Page! 1 of! 23

Thomas M. Dater Precision Unmanned Aerial Systems LLC

10606 W 35 th Ct S Wichita, KS 67215 ( 620 ) 245

- 7008 Tom.dater@Precision

- UAS.com

www.Precision

- UAS.com

August 18, 2015

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

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft Systems Operations Allowed by Section 333 of the FAA Moder nization and Reform Act of 2012 Through the Exemption Process Identified Under 14 C.F.R. Section

11.81

Dear Sir/Madam,

Pursuant to Section 333 of PL 112

- 95 commonly known as the “FAA Modernization and
Reform Act of 2012” or “The Reform Act”, Precision Un manned Aerial Systems LLC
(d/b/a Precision UAS), hereby applies for authorization to conduct commercial
unmanned aerial systems (UAS) operati ons for the agriculture, oil and gas and energy
production, mining, structural mapping and inspection, landscape m odeling,
infrastructure management, surveying, aerial mapping and photography and videography,
emergency and disaster response, forestry, humanitarian aid, conservation, and wildlife
preservation industries , within the United States National Airspace Syste m (NAS); within
Class G and occasionally E airspace, along with additional restrictions identified herein.

This request is separate from any and all Certificate of Authorization/Waiver (COA)
requests submitted by public agencies identifying, Precision UA S (or its affiliates), as
their UAS contract service provider authorized under Sec. 334 of the “Reform Act.”
This request does not pertain to any and all activities conducted under the guidance of the
Department of Defense while operating over restricted military airspace during military
exercises in which, Precision UAS (or its affiliates), has been identified as a participant in
providing UAS operations and support.Page! 2 of! 23

Contained within is detailed information on why the approval of the request is in the
“...public’s interest...” and how the approval will “...provide a level of safety at least
equal to that provided by the rule...” Precision UAS seeks exemption from. In a ddition

, t hrough the vast operational experience in the UAS field seen nowhere within the civilian
community, Precision UAS will indicate how the approval will facilitate their ability to

work with the FAA to “...safely accelerate the integration of civil unmanned aircraft
systems into the national airspace system...” as directed by Congress.

Thank you for your time and consideration in this matter and please feel free to contact
me with additional information or requests you may desire.

Thomas M. Date r Precision UAS

Applicant Contact Information: Precision Unmanned Aerial Systems LLC

Attn: Thomas M. Dater

10606 W 35 th Ct S Wichita, KS 67215

620

- 245

- 7008 tom.dater@precision

- uas.comPage! 3 of! 23

1. Company Background

2. Training & Operations

3. Regulations

– Exceptions Requested

3.1. 14 C.F.R Part 21 Subpart H

– Airworthiness Certificates

3.2. 14 C.F.R § 45.23 (b)

– Aircraft Marking and Identification Requirements

3.3. 14 C.F.R § 91.7 (a)

– Civil Air craft Airworthiness

3.4. 14 C.F.R § 91.103

– Preflight Action

3.5. 14 C.F.R § 91.119

– Minimum Safe Altitudes

3.6. 14 C.F.R § 91.121

– Altimeter Settings

3.7. 14 C.F.R § 91.151 (a)

– Fuel Requirements for Flight in VFR Conditions

3.8. 14 C.F.R § 91.405 (a)(1), § 91.409 (a)(2), and § 91.417 (a) & (b)

–
Maintenance Inspections

4. Public Interest

5. Privacy Concerns

6. FAA Collaboration

7. Summary ~ Federal Registry

Appendix!A

Additional Documents

• Flight Planning Document

• Precision UAS Operations ManualPage! 4 of! 23

1. Company Background

Precision Unmanned Aerial Systems LLC was conceptualized in 2014 when the founder noted that nearly every industry could benefit from the use of Unmanned Aerial Systems (UAS). Precision Unmanned Aerial Systems LLC was founded in 2015 as a realization of this concept

. Drawing from over a decade of experience and 10,000+ hours of operational experience in the UAS industry and 1,000+ hours commanding missions aboard a manned Intelligence Surveillance and R econnaissance (ISR) aircraft. Conducting missions in congested ai rspace during operational missions sets both state side and forward deployed in support of Operations Enduring Freedom, Iraqi Freedom, New Dawn, and Resolute Support along with other real world contingencies and exercises;

Precision UAS has a resume of UAS operational experience that is unparalleled.

In addition, the founder of Precision UAS has spend the last four years as a Systems Engineer supporting ISR operations in Afghanistan by performing sensor, communication, and aircraft maintenance providing in valuable experience. The experience and diversity that Precision UAS brings to the United States civilian UAS operations industry is second to none and is therefore “... in the public’s best interest...” for the Secretary to approve this exemption request.

