U.S. Department of Transportation Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 20590 Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R. Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Botlink is applying for an exemption from the Federal Aviation Regulations (FARs) to allow commercial operation of its Unmanned Aircraft Systems (UAS). Specifically, Botlink seeks an exemption to perform research, development, aerial photography, aerial videography, and aerial data collection. This request is substantially similar to other data collection petitions previously approved, and should be considered under the expedited summary grant procedures. Approval of the exemption for the petitioner will allow commercial operations of the 3D Robotics Quadrotor, 3D Robotics Solo, DJI Phantom 2, DJI Phantom 3, AgEagle, and Aerobotic ER-1. in class G airspace nationwide unless otherwise prescribed by an Air Traffic Organization (ATO) issued COA. Operation of the UAs under the strict conditions proposed below will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. Operations using these UAs are far safer than conventional operations conducted with helicopters and fixed-wing aircraft that weight thousands of pounds, carry highly flammable fuel, and operate in close proximity to the ground, trees, infrastructure, and people. Congress directed the FAA to consider seven factors in deciding whether to approve Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight. In this case, each factor supports the exemption request. In particular, these UA are small and will operate at slow speeds and close to the ground. It will be able to more safely and efficiently conduct the operations that would otherwise involve risk of injury or death. The substantial increase of safety and decrease of risk to human life and to property weighs heavily in favor of granting the exemption. See the table of contents below for the full exemption request. If we can provide any additional information to assist your in the processing of our exemption request, please contact us at (701) 353-9482 or via email at shawn@botlink.io. Thank you,

Shawn Muehler COO, Botlink

## APPENDICE LIST Exhibit 1: Botlink Flight Operations Manual Exhibit 2: Botlink Software User Manual Exhibit 3: Aerobotic ER-1 Operating Manual Exhibit 1 has been submitted confidentially to the FAA and is not available to the public.I. Publishable Summary Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules: 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 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)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially small unmanned aircraft system s. Approval of the exemption requested by the petitioner will allow commercial operation of the 3D Robotics Quadrotor, 3D Robotics Solo, DJI Phantom 2, DJI Phantom 3, AgEagle, and Aerobotic ER-1 for the purpose of research, development, aerial photography, aerial videography, and aerial data collection in Class G airspace nationwide, unless otherwise prescribed by an ATO-issued COA. The requested exemption should be granted because operation of small UA weighing 55 pounds or less, conducted in the strict conditions outlined below, will provide an equivalent level of safety while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed-wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight – each support the request. In particular, the aircraft are small, and will operate at slow speeds, and close to the ground. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of granting the exemption. II. Petitioner’s Contact Information Shawn Muehler Botlink COO 118 N Broadway, Unit 504 Fargo, ND 58102 Phone: (701) 353-9482 Email: shawn@botlink.io III. Background on Botlink Botlink is a team of professional and military pilots, engineers, and communicators on a mission to build the world’s most capable UAV platform, providing our users the capability to safely control their drone, remain compliant & process data over the cellular network. No matter the task or location, Botlink enables everyone to do more with your drone.Shawn Muehler, Botlink COO and an officer in the U.S. Air Force, has been serving our country and flying both manned and unmanned aircraft for over a decade. His love of flying model aircraft and Cessnas in his youth transpired into flying Learjets and military drones as a profession, and Shawn's extensive aviation and technology background is the inspiration for Botlink. IV. Proposed Operations
A. The UAs The requested exemption will permit petitioner to operate the 3D Robotics Quadrotor, 3D Robotics Solo, DJI Phantom 2, DJI Phantom 3, AgEagle, and the Aerobotic ER-1. The 3D Robotics Quadrotor, 3D Robotics Solo, DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and AgEagle have all been previously approved for commercial operation under Section 333 Exemptions. Operating manuals and support documentation have not been included with this exemption request but are available upon request. The Aerobotic ER-1 has not been previously approved for operation under a Section 333 Exemption. This UA falls within the the seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight. It has the following specifications:Exhibit 2 contains the Botlink Software User Manual. This Manual contains information about the Botlink XRD Flight Controller and Botlink Control and Safety Software. Exhibit 3 contains the Aerobotic ER-1 Operating Manual. This Manual contains full specifications of the Aerobotic ER-1 airframe. Please refer to these document for full specifications of the UA. B. The Crew The crew will consist of a pilot-in-command (PIC) and a visual observer (VO). The PIC and VO will have been trained in operation of UAs and received up-to-date information on the UA to be operated pursuant to this grant. The PIC will have, at minimum, a sport pilot license and a U.S. driver’s license. Please refer to Exhibit 1, Section 2: Crew Qualifications and Currency for further information regarding crew members. C. Flight Conditions The UA will be used for research, development, aerial photography, aerial videography, and aerial data collection in Class G airspace (unless otherwise prescribed by an ATO-issued COA) under 400 feet above ground level (“AGL”) and under controlled conditions over restricted property. Petitioner will only operate its UA in visual meteorological conditions (VMC). The UA will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from a

