iificate;

8 SeePumaAFM, at 55-56. 9 Loss ofLink is identified by unchanging video and unchanging data and time, as well as the appearance ofa clock symbol on the Link Status Bar. Loss ofLink does not necessarily mean thatthe Pumahas lost GPS.U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 7

• Maintain, at aminimum, a valid FAAthird-class medical certificate; and • Complete the manufacturer's US Military-approved training program for operationofthe UAS. UAE notes that the FAA has found that safety factors have permitted operation of UAS by operators withthese qualifications pursuantto COAs for public aircraftwhen the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). SpecificExemptionRequests andEquivalentLevelofSafety Showings 14 C.F.R. §45.23(b)- Display ofmarks; general Section 45.23(b) provides as follows: 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. The Puma has no entrance to the cabin, cockpit, or pilot station on which the word "Restricted" can be placed as required by this provision. Two-inch lettering also is not possible given the overall size of the Puma. UAE, therefore, requests an exemption to display, with one-inch lettering, the word "Restricted" on the forward fuselage in compliance with §45.29(f). The equivalent level ofsafety will be achieved by having the Pumamarked with oneinch lettering on its forward fuselage because the pilot, observer, and others working with the UAV will see the identification ofthe UAS as "Restricted." The FAA has issued similar exemptions to this regulation, including to Pioneer Hi-Bred International, Inc., Exemption No. 10810; Raytheon Missile Systems/Advanced Programs, Exemption Nos. 10167 and 8738; and Trimble Navigation Limited, ExemptionsNo. 10700 and 11042. 14 C.F.R. §§ 61.113(a) and (b), 61.133(a)

- Private Pilot Privileges and Limitations: Pilotin Command; CommercialPilotPrivileges andLimitations Subsections (a) and (b) of § 61.113 prohibit private pilots from operating aircraft in commercial operations, and Section 61.133(a) requires an individual operating an aircraft for compensation orhire to hold a commercialpilot certificate. As mentionedU.S. DepartmentofTransportation DocketManagement System July 28, 2015 Page 8 above, the FAA has the statutory authority to wmve the pilot requirements for conunercial operations. 49 U.S.C. §44701(£). UAE requests an exemption from 14 C.F.R. §§ 61.113(a) and (b) and 14 C.F.R. § 61.133(a) so that the Puma may be operated by individuals who (a) have a private pilot certificate, and (b) have completed AeroVironment's US Military-approved trainingprogramfor operation ofthe Puma. Based upon the design features ofthe Puma, its autopilot system, and safety factors, the FAA should permit operation ofUAS by operators with a private pilot certificate when the conditions described above have been satisfied. The above-described conditions are in-line with those set forth in FAA Order 8900.1, Volume 16, Chapter 4, Section 1. UAE proposes to conduct operations in accordance with these restrictions. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation ofthe Puma with a private pilot certificate. The risks associated with the operation ofthe Puma (given its size, speed, operational capabilities, and lack ofcombustible fuel) are so much less than the level ofrisk associated with fixed wing and rotorcraft operations, bothprivate and commercial, as contemplatedby Part 61, that allowing operations ofthe Puma, as set forth above, meets or exceeds the presentlevel ofsafetyprovidedunder 14 C.F.R. §§ 61.113(a) & (b) and 61.133(a). 14 C.F.R. § 91.7(a) and (b): Civil aircraft airworthiness. Sections 91.7(a) and (b) prohibit operation ofa civil aircraft unless it is in airworthy condition. UAE requests an exemptionfrom this regulationbecausethe Pumawould not operate with an airworthiness certificate under the proposal set forth in this filing. 10 Given the size ofthe aircraft and the requirements that have already been met in approval of AeroVironment's Restricted Category Type Certificate and Certificate ofWaiver or Authorization, an equivalent level ofsafety will be achieved by ensuring compliance withAeroVironment's manualspriorto eachflight. 14 C.F.R. § 91.109(a): FlightInstruction Sections 91.109(a) 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. The Puma is a remotely piloted aircraft, and, by design, it does not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. Completing