2. Training & Operations

Section 333 of “The Reform Act” states: “...the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system...In making the determination under subsection (a), the Secretary shall determine, at a

minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populate d areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security...”

Precision UAS will adhere to the specifications and requirements set within their

oper ations manual(s), Operations manual(s) of aircraft listed in Appendix A and FAA guidelines to include but not limited too; 8900.1 CHG 351 Volume 16 , 8900.227 and more specifically the requirements set within the Section 333 exemption approval #

11062

, rece ntly obtained by Astraeus Aerial.

Precision UAS seeks authorization to utilize the systems listed in Appendix A to conduct operation s for agriculture, oil and gas and energy production, mining, structural mapping and inspection, landscape modeling, infras tructure management, surveying, aerial mapping and photography and videography

, emergency and disaster response

, forestry, humanitarian aid, conservation, and wildlife preservation industries. We fully anticipate conducting operations for two or more industries concurrently over the same area and therefore believe, flight operations and the safety of, require our full attention regardless of whether the aircraft is imaging a piece of land or col lecting informational data at thePage! 5 of! 23

same location. The fixed wing and multi

- rotor aircraft selected by Precision UAS all meet the requirements for determination by being less than 55 pounds (all systems weighing under 15 pounds), flying at speeds under 60 kn ots, and flying for less than two hours (battery limited). Operating within visual line of sight (VLOS) and remaining below 400 ft AGL are standard operating procedures for Precision UAS and will remain so until further advances in safety of flight are int roduced to the market and regulated by the FAA. As described below, all operations will be confined to those areas no closer than one statue mile of any airfield and the proper authorities will be notified with any operations within five statue miles. Furt hermore, when it comes to national security

concerns, Precision UASs’ founder has spent 10 + years defending our country as a military member ensuring national security is of the utmost priority in any activities they partake in.

Operator Training: All PIC and Supplemental Pilots (SP) will abide by the requirements

set forth in 8900.1 CHG 351 Volume 16. All initial aircraft flight o perations and maintenance training will be conducted by a certified flight/maintenance instructor. Once an operator is certifie d they will they will enter into Precision UAS operations qualificat ion training which includes FAA authorized ground school training and a third

class medical examination. Upon successful completion, the operator will earn their Supplemental Pilot(SP)/Vis ual Observer (VO) rating. SP/VO will be required to conduct

25 operational hours to be considered for PIC qualification testing in addition to holding at a minimum, private pilot license. The operator will then be required to complete a

written test and “c heck ride” in which upon successful completion, the operator will receive their PIC rating.

NOTE: Ground School Training will be conducted by FAA certified instructors

Initial certification training requirements include:

Pre

- Flight Training: • Unpacking and assembly • Power requirements, set

- up and connectivity • System end

- to

- end set

- up and test / inspections • Preflight, run

- up and system checks

Flight Operations Training: • Proper Handling • Motor Operations • GCS Flight Programming and Test

• Launch • Basic Flight (climb, cruise, descent, landing) • Maneuvering • Airspace and Landing Zone Operations • Flight Reprogramming • Flight Monitoring

• In

- Flight Emergency ProceduresPage! 6 of! 23

Post Flight:

• Shut Down Procedures • Data Retrieval and Storage

• End

- to

- En d Test and Maintenance Logs • Disassembly • Packing, Storage and Transportation

SP/VO qualification training requirements instructed by Precision UAS include: • Understanding FAA Rules / Regulations • Collection Requirements • Operational Planning • Fligh t Planning • Area of Operations ~ Hazard Mitigation • Daily Flight and Inspection Log Completion • Proper Authority Notification Process

• Crew Resource Management (CRM)

PIC qualification testing requirements instructed by Precision UAS include:

• Written Exam consisting of 60 questions with a pass rate of 70% following the

guidelines set forth by the FAA Airman Knowledge Testing requirements • “Check Ride” and Oral exam consisting of:

o Airport Operations

o Maintenance Inspections

o Flight Plan Development

o Area of Operations Hazard Mitigation

o Weather Hazard Mitigation

o Emergency Procedures

o Pre

- Flight Operations

o Flight Operations

o Post

- Flight Operations

Operations Execution: Given the fact commercial UAS operations are restricted due to the lack of regulations, a logical and safe solution is to utilize the safety guidance provided for hobbyist use of sUAS and other model aircraft as identified by Advisory

Circular 91

- 57 and Section 336 of the “Reform Act”. Precision UAS operations will be conducted in a methodical, efficient , and most importantly safe manner adhering to strict guidelines that address safety concerns with proximity to airports and populated areas in the interim of official guidance from the FAA as the rules and regulations are being further developed

.