Airframe Aerobotic ER-1 Control System Botlink XRD Flight Controller and Botlink Control and Safety Software. Datalinks Main: 4G LTE cellular communications Backup: 915 MHz handheld RC transmitter Maximum Speed 61 knots Size Wingspan = 12.25 feet Length = 5.7 feet Maximum Weight 20 pounds Maximum Altitude 5000 feet for guaranteed cellular connection Ground Control Station Botlink Control and Safety Software. Software is installed on either a mobile device or laptop. Backup Spektrum RC transmitter for emergency use. Motor Hacker A50 14L Series Motor Payloads GoPro Hero 3, Sony QX 1, Sentera Dual, other payloads as required that fall within weight and balance limits Return Home Procedures Has programmable failsafe procedures in the event the aircraft loses control link or GPS. Aircraft can be programmed to return to the home location and perform an autonomous landing.cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present. D. Flight Operations The purpose of the UA flights for which exemption is requested will be for research, development, aerial photography, aerial videography, and aerial data collection. Every UA flight will use at minimum a two person flight crew: a PIC and a VO. Petitioner will fly the UA no higher than 400 feet above ground level (AGL). Please refer to the following exhibits for more information regarding flight operations:
Exhibit 1: Section 3: Airworthiness Section 4: Airspace Section 5: Standard Operating Procedures V. Aircraft and Equivalent Level of Safety The petitioner proposes that the exemption apply to the UAs that have the characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the current regulatory structure. Section V below identifies the limitations and conditions to which the petitioner agrees to be bound when conducting commercial operations under a grant of this petition. Appendix A contains a matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it provides equivalent level of safety and (iii) one or more recent Section 333 exemption grants in which the FAA recognized this equivalent level of safety. Approval of the commercial operations outlined in this petition presents non national security issue The PIC will possess, at a minimum, a sport pilot’s certificate, so he or she will have been subject to security screenings by the Department of Homeland Security. VI. Proposed Conditions of the Exemption
1. The UAs, including battery and payload, will weigh no more than 55 pounds.
2. UA operations under this exemption will be limited to conducting operations for the purpose of research, development, aerial photography, aerial videography, and aerial data collection in Class G airspace nationwide, unless otherwise prescribed by an ATO issued COA.
3. Flights will be operated within line of sight of a PIC and VO.
4. Flights will be operated at an altitude of no more than 400’ AGL, as indicated by the procedures specified in the operating documents.
5. The UA will not be flown at an indicated airspeed of over 87 knots.
6. Minimum flight crew for each operation will consist of a PIC and VO.7. The PIC will have a minimum of a sport pilot license and either a U.S. driver’s license or a third class medical certificate.
8. The petitioner will not permit any PIC to operate the UA unless the PIC meets its qualification criteria and demonstrates the ability to safely operate the UA in a manner consistent with how the UA will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from person, vessels, vehicles, and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR 61.51(b). A record of the PIC training will be documented and made available upon request by the Administrator. Training operations will only be conducted during dedicated training sessions. During training and proficiency flights, all persons not essential for flight operations will be considered nonparticipants and the PIC will operate the UA with appropriate distance from them in accordance with 14 CFR 91.119.
9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles, and will not be permitted to operate the camera or other instruments.
10. The PIC will be designated before the flight and may transfer his or her designation to other qualified PIC. The PIC will ensure that the VO can perform the functions prescribed in these conditions and operating documents.
11. A pre-flight briefing will be conducted in regards to the planned UA operations prior to each day’s activities. All personnel who are performing duties in connection with the flight activity will be present for the briefing.
12. Prior to each flight, the PIC will inspect the UA and GCS to ensure it is in a condition for safe flight. The preflight inspection will account for all potential discrepancies. If the inspection reveals a condition that affects the safe operation of the UA, the aircraft will be prohibited from operating until the required maintenance is performed. All maintenance and alterations will be properly documented in the aircraft records.
13. Petitioner will conduct a functional check flight on any UA that has undergone maintenance or alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical component. The PIC who conducts the functional check flight will make an entry in the aircraft records.
14. The petitioner will follow the UA manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
15. The UA will be operated within visual line of sight of the PIC and VO at all times.
16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power for the UA 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.17. The UA will have the capability to abort a flight in case of unexpected obstacles or emergencies.
18. The UA will be programmed so that if it loses communications or loses its GPS signal, it will return to a pre-determined location within the planned operating area and land or be recovered in accordance with the operating documents.
19. The operating documents required under 14 CFR 91.9 and 91.203 will be maintained and available to the PIC at the GCS any time the UA is operating. The documents will be made available to the Administrator or any law enforcement official upon request. If a discrepancy exists between the conditions and limitations in the exemption grant and the procedures outlined in the operating documents the grant conditions and limitation will take precedence and will be followed. Otherwise, the petitioner will follow the procedures outlined in its operating documents. If it updates or revises its operating documents, it will present updated and revised documents to the Administrator upon request.
20. Petitioner will obtain permission from the landowner or authorized agent of the landowner over which flights will be conducted.
21. UA operations will not be conducted at night, as defined in 14 CFR 1.1. All operations will be conducted under VMC conditions. Flights will not be conducted under special visual flight rules.
22. The petitioner will obtain an ATO issued Certificate of Authorization (COA) prior to conducting any operations under the grant of exemption. Petitioner will request a NOTAM not more than 72 hours in advance, but not less than 24 hours prior to an operation.
23. The UA will not be operated within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management has been obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. Any letter of agreement with the airport management will be made available to the Administrator upon request.
24. 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.
25. All operations will be conducted in Class G airspace or as otherwise prescribed in an ATO issue COA.
26. All aircraft operated in accordance with this exemption 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 part 45, Subpart C. Markings will be as large as practicable.
27. The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times.
28. The UA will not be operated by the PIC from any moving device or vehicle.29. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless one of the following three conditions are met:

• Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident.

• The aircraft is operated near vessels, vehicles, or structures where the owner/controller

of such vessels, vehicles, or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present undue hazard.

• Operations nearer to the PIC, VO, operator trainees, or essential persons do not present

an undue hazard to those persons per part 91.119(a).
30. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB website: www.ntsb.gov. VII. Privacy There is little concern that the proposed flights will cause invasions of privacy. All flights will occur over either (a) public rights of way where there is no expectation of privacy; (b) over private property with permission of the landowner/authorized agent and consent of participating individuals. In the event data is inadvertently collected of a person or property not in the flight area, it will be immediately deleted or cropped from the images. Petitioner will also follow the Association for Unmanned Vehicle Systems International (AUVSI) Code of Conduct for all operations. VIII. Public Interest and Safety The planned UA use will increase safety for a variety of aerial operations traditionally done with manned aircraft. Generally, manned operations are more time consuming and more expensive that the same operations done with a UA. Use of manned aircraft poses enhanced risk to the pilot and onboard crew, who would be several hundred feet in the air. The enhanced safety and reduced environmental impact achieved using a UA and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UA operation enabled by this exemption is in the public interest. Botlink has prepared a risk management tool that it will utilize during operations. This tool can be found in Exhibit 1. Satisfaction of the criteria provided in Section 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 requested exemption allowing commercial operation of the petitioner’s UA pursuant to Botlink’s rules of operation.IX. Regulations from Which Exemption is Requested 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a); 14 C.F.R. 61.315(a) : Pilot privileges and limitations These regulations limit sport, recreational, and private pilots from performing commercial operations. Botlink can achieve an equivalent level of safety because the UAs will not carry pilots or passengers. Further, having an FAA pilot license does not correlate to the skills required to operate a UA safely. Further, the risks of Botlink UA operations are far less than the risk levels associated with manned commercial operations. Thus, allowing Botlink to operate its UA with a sport pilot license or greater will achieve an equivalent or better level of safety. 14 C.F.R. 91.7(a): Civil aircraft airworthiness This regulation prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is no applicable. 14 C.F.R. 91.119 (c) : Minimum safe altitudes This regulation prescribes safe altitudes for the operation of civil aircraft. Botlink will operate below 400’ AGL unless otherwise allowed by an ATO-issued COA. Botlink operations will also occur in secured areas with the permission of the land owner. Given the size, weight, maneuverability, and speed of Botlink UAs, this will provide an equivalent level of safety to manned operations.

14 C.F.R. 91.121 : Altimeter settings This regulation requires each person operating the 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 UA may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. 91.151(a) : Fuel requirements for flight in VFR conditions Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of UAS during daylight hours in visual flight rule conditions to continue until 5 minutes of battery power remain or the manufacturers recommendation, whichever is greater. Botlink seeks the requested relief because without an exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of any aerial acquisition of data that Botlink proposes to conduct pursuant to this exemption request.The technical specifications of the proposed UA, their Operating Manuals, and Botlink’s proposed operating limitations, ensure that Botlink will safely operate the selected aircraft during daylight hours in VFR conditions until the battery reserve limits proposed above remain. 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b) : Maintenance Inspections These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Botlink. Maintenance will be accomplished pursuant to the User Guide or Operating Manual. An equivalent level of safety will be achieved because these UAs are 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 UA can land immediately and will be operating from no higher than 400’ AGL. The PIC will ensure that the UA is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.X. Summary In summary, Botlink seeks an exemption from 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 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)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially small unmanned aircraft system s. Granting Botlink’s request for exemption will reduce current risk levels and therefore enhance safety. Currently, manned commercial operations rely primarily on the use of larger aircraft running on combustible fuel. Botlink’s UAs do not contain combustible fuel, are smaller, lighter, and more maneuverable than conventional manned aircraft. Furthermore, Botlink’s UAs operate at lower altitudes. There are no pilots or passengers on Botlink’s UA which decreases the likelihood of death or serious injury. Botlink’s aircraft all weigh less than 55 pounds and travel slower than 87 knots in secure areas which will provide an equivalent level of safety that is currently achieved under current FARs. Accordingly, Botlink respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by Botlink pursuant to the FAA’s Reform Act of 2012. Thank you for your time and consideration.

Respectfully Submitted,

Shawn Muehler COO, Botlink