10 The restricted categorytype certificate thatAeroVironmenthas received for the Puma is limited to Alaska.U.S. DepartmentofTransportation DocketManagement System July 28, 2015 Page 9 instructionthroughAeroVironment'straining programwill ensure an equivalentlevel ofsafety. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instructioninexperimental aircraft. See ExemptionNos. 5778K and 9862A. 14 C.F.R. § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, Section 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. As set forth herein, the Puma will never operate at higher than 400 feet AGL. It will, however, be operated in a manner that avoids congested or populated areas as described in the Proposed Operations Locations section above. Because agriculture, aerial survey work, and patrolling must be accomplished at relatively low altitudes, i.e., less than 500 feet AGL, an exemption from Section 91.119(c) is needed. The equivalent level of safety will be achieved given the size, weight, speed, and material with which the Puma is built. Also, no flight will be taken without the permission ofthe landowner orthe party controllingthe land. With advance noticeto the landowner, all affected individuals will be aware ofthe agriculture, survey, and patrolling flights. Compared to similar operations conducted with conventional aircraft orrotorcraft, which weighthousands ofpounds and carry flammable fuel, any risk associatedwiththese operations will be far lessthanthose currently allowed with suchconventional aircraft operating at orbelow500 feet AGL. 14 C.F.R. § 91.151(a): FuelRequirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from begi1ming "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly afterthatfor at least45 minutes." 14 C.F.R. § 91.151(a). The Puma's batteriesprovide between 2 and 3.5 hours ofpowered flight. Without an exemption from 14 C.F.R. § 91.151, the Puma's flights would be limited to approximately 1.5 hours in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylightVFRconditions isreasonable.U.S. Department ofTransportation Docket Management System July 28, 2015 Page 10 Anexemption from 14 C.F.R. § 91.151(a) is safe and consistentwithinthe scope ofa prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operatingthe Puma, a UAS, without 30 minutes ofreserve fuel does not create the type ofrisks that Section 91.151(a) was meant to prevent. The fact that the Puma neither carries persons nor cargo only enhances its safety. Additionally, limiting Puma flights to 1.5 hours would greatly reduce its utility and capability. Inthe unlikely event thatthe Puma shouldrunout of fuel, it would simply land. Given its weight and materiel construction, the risks are less than contemplatedby the currentregulation. An equivalent level ofsafety can be achieved by maintaining 10 minutes ofreserve fuel, which, allowing one hour and 50 minutes offlight time, would be more than adequate to return the UAS to its planned landing zone from anywhere in its operating area. Similar exemptionshave been grantedto other applicants, including butnot limitedto Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §§ 91.405(a); 91.407(a)(l); 91.409(a)(2); 91.417(a): Maintenance Inspections Section 91.405(a) requires 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) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an mmual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires that an owner or operator keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Pm·t 43, or licensed pilots and records ofapproval ofthe aircraftfor returnto service. Maintenance ofthe Pumawill be accomplished onlybyUAEtrained staffpursuantto the manufacture's supplied manuals and training program. An equivalent level of safety will be achieved because the Puma is small in size, will carry no external payload, will operate only in restricted predetermined areas, and is not a complex mechanical device. As provided in the Maintenance Manual and the SOP, the operator ofthe Puma will ensure that it is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is perforn1ed. 11 Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensme an equivalent level ofsafety.

11 Although the remote area SOP will differ in some respects from the North Slope SOP, it will include the identical requirements that the Puma operator ensure the Puma is in working order prior to flight, perform required maintenance, and keep a log ofany maintenance performed.U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 11

The Puma comes with one Field Repair Kit ("FRK"). The FRK includes the items necessary to conductfield repairs orroutine maintenance. FederalRegister Summary Pursuant to 14 C.F.R. § 11.81(£), the following summary is provided for publication inthe Federal Register, shouldthe FAA determine thatpublicationis needed: DocketNo.: No. FAA-2015- Petitioner: UnmannedAerial Enterprises, LLC ("UAE"). Section of 14 CFR: 14 C.F.R. §45.23(b), 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 C.P.R. § 91.151(a), 14 C.F.R. § 91.405(a), 14 C.F.R. § 91.407(a)(1), 14 C.F.R. § 91.409(a)(2), 14 C.F.R. § 91.417(a). Description of Relief Sought: Unmanned Aerial Enterprises, LLC is seeking an exemption to conduct commercial agriculture, aerial survey, and patrol operations using a small unmmmed vehicle (55lbs or less) in remote and rural areas of the United States using privatepilots. UAE will file an application for COA approval ofspecific flight locations. Should the FAA need or require identification ofsuch location in this application, UAE will supplementthe record as requested. Based upon the foregoing, UAE requests that the FAA grant it the necessary exemptions under Section 333 ofthe FAA Reform Act and 49 U.S.C. §44701(£) as requested hereinto allow commercial operations ofthe Pumawithinthe areas defined above. 

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## * *U.S. Department ofTransportation DocketManagement System July 28, 2015 Page 12 Ill. EXEMPTION REQUESTSFORPREVIOUSLY APPROVEDUAS UAE hereby respectfully requests exemptionsto operate the following UAS based on like and similarexemptions already granted: Fixed "VingAircraft PrecisionHawk Multi-RotorAircraft DJI S1000, S800 DJI S900 DJI F550 DJI F450 DJI Phantom 2

### + Mulit-Rotor G4 PreviouslyApprovedExemptionNumber 11345 PreviouslyApprovedExemptionNumber 11401 11256 11397 11287 11138 11306 The requested exemptions would permit UAE to pursue its commercial interests in providing services to clients using UAS in rural or sparsely populated areas ofthe United States. ContactInformation UnmannedAerial Enterprises, LLC Attn: Will S. Skinner 21600 Oxnard Street, Suite 1760 Woodland Hills, CA 91367 (818) 710-7708 Direct (818) 710-7701 Fax skinner@skim1erlawgroup.com

Very truly yours,

Will S. Skinner