April 20 , 2015

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

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Reg ulations from 14 CF R Part 21; 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Refo rm Act) and 14 C.F.R. Part 11, Daniel C. Augspurger , operator of Unmanned Aircraft Systems (“UASs ”) equipped to offer on

- demand comm ercial UAS operations for aerial data

collection that involves aerial surveying, construction site inspection and monitoring, and real estate and marketing photography/videography, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to all ow commercial operation of its micro UAS , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333

.

As described in this document and the attached Flight Manual, the requested exempti on
would permit the operation of small, unmanned and relatively inexpensiv e UAS under controlled

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations using conv entional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of

T ransportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the

Reform Act.

The name and address of the applicant is:

Dan iel C. Augspurger 1552 Progress St North Liberty, IA

Ph: 319.333.9414

Email: daugs4@gmail.com

FAA Certificate # 2840369 ATP

Daniel C

. Augspurger is a professional pilot that makes his living flying corporate jets . He holds an Airline Transport Pilot’s license with a first

- class medical along with a Certified Flight Instructor Airplane (CFI) and Instrument Instructor (CFII) rating and has accumulated over 3500 hours of flight time. He has been flying professionally for 10 years and still makes occasional

use of his CFI and CFII lice nses in single engine aircraft.

Attachments to this exemption request include the Yuneec Q500 user manual and the Flight Manual which includes conditions and limitations of operations, checklists, and the maintenance log.REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED:

14 CFR Part 2 1 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

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)

ST ATUTORY AUTHORITY FOR EXEMPTIONS

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national airspace system (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 crea te a hazard to users of the NAS or 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 • Op eration of the UAS within visual line of sight of the operator.

Daniel C. Augspurger’s microUAS are rotorcraft, weighing 4 or fewer lbs. including payload. They operate, under normal conditio ns at a speed of no more than 15 knots and have

the capability t o hover, and move in the vertical and horizontal plane simultaneously. They will operate only in li ne of sight and will operate only within a sterile area. Such o perations will

insure that the UAS will “not create a hazard to users of the national airspace system or the public.” Reform Act Section 333 (b).

Given the small size of the UASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) i n which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs

and the restrict ed areas in which the relevant UASs will operate, approval of the application
present s no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including

e nhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest.SPECIFIC AREA S THIS EXEMPTION WILL BENEFIT THE PUBLIC INTER E ST:

- Rea l Estate and Marketing Purposes (photography/videography).

1. Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive.

2. Only large companies or high

- end realtors or luxury homeowners can afford to absorb the expense of manned aircraft videography. This d eprives small budget real estate companies and the average homeowner of a very valuable marketing tool.

3. Manned aircraft pose a threat to the public through potential catastrophic loss or crash of a large aircraft. Loaded with explosive hydrocarbon based fuel, a much larger risk is imposed on the general public than a sma l l, less than 4 lbs , UA that is powered by a small battery.

4. Daniel C. Augspurger will eliminate the above problems by offering the use of a
small, ultra

- light weight UA that is powered by a no emission battery and is very inexpensive to operate and own as compared to a large manned aircraft. This serves the public interest by making such operat i ons safer and much more affordable.

- Construction Site Inspection and Monitoring

o The use of UA on a construction site can significantly reduce the risk to workers of falls while inspecting, surveying, or monitoring site progress. UAS can inspect, photograph, and collect data on hard to get to areas that otherwise would require worker inspection. Fal ls are a leading source of workplace fatality and injury on

construction sites

. R educing falls through UAS use for site imaging could save

workers lives.

UAS DESCRIPTION

Daniel C. Augspur ger intends to use and operate the Yuneec Q500 UAS multirotor aircraft. All operations will be predominately flown under 200 feet AGL. Aircraft are pre

- programmed to not fly within 5 miles of an airport and will have an altitude limit of 400ft AGL.

These aircraft have fail safe features that include, but are not lim ited to geo fencing and los t link return to home/transmitter capability

. This has been tested by the company as well as personally by turning off the transmitter simulating loss of GPS. The aircraft hovers in place,

heads toward the transmitter’s last loca tion and will land if GPS signal is not recovered. In addition there are low voltage warning lights on the aircraft, and a low voltage warning vibration and alert on the personal ground station (controller /transmitter ).

