____________ Birds Eye Aerial Drones, LLC | 805

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2 3 February 2015

U. S. Department of Transportation Docket
Management System
1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request § 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR §
21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 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,

Pursuant to § 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Birds Eye Aerial Drones

, LLC , operator of Small Unmanned Aircraft Systems (sUAS )
equipped to conduct aerial filming and photographing to include: infrastructure inspections, aerial acquisition (mapping), real est ate, and other applicable areas for pre

- planned, controlled area s , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow c ommercial
operation of its sUAS s , so long as such operations are conduct ed within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by §

333. Birds Eye Aerial Drones

, LLC c urrent operation of sUAS for commercial purposes has been halted to
comply with re cently enacted federal avia tion regulations pertaining to s UAS

.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and multi

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

- site safety personnel controlling access, and 4) would provide increased safety
and enhancements to clients' business operations.
We are prepared to modify or amend any part of this request to satisfy the need for an
equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarification.

The name and address of the applicant is:

Birds Eye Aerial Drones, LLC

Scott J. Painter

CEO

Phone: 805

- 890

- 1991

Email: I nfo@BirdsEyeAerialDrones.com
Address: 6015 Sarita St, La Mesa CA, 91942

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BACKGROUND OF PETITIONER

Birds Eye Aerial D rones, LLC is a Veteran/Family owned business and is operated by Scott

Painter . Mr. Painter is a FAA licensed pilot with a high performance rating and holds a third class
medical certificate . He has been piloting for seventeen years and ha s been active in model radio controlled aviation for over twenty years. He has several thousand hours experience in
combined full scale and m odel aviation

. He has an extensive military aviation background a nd a

B.S. degree in aviation management . Mr. Painter is also an active member of Academy of Model

Aerona utics (AMA) and Aircraft Owners and Pilots Association ( AOPA )

.

Birds Eye Aerial Drones , LLC cu rrently operates two different types of registered s UASs and is currently registering an additional model to the fleet

.

• Team Black Sheep Discovery Pro (N848SP)

• Tarot T15 (N849SP)

• DJI Inspire (currently registering)

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT

The exemption request will permit Birds Eye Aerial Drones, LLC to operate sUASs commercially for the purpose of aerial filming and photographing inspections of infrastructure

, aerial acquisition (mapping)

, real estate, and other applicable areas . Birds Eye Aerial Drones, LLC will provide a service that is beneficial to an industry that is already using, and seeking to use, sUASs for these purposes with a legal and safe option. This will benefit the public with the controlled operation of sUASs and increase integration into the National Airspace System (NAS).

Birds Eye Aerial Drones, LLC s UASs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a s UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Conducting aerial acquisitions with Birds Eye Aerial Drones, LLC sUASs , instead of manned aircraft, will greatly benefit the public by drastically re ducing the levels of air and noise pollution generated during traditional aerial survey flight operations.

Previously high resolution digital aerial real estate photography was only affordable to a few
select a gencies with deep pockets. Birds Eye Aerial Drones, LLC would like to help chang e t his by employing our sUASs a nd make aerial photography affordable to everyone.

High quality aerial imagery and data can provide new and enhanced information about a location being surveyed, inspected, or otherwise measured.

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PUBLIC SAFETY

First, an d most importantly is safety. C onstruc tion continues to be one of the most dangerous
industries in our United States economy. Allowing Birds Eye Aerial Drones, LLC sUASs o perations

on construction sites , for the purpose of infrastructure ins pection, enables safety managers to gain valuable, on demand, aerial images . As a result, safety managers can identify possible hazards that may jeopardize worker health.

Utilizing Bi rds Eye Aerial Drones, LLC sUAS for aerial acquisitions will not have d etrimental effects to the environment caused by operating a combustible fuel bas ed, large scale manned
aircraft

.

Whether helping to protect the public, inspecting infrastructure or acquiring aerial imagery

,
s UAS s provide real

- time situational awareness, enabling better decision

- m aking. Better
decision

- making saves lives and protects property.

