I'...,_._.,/' BillyF. Johnson, Jr., Owner 7812 Thor DriveAnnandale, VA 22003 (703) 560-5383 Aerialwerks@gmail.comDear Siror Madam, 1 September 2015 SUBJECT: Petition for Exemption under FAA Section 333. 1. Pursuant to Section 333ofthe FAA Modernization and Reform Actof 2012 (the "Reform Act") and14CFR Part 11, BillyF. Johnson, Jr., hereby applies foran exemption from the listed Federal Aviation Regulations to allow commercial operation of designated UASs. 2. Purpose. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services inthe following areas: a. Aerial Photography and Videography for the real estate, construction, and utilities industries b. Agricultural Surveying and Application c. UAS Operator Training d. Product Demonstrations e. Research and Development 3. UAS Models and Operational Characteristics: a. TBS Discovery Professional Quadcopters (2). These are electrically powered and are equipped witha GPS Stabilized Flight controller, GPS beacon, HD Video camera, 2-axis gyro-stabilized gimbal, and Bluetooth transponder. They weigh 2.18kg and havea maximum airspeed of 45kph. The maximum flight time using a 4,500mAh lithium lon battery is21 minutes. b. Hoverthings Flip FPV Professional Quadcopters (2). These are electrically powered and are equipped withaGPS Stabilized Flight controller, GPS beacon, HD Video camera, and Bluetooth transponder. They weigh 1.45kg and havea maximum airspeed of 75kph. The maximum flight time using a 4,500mAh lithium lon battery is24 minutes. c. Blackout 330 Professional Quadcopter. Itis electrically powered and equipped withaGPS Stabilized Flight controller, GPS beacon, HD Video camera, 2-axis gyro-stabilized gimbal, and Bluetooth transponder. It weighs 1.27kg and hasa maximum airspeed of 90kph. The maximum flight time using a 2,500mAh lithium lon battery is14 minutes. d. Lumenier QAV-400 Quadcopter. Itis electrically powered and equipped withaGPS Stabilized Flight controller, GPS beacon, HD Video camera, and Bluetooth transponder. It weighs 1.43kg and hasa maximum airspeed of 80kph. The maximum flight time using a 3,300mAh lithium lon battery is17

minutes. 4. Safety:a. Registration and Identification. UASs willbe marked with the owner's name, address, phone number, and email address, aswellasany additional FAA registration information required to positively identify the aircraft and owner."' b. Pre-Flight Inspection. Prior to each flight the PIC will inspect the UASto ensure the craftis ready for flight. This inspection will include a physical inspection ofthe UAS, aswellas checking flight controls, verifying aGPS location lock, and ensuring the batteries contain an adequate charge to complete the flight and land with at leasta20% reserve of power. The pre-flight inspection also includes reviewing

the flight location to ensure itisnota restricted fly zone or area of concern, aswellas establishing a 20-meter safety perimeter around the takeoff and landing point. All participants, to include neighbors are informed ofthe flight prior to take off.A complete on-site safety checklist is attached. c. Maintenance. UASs will comply with maintenance and inspection requirements ofthe manufacturer. Each UAS will have an individual maintenance log indicating any maintenance, modification, alteration, rebuild or component change. In addition, the logs will indicate test flight results

following each maintenance activity. d. Radio Frequencies. i. Control Frequency. The UAS control frequency forall UASs is 433MHz. The EzUHF 0.50 watt transmitter is manufactured by Immersion RCandis certified FCC-compliant. ii. Video Frequencies. The UAS live feed video systems can operate on either oftwo frequencies, depending onthe local environment, interference and frequency congestion. The 0.70 watt 2.4GHz transmitter is manufactured by Immersion RC. The 0.50 watt 5.8GHz transmitter isalso manufactured by Immersion RC. Both are certified FCC-compliant. e. Operator Qualifications. All flight operations willbe conducted byat least two individuals (PIC and observer) who will maintain verbal communication with each other atall times during the flight, and who will remain stationary onthe ground during the flight operations: i.APilotIn Command (PIC) who possess the following credentials: 1.An Airman Certificate issued under 14CFR 61. (Billy F. Johnson holds a Private Pilot Single Engine License with an Instrument Rating in both Land and Sea Planes, and has