YUNEEC Q500 SPECIFICATIONS:

o 

### Max F light Time 25 Minutes

o 

### Dimension 16.5x16.5x9.5in (420x420x240mm)

o 

### Diagonal Length Without Rotor Blades 22.2in (565mm)

o 

### Propeller/Main Rotor Diameter 13.0in (330mm)

o 

### Takeoff Weight 60oz (1700g)o 

### Battery 5400mAh 3S 11.1V LiPo

o 

### Transmitter 10

- channel 2.4GHz with 5.8GHz video downlink

o 

### 3 Flight Modes Smart, Angle and Home Modes

o 

### Max Flying Height Default 122m (400ft) Above Ground Level

o 

### Max Rotation Rate 65°/s

o 

### Max Roll Angle 35°

o 

### Radio Control Frequency Band 2.4GHz

o 

### Operating Temperature Range

- 5 °C to 80 °C

o 

### Max Cli mb Rate 3m/s

o 

### Max Desc ent Rate : 2m/s

FCC information: “This product contains a radio transmitter with wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in t he 2.400GHz to 2.4835GHz frequency range.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Daniel C. Augspurger proposes that the exemption requeste d herein apply to sUAS that have the characteristics and that operate with the limitations listed herein. These limitations provide

for at least an equivalent or higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conducted with conventional aircraft.

These Operation L imitations /Specifications and conditions to which Daniel C. Augspurger agrees to be bound when conducting commercial operations under an FAA issued exemption at

a minimum include:



### 1. Operations are limited to the Yuneec Q500, when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). Daniel C. Augspurger 

### will use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft

manufacturer.

4. The UA will be operated at an altitude of no more than 400 feet ab ove ground level
(AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than
corrective lenses, as specified on the PIC’s FAA

- issu ed airman medical certificate.

### 6. All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The

VO and PIC will be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the dura tion of the flight. The PIC

will ensure that the VO can perform the duties required of the VO.

7. All flight crew members, including PIC and VO, will have an understanding of, and comply with, Title 14 Co de of Federal Regulations, and/or Agency directives and regulations, applicable to the airspace where the UAS will operate. Specifically all flight crew members will receive training on the rules and responsibilities described in 14 CFR

Part 91 Sections 91 .111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including standard ATC phraseology and

communication.

7. All operating documents will be accessible during UA operations and made available to

the Adm inistrator upon request. Daniel C. Augspurger 

### will track revisions of the operating procedures /limitations and present updated and revised documents to the Administrator or any law enforcement official upon request.

8. A ny UA that has undergone maintena nce or alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations. Functional test flights will only be condu cted by a PIC with a VO and will remain at least 500 feet from other people. The funct ional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for ma intaining and inspecting the UA to ensure that it is i n a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the

UA is in a condition for safe flight . The pre

- flight inspection will account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UA is fo und to be in a condition for safe flight.

11. Daniel C. Augspurger 

### will follow the UA manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft

components. All maintenance will be recorded in a maintenance log and kept with the operating documents at all times.

12. Each UA will comply with all manufacturer safety bulletins.

### 13. A PIC will hold either an airline transport, commercial, private, recreational, or sport

pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the flight review requiremen ts specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. Daniel C. Augspurger 

### will not permit any PIC to operate unless the PIC demonstrates the

a bility to safely operate the UA in a manner con sistent w ith these specifications

, including evasive and emergency maneuvers and maintaining appropriate distances from

persons, ve ssels, vehicles and structures. Prior to commercial operations, the PIC must have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), a minimum of 25 hours of total time as a UAS pilot and at least 5 hours logged as a UAS PIC operating the make and model of the UAS to be utilized for operations under this requested exemption, and three takeoffs and landings in th e preceding 90 days. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a

manner consistent w ith how the UA will be operated will be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered n onparticipants, and the PIC

will operate the UA with appr opriate distance from nonparticipants in accordance with 14
CFR § 91.119.

15. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights will

not be conducted under special visual flight rules (S VF R).

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted

with an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issu ed to Daniel C. Augspurger



### . The letter of

agreemen t with the airport management will be made available to the Administrator or any law enforcement official upon request.

17. A n Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA)

will be obtained prior to conducting any operation planning to occupy any airspace

between 200ft AGL and 400ft AGL under this requested grant of exemption. Additionally, Daniel C. Augspurger will request a Notice to Airmen (NOTAM) not more than 72 hours, but not less than 48 hours prior to the op eration.

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or l oses its GPS signal, the UA will r eturn to the

transmitter/

predetermined location within the planned operating area.