P RIVACY

Al l flights will occur over private or controlled access property with the property owner’s or controlling a uthority’s prior consent and knowledge. Aerial photography/f ilming will be of people who have also consented to being p hotograph ed or otherwise have agreed to be in the
area wh ere filming will take place.

C ONDITIONS AND LIMITATIONS:

As set forth in the Flight Operations and Procedures Manual ( FOPM ) and Manufacturers Pilot Training Guide ( MPTG ) , the applicant proposes the following li mitations and conditions :

1. UAS must weigh less than 55 pounds;

2. UAS airspeed not to exceed 50 knots;

3. UAS flights may not operate at more than 400 AGL and Altitudes reported to ATC must be in feet AGL;

4. UAS must be operated within V isual L ine of S ight (VLOS) of the PIC;

5. All operations will utilize a V isual O bserver (VO). The VO may be utilized as long as the PIC maintains VLOS capability and can communicate with the VO at all times;

6. The conditions and limitations will be added or amended in the operator’s manual;

7. The PIC will inspect the UAS to ensure it is safe for flight, along with the Ground Control Station (GCS) if utilized. All maintenance and alterations must be properly documented.

8. A functional test flight must be performed for any UAS that has undergone maintenance or alterations and be performed by the PIC and added to the operator’s manual;

9. T he operator must follows the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement inspection and life limit requirements. The following must be included in the operator’s manual;

a. Actuators / Servos;
b. Transmission (single rotor);

c. Power plant (motors);

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d. Propellers;

e. Electronic speed controller;
f. Batteries;

g. Mechanical or dynamic components (single rotor);
h. Remote command and control;

i. Ground control station (if used); and a ny other component(s) as determined by
the operator.
10. T he PIC must possess a private pilot certificate, a current third

- class medical certificate and meet the flight review requirements specified in 14 CFR § 61.56;

11. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight hours and 25 hours as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar s UAS s type;
12. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five hours as a s UAS pilot ope rating the make and model of s UAS to
be utilized for operations under the exemption and three takeoffs and three landings in the preceding 90 days. The PIC must operate the s UA Ss with appropriate distance from nonparticipants in accordance with 14 CFR § 91 .119;

13. The PIC and VO must have completed a qualification process;
14. A flight demonstration, administered by an operator approved and a qualified pilot must be completed and documented in accordance with the operator’s manual;

15. The s UA Ss may not be operated directly over any person, except authorized and consenting inspection personnel, below an altitude that is hazardous to persons or
property;
16. All participating persons must be essential and consent to the UAV operation which should require no further FSDO or ASI approval;

17. The operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and who are necessary for the on

- going operation of the entity being inspected;

18. If the UAS loses communications or l oses its GPS signal, the UA S must return to a pre

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

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual;

20. Each operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first;

21. The operator must contain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but no less than 48 hours prior to the operation;

22. All a ircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as possi ble;

23. The operator must develop procedures to document and maintain a record of the UAS maintenance, alterations, status of replacement/overhaul component parts, and the

t otal time in service of the UAS ;

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24. Each UAS operated under this exemption will comply with all manufacturing safety bulletins;

25. The operator will develop UAS technician qualification criteria. And the criteria will be in the operator’s manual ; 26. The pre

- flight inspections section of the operator’s manual will include the requirement
that the pre

- flight inspection will account for all discrepancies, i.e. inoperable components, items, or equipment;

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the FCC or other appropriate government oversight

agency requirements;

28. At least three days before a scheduled inspection the operator of the UAS affected by this exemption will submit a written plan of activity to the local FSDO with jurisdiction over the area of the proposed inspect ion. The 3

- day notification may be waived with the
concurrence of the FSDO. The plan of activities will include the following:

a. Dates and times for all flights
b. Name and phone number of the operator for the s UAS s inspection conducted under this grant of exemption

c. Name and phone number of the person responsible for the on

- site operation of
the UAS
d. Make, model, and serial or N

- number of UAS to be used

e. Name and certificate number of UAS PIC s involved in the inspection process
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the inspection; the list of those who gave permission shall be made available to the inspector upon request

g. Signature of exemption

- holder or representative
h. The description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which the inspection will be conducted and
the altitudes essent ial to accomplish the operation

i. The documents required under 14 CFR §§91.9 and 91.203 must be available to the PIC at the ground control station of the s UAS s any time the aircraft is operating. These documents must be made available to the Administrator or any law en forcement official upon request.