over 700 hours of Pilotin Command time). 2.A Valid State Driver's License. 3.At least 200 cycles and25 hours of flight experience inthe UAS rotorcraft. 4.At least5 hours of flight experience and3 takeoffs and landings in make and model being flown inthe prior 90 days. ii.A Visual Observer. f. Flight Operations. All flight operations will comply with the following: i. Conducted in VMC conditions. ii. Maintain VLOS atall times. iii. Pre-flight inspections and safety risk assessments willbe conducted prior to each flight. (See attached checklist). iv. Altitudes will remain below 400 feet AGL. v. Ground speeds will not exceed 50 knots. vi. Not take place within 5 nautical miles ofan airport. vii. Notbe made near or over people without their prior permission. viii. Not exceed 80% ofthe battery capacity or30 minutes, whichever occurs first. ix.All applicable local Flight Standards District Office (FSDO) requirements. 5. Exemptions Requested.**~** a. 14 CFR, Part 21, Subpart H: Certification Procedures for products and parts, Airworthiness Certificates. Justification: The speed, weight, size, and limited operating area associated with the UASs described in paragraph 3 meet the conditions of FMRA Section 333 and donot require airworthiness certificates. An equivalent level of safety willbe achieved by permanently attaching the owner's name, address, phone number, and email to each ofthe UASs. Given the size and limited operating area associated with the UAStobe utilized bythe petitioner, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level of safety under Part 11and Section 333ofthe Reform Act. Lastly, there isno credible threat to national security posed bythe UAS, due

toits size, speed of operation, location of operation, lackof explosive materials, and inability to carry

a substantial external load. b. 14 CFR, Part 91.9(c), 45.23 (b), and 45.27(a). Justification: Even though the UASs will not have airworthiness certificates, an exemption may be needed. Given the sizeofthe UAS, 2" letters for the "Experimental" signage isnot possible. An equivalent level of safety willbe achieved by permanently attaching the owner's name, address, phone number, and email to each ofthe UASs. The marking "Experimental" willbe applied tothe fuselage in compliance with 45.29(f). The FAA has issued the following exemptions tothe aircraft marking requirements of§ 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A. c. 14 CFR, Part 27: Airworthiness Standards: Normal Category Rotorcraft. Justification: Petitioner requests an exemption from Part 27's airworthiness standards for the same reasons identified inthe exemption request from 14CFR Part 21, Subpart H. d. 14 CFR, Part 91.9(b)(2): Civil Aircraft Flight Manual inthe Aircraft. Justification: The UAS, given its size and configuration hasno ability or place to carry sucha flight manual onthe aircraft, not only because there isno pilot on board, but because there isno room or capacity to carry such an item on the aircraft. The equivalent level of safety willbe maintained by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate access toit.The FAA has

issued the following exemptions tothis regulation: Exemption Nos. 8607,8737, 8738, 9299, 9299A, 9565,9565B, 10167,10167A, 10602,32827,and 10700. e. 14 CFR, Part 91.103(b)(2): Preflight Action. Justification: The UAVs will notbe operating from airports or runways. An equivalent level of safety willbefor the PICto complete a pre-flight checklist and risk assessment prior to each takeoff. The checklist is attached tothis application. f. 14 CFR, Part 91.109: Flight Instruction. Justification: The UASs described in paragraph 3donot have dual controls and donot carry pilots or passengers. Asan equivalent level of safety, control ofthe UASisbya ground-based PIC using a radio control link. Inthe event the radio link between the UAS and control radio islost, the UAS will hover in place for three seconds and attempt to re-establish the control link. Ifthe UASis unable to re-establish the control link, the UAS will autonomously climb toa safe altitude (SOm/165 feet AGL) to clear obstructions, return tothe launch point (RTL), and land automatically. The FAA has approved exemptions for flight training without fully functional dual controls fora number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. g. 14 CFR, Part 91.119: Minimum Safe Altitudes. Justification: Asthis exemption isfor UASs resembling a helicopter and the exemption requests authority to operate uptoan altitude of400 feet AGL, an exemption may be needed. However, given the size, weight, speed, and limited range of the UASs imposed bythe VLOS requirement, the equivalent level of safety willbe achieved. No flight willbe performed without the permission ofthe property owner or participants inthe activity. All affected individuals willbe aware ofthe planned flight operations prior to beginning the flight. The exception to exceed the 400 feet AGL may occur when the UASisused to survey or photograph a.'t structure that exceeds 400 feet AGL. Inthat instance, the UAS will notbe operated more than 100 feet above the highest point ofthe structure. h. 14 CFR, Part 91.121: Altimeter Settings. Justification: The UASs detailed in paragraph 3are not equipped with barometric altimeters and donot have the payload capacity to carry them. An equivalent level of safety is provided via the Global Positioning System (GPS) equipment and telemetry data link, which downlinks from the UAStothe ground control station for real-time, active monitoring ofthe flight bythe PIC. The visual flight data, aswellasthe on-screen telemetry datais recorded atthe ground station. The altitude information, combined with VLOS ator below 400 feet AGL, ensures compliance with this section. i. 14 CFR, Part 91.151: Fuel requirements inVFR conditions. Justification: The UASs described in paragraph are powered by Lithium lon batteries that provide a maximum flight time of20 minutes. Safety will notbe affected by operating only under visual meteorological conditions (VMC) under visual flight rules (VFR), with adequate battery power toflyatotal duration of16 minutes (or 80% battery consumption- whichever occurs first), leaving a20% reserve of four minutes to land the UAS