### 19. The PIC will abort the flight in the event of unpred icted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and fo recast weather conditions) there is enough available power for the UA S to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

22. All aircraft operated by Daniel C. Augspurger 

### will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification ( N Number) markings in accordance with 14 CFR p art 45, Subpart C. Markings will be as large as practicable.

23. Do cuments used by Daniel C. Augspurger 

### to ensure the safe operation and flight of the UA

and any documents required under 14 CFR §§ 91.9 an d 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. Thes e
documents will be made available to the Administrator or any law enforcement official

upon request.

24. The UA will remain clear and give way to all manned aviation operations and activities at

all times.

25. The UAS will not be operated by the PIC f rom any moving device or vehicle.

26. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipatin g persons
from the UA S and/or debris in the ev ent of an accident. Daniel C. Augspurger 

### will

ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500

fee t of the UA S , flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and,

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present

an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered no nparticipati ng persons under these specifications

27. A ll operations will be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller o r authorized representative will be obtained for each flight to be conducted.

### 28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as de fined by the applicable COA will be reported

t o the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board

.

REGULATIONS FOR WHICH EXEMPTIONS ARE REQUESTED

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

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 private 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 UAS is remotely controlled with no living thing

on bo ard. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety provided by the requ irements included in the Operation Specifications exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associ ated with the operation of the

UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operat ions of the UAS as requested with 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 condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requi rements contained in the Operating Specifications for

maintenance and the 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, markings, and placards, or any combination thereof. The UAS, 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 b ecause there is no room or capacity to carry such

an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight

manual /specifications at the ground control po int where the pilot flying the UAS will have

immediate access t o it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827,

and 10700.14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery req uirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction : Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being use d for flight instruction unless that aircraft has fully functioning dual

controls. UASs 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 communic ates 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. See Exemption Nos.5778K & 9862A. The e quivalent level of safety will be

achieved provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the 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. A s this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth
herein, T he 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 their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the aerial activity, all

affected i ndividuals will be aware of the planned flight operations. Compared to flight operations

with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the

lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL other industries. In addition,

the low

- altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conventiona l aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings This regulation 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.” T he sUAS will not have a barometric altimeter.

H owever, the use of triangulation with a minimum of six satellites in use by its onboard GPS will be able to give accurate Height Above Ground Level (HAGL) measurements. Daniel C Augspurger believes that an equivalent level of safety can be achieved by the operator as the sUAS uses HAGL from its initialization/takeoff point.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Cond itions Section 91.151 (a) 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 flyto the first point of intended landing, and, assuming normal cruising speed

– (1) During the day,

to fly after that for at least 30 minutes.

The FAA has previously issued exemptions for fuel requirements in VFR conditions for sUAS aircraft. See exemptions 2689F, 5745, 10673, 10808 and 11138.

Daniel C. Augsp urger believes an equivalent or higher level of safety can be obtained by terminating the flight prior to the following:

- Yuneec Typhoon Q500

— 25 minutes or 25% of battery life, whichever occurs first. The UAS has a second level of safety that is achieved through the use of an aircraft battery monitoring system. The aircraft system will aler t the operator of low battery voltage through a vibration in

the control station.

Daniel C. Augspurger will not operate at night in accordance with 14 CFR 1.1.

An equi valent level of safety will be achieved because these sUAS are limited in size, scope of operations, and shall only fly above approved privately owned and operated property at or below 400 feet HAGL, and does not bear the same risks associated with large m anned aircraft and therefore should be exempt from this section’s requirements.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness 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 UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no a bility or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate acc ess to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A,
9797, 9797A, 9816A, and 10700.

14 C.F.R. §9 1.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, exce pt as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section s and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applica nt. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and opera te only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 fee t AGL, with the vast majority of operations under 200 feet. As provided in this document and the Flight Manual , the operator

will ensure that the UAS is in working order prior to initiating flight, perform requiredmaintenance, and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and bes t suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

SUMMARY

********* Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined tha t publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91 .409 (a) (2); and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (less than 4lbs).

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subjects being filmed and in extreme proximity to people and structures and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the operational location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried

on boa rd. The sUAS is carried to the operation site and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., cond ucted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. The grant of this exemption request will provide improved safety in day VFR operations. Satisfaction of the criteria provided in Sectio n 333 of the Reform Act of 2012

- - size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the request ed exemptions allowing commercial operation of the applicant’s UAS.

Sincerely,

Daniel C. Augspurger

319.333.9414 daugs4@gmail.com