29. The UA S must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to ultra

- light vehicles, parachute activities, parasailing activities, hand gliding, etc.);

30. UAS operations may not be cond ucted during night, as defined in 14 CFR § 1.1 All operations must be conducted under visual meteorological conditions (VMC). Flights
under special visual flight rules (SVFR) are not authorized;

31. The UAS cannot be operated by the PIC from any moving device or vehicle;

32. The UA S may not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC;

33. The UA S may not be operated in class B, C, or D airspace without written appr oval from
the FAA. The UA S may not operate within 5 nautical miles of the geographic center of a

non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with the airport’s management is obtained, and the o peration is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be m ade ava ilable to the administrator

upon reques t;

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34. Any I) Incident, 2) Accident, or 3) Flight operation that tra nsgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA must be reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS

- 80) within 24
hour. Accidents must be reported to the National Transportation Safety Board (NTSB) per instruction contained on the NTSB 'w eb site: www.nts b.gov. Further fl ight operations may not be conducted until the incident, accident, or transgression is

r ev iewed by the A FS

- 80 and authorized to resume operations is provided;

35. The UAS, PIC and operator will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

L IST OF ATTACHMENTS

1. Birds Eye Aerial Drones, LLC Flight Operations and Procedures Manual

2. Manufacturers Pilot Training Guide

3. Team Black Sheep, Discovery Pro N848SP, Operating Manual

4. Tarot, T15, N849SP, Operating Manual

5. DJI Inspire, Operating Manual

6. Ground Station Operating Manual

7. DJI NAZA User Manual

8. Battery Log Form

9. Maintenance Log Form

10. Pre Flight /Post Flight Checklist

11. Flight Notification/Release Form

12. Flight Safety

T welve attachments listed are referenced in the request for exemption and contain trade secret and commercial proprietary information that Birds Eye Aerial Drones, LLC has no t and will not share with others except under appropriate confidentiality agreements. The Birds Eye Aerial Drones, LLC FOPM attachment contains operating conditions and procedures that have been developed exclusively by Birds Eye Aerial Drones, LLC, and th at are not available to the public. Birds Eye Aerial Drones, LLC is requesting that these attachments be treated as proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from release under the Freedom of Informa tion Act. See 5 U.S.C. 552
et seq.

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REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED:

14 CFR Part 21 14 CFR 61.113 (a) & (b)

14 CFR 61.133 (a)

1 4 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)

14 C.F.R. 91.109 (a)

14 C.F. R. 91.119

14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

14 C.F.R. 21: Certification Procedures for Products and Parts This section outlines requirements for the issue of design and production approvals, airworthiness certificates, and other air worthiness approvals. Birds Eye Aerial Drones, LLC is aware that if an exemption is granted as per Section 333, an airworthiness certificate would be issued and a request for exemption from Part 21 is unnecessary. However, as outlined in the List of Limitations and Conditions in this application, as well as all of the Attachments to this application, including the FOPM

, Birds Eye Aerial Drones, LLC seeks to uphold the same level or exceeded level of safety
as described in Part 21 of 14 C.F.R.

14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in
Command. Commercial Pilot Privileges and Limitations. Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the 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 operating the aircraft to have a pri vate pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlle d and restricted, and all flights are planned and coordinated in
advance as set forth in the FOPM . The level of safety provided by the requirements
included in the FOPM exceeds that provided by a single individual holding a commercial pilot’s certificate o perating a conventional aircraft. 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 of the sUAS as requested wit h a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy co ndition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining

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airworthiness. Given the size of the aircraft and the requirements contained in the

FOPM for maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 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, ma rkings, and placards, or any
combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to car ry such an item on the aircraft.