safely. This request for exemption falls within the scope of prior exemptions. See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with§ 91.151 (a)); see also Exemptions 2689F, 5745, 10673, and 10808. j. 14 CFR, Part 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration. Justification: The UAS, given itssize and configuration hasno ability or place to carry suchaflight manual onthe aircraft, not only because there isno pilot on board, but because there isno room or capacity to carry such an item onthe aircraft. The equivalent level of safety willbe maintained by keeping the documents atthe ground control point where the pilot flying the UAS will have immediate access to it.The FAA has issued numerous exemptions tothis regulation. A representative sample of other exceptions which includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. k. 14 CFR, Part 91.405: Maintenance Required. Justification: These requirements apply only to aircraft that have an Airworthiness Certificate. The speed, weight, size, and limited operating area associated with the UASs described above meets the conditions of FMRA Section 333 and donot require an airworthiness certificate. An equivalent level of safety willbe achieved by performing maintenance in accordance with the owner's manuals and maintaining a maintenance log book for each UAS. I. 14 CFR, Part 91.407: Operation after maintenance, preventative maintenance, rebuilding, or altercation. Justification: This requirement applies only to aircraft that have an Airworthiness Certificate. The speed, weight, size, and limited operating area associated with the UASs described above meets the conditions of FMRA Section 333 anddonot require an airworthiness certificate. An equivalent level of safety willbe achieved bythe PIC performing pre-flight and post-flight inspections. In addition, following any maintenance, rebuilding or alteration, the PIC will perform a flight testing ina controlled, non-commercial environment to ensure the UASisfully operational and safe. The owner will document the results ofthe test flights inthe UAS maintenance log book. m. 14 CFR, Part 91.409: Inspections. Justification: This requirement applies only to aircraft that have an Airworthiness Certificate. The speed, weight, size, and limited operating area associated with the UASs described above meets the conditions of FMRA Section 333 anddonot require an airworthiness certificate. An equivalent level of safety willbe achieved by performing pre-flight inspections prior to

operating the UAS. AUAS pre-flight checklist and risk assessment are attached. n. 14 CFR, Part 91.417: Maintenance Records. Justification: This requirement applies only to aircraft that have an Airworthiness Certificate. The speed, weight, size, and limited operating area associated with the UASs described above meets the conditions of FMRA Section 333 and donot require anairworthiness certificate. An equivalent level of safety willbe achieved by maintaining an individual maintenance log book on each UAS. 6. Thank you for your consideration. Ifyou need more information or have questions, please contact me. Sincerely,BillyF. Johnson, Jr.**~**iot On-Site Safety Checklist Pre-flight• Review flight area using Google Earth. • Review area for FAA restricted fly zones (using FAA iPad App "B4UFiy", when available). • Review area for cellular towers or other transmitters. • Review safety checklist with sponsor. • Visit each neighbor to announce that aerial photography willbe occurring. • Establish 20 meter perimeter around Launch zone. • Post "DANGER: Flight Operations" sign. Flight Set-up • Advise everyone of Launch zone perimeter. • Inspect UAV for damage. • Turn on remote control and make sure voltage isat least 6.5 volts. • Verify the correct UAVis selected under "Model". • Ensure all switches areinfull forward (GPS Stabilized) position. • Clear the launch zone and pluginthe UAV battery. • Make sure the ESC arming tones are correct. • Wait for the GPSto lock (Solid green LEOs slowly flashing). • Verify GPS lock (minimum 5 satellites) on Ground Station screen. • Verify UAV battery voltage (minimum 16.5v) on Ground Station screen. • Activate flight recorder (Red LED flashing). • Check that launch siteis clear for liftoff. • Announce "Launching UAV". • Arm motors and climb to10 meters. • Verify controls are working and displays are correct. • Proceed with flight. Flight• Monitor both GPS Lock (#satellites) and battery level every minute. • Watch for any changes tothe "Launch" area. • Watch for any irregular craft behavior and land immediately if necessary. • Return the craft tothe landing area within 20% of battery life(or 14.8 volts indicated). Post-Flight• Announce that the craftis returning to land. • Check that landing areais clear. • Slowly bring the UAVinfor landing. • Disarm motors. • Disconnect UAV battery. • Turn off remote control. • Check UAV for damage or missing parts. • Store all equipment.Safety Checklist Aerialwerks, LLC operates under the following guidelines and follows all FAA regulations. Please initial each item and signatthe bottom. Please be aware ofthe following limitations:

• We cannot fly within 1mile ofFAA Restricted Zones. • We cannot fly within 5 miles ofan operating airport. • We cannot fly more than 400 feet above the launch elevation. • We must maintain a20 meter perimeter around the takeoff point. • We will land the UAV immediately if problems occur. •Privacy Concerns: •If neighbors have concerns we cannot fly until they are resolved. •If photography isa concern we cannot fly untilitis resolved. Safety:• You agree to assist in controlling the number of people inthe Launch zone. • You agree to assist inthe safety ofthe flight. Safety Checklist Signatures Printed Name & Signature Bill JohnsonOwner, Aerialwerks