14 C.F.R. § 91.109 (a) : FLIGHT INSTRUCTION Section 91.109 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
function ing dual controls. UAs and remotely piloted aircraft, by their design do not have fully functional dual controls. 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 for flight instruction in experimental aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 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. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein , except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without thei r pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the s UAS s as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Becaus e of the advance notice to the property owner and participants in the activity, all affected individuals will be aware of the planned flight operations as set forth in the FOPM.

14 C.F.R. § 91.121 Altimeter Settings This regulation requires each person op erating 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 the sUAS may not have a barometric altimeter, but ins tead a GPS altitude read out, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant to the

FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

T his regulation prohibits 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 first point of intended landing, and, assuming normal cruis ing speed

– (1) During the day, to fly 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 40 minutes of powered flight. To meet the 30 minute reserve requir ement in 14 CFR § 91.151, sUAS s flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight i n daylight or night VFR conditions is reasonable.

L imiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.

A n equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Regis tration 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 opera te a civil aircraft unless the airworthiness certificate 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 s UAS f ully loaded weighs no more than 55 lbs. and is operated 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 safety will be achieved by keep ing these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the

sUAS.

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections
The se 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 a s 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 apply 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 FOPM. An equivalent level of safety will
be achi eved 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 s UAS can land immediately and will be operating from no higher than
400 f eet AGL. As provided in the FOPM , the operator will ensure that the s UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with

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the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

THE APPLICABLE LEGAL STANDA RD UNDER SECTION 333

Birds Eye Aerial Drones, LLC submits that grant of this exemption application advances the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs
into the NAS if it can be a ccomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS, the public, or pose a threat to national security in light of the following:

● The UAS’s size, weight, speed, and operational capability; ● Operation of the UAS in close proximity to airports and populated areas; and ● Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a) (1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333 (c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, from the requirement that all civil aircraft must have current airworthiness
certificate and those r egulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the a dditional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with use of UASs for aerial

vi deography/photography, the reduction or elimination of unregulated operators, and the safe

i ntegration of UASs. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

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CONCLUSION

As set forth herein, Birds Eye Aerial Drones, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernizati on and Reform Act of 2012 from the requirements of 14 CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 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), which will permi t safe operation of the s UAS s commercially, without an airworthiness certificate, for the limited purpose of conducting aerial imagery over small, defined operational areas of the
United States.

Approval of the exemption allowing commercial operations of Birds Eye Aerial Drones,

LLC s UASs will increase safety by permitting an operator to conduct a service safely b y adher i ng

to the prescribed guidelines. The e xemption will also encourage the education of sUAS operators and the adoption of FAA guidelines and approval for commercial sUAS operations as pertains to Birds Eye Aerial Drones, LLC employees and contractors

. It will allow Birds Eye Aerial Drones, LLC to provide a service that benefits the public and local businesses

. It benefits the public through a higher level of safety of sUAS operations and through a smooth integration of
sUASs into the NAS

. Having a pilot owned business bridges the gap between the advancement
of s UAS technology and the current practices and operatio ns in the NAS and with the FAA. This

assists the FAA with its mission of promoting aviation while preserving safety of aviators, the public, and property. The s UASs operated by Birds Eye Aerial Drones, LLC satisfies the criteria set
forth in § 333 of the Reform Ac t

– size, weight, speed, operating capabilities, operation within visual line of sight, and national security

– and showing an equivalent level of safety to manned aircraft flights through appropriate pilot certification and safety focused standards of operati on, providing more than adequate justification for the grant of the requested exemptions allowing commercial operations.

By granting this Petition, the FAA Administrator will be fulf illing the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Birds Eye Aerial Drones, LLC to safely, efficiently, and economically operate the s UASs commercially within the NAS.

Respectfully,

Scott J. Painter

CEO Birds Eye Aerial Drones, LLC

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