The following list provides specific rules and guidelines all Precision UAS operations will adhere to too ensure at least an equivalent or higher level of safety when compared to manned aircraft performing the same functio ns as outlined within 14 C.F.R.

1) All flight crews will:Page! 7 of! 23

• Be comprised of a minimum of two certified operators; one serving as PIC

and the others as VO

• Consist of one certified air vehicle maintenance technician to conduct pre and post flight inspections NOTE: PIC/SP/VO may also fill the role of the maintenance technician

• Attend pre and post flight mission briefs which will consist of weather information, flight information to include operational area and mission objectives, hazard mitigation actions and most importantly emergency and abort procedures; also included will be any NOTAMs or improvements to standard operating procedures through further refinements in operations

• Sign applicable documentation verifying their attendance to mandatory briefs as well as produce daily pre and post flight inspections and flight logs

• Communicate over two way radio, cell phone and/or other communication devices identified to increase operational efficiencies

2) All flight operations will:

• At no time fly within one statute mile of any operational airf ield

• Provide prior notification to airfield operator and airfield air traffic control tower (when applicable) when operating within five statute miles of any active airfield; no later than 24 hours prior to air operations

• Provide prior written notification to FSDO(s) and local/county sheriff and fire departments in the event assistance is required to include: flight plans, type and capabilities of air vehicle(s) operated and operator’s contact information; no later than 72 hours prior to operations

• Be condu cted using sUAS as defined by the FAA weighing less than 55 lbs; all operations authorized through this exemption request will be done

with the aircraft listed in Appendix A (future aircraft will be presented to FAA for approval prior to operational use)

• B e conducted in Class G and occasionally E airspace and shall not exceed 400 ft above ground level (AGL)

• Be conducted within visual line of sight (VLOS) of the qualified PIC and

VO

• Give right

- of

- way to and avoid flying near manned aircraft at all times

• Be c onducted in rural environments and outside of city limits

• Be conducted with prior written consent from land owner

• Ensure air vehicles do not encroach within 250 ft of any improved road, person, vehicle or structure that is not associated with operations

• Ab ort/Cancel in the event of detrimental weather to include wind speeds exceeding the allowable limits as defined within operations manual

3) Emergency Procedures: All emergency procedures will be conducted within the guidelines outlined within the aircraf ts operations manual to include but not limited to the following:Page! 8 of! 23

• In the event the air vehicle losses GPS signal, automated return to home will immediately commence based on the pre

- programmed parameters identified and uploaded prior to initiation of flig ht. The flight plan is built in such a way that hazards are identified prior to launch will allow the PIC to successfully recover

control of the air vehicle.

• In the event the PIC losses signal with the air vehicle, automated return

- to

- home

and loiter will commence until signal is regained. The flight plan is built in such a way that all hazards are identified prior to launch and an automated landing in the event signal is not regained will be conducted in a safe and responsible manner

.

• In the event hazardous weather unexpectedly approaches and may affect operations, the PIC will immediately abort the operation and conduct landing

activities

• In the event an in

- flight emergency occurs, (i.e. air vehicle maintenance issues), the PIC will immediately abo rt flight and conduct landing activities; air vehicle inspection will immediately be achieved and the air vehicle will not return to service without proper authorization from certified maintenance technicians

• In a “significant” event (i.e. air vehicle cras hes and outside assistance is needed), PIC will conduct notification procedures to include county sheriff and fire departments, airfield operator/tower if applicable and any other authority required to mitigate situation

o A “significant” event report will b e generated by the PIC, verified by the VO and maintenance technician and immediately provided to the Director of Operations

NOTE: Notification will be made to the FAA to assist in future prevention techniques

By following these strict, mostly self impos ed guidelines; Precision UAS, will achieve a safety level greater than that directed by the rules in which they seek exemption, especially true when you compare the same operating procedures against a manned aircraft. SUAS are inherently safer in all facet s due to the fact that they are much smaller, fly at much lower speeds, there are no human operators on board and there is zero fuel to be concerned with in the event of a crash. As processes are further refined, the operations will only add to an already higher level of safety compared to manned flight operations in which serves the public’s best interest in the FAA’s endeavor to integrate UAS into the

NAS.

3. Regulation

– Exemption Requested

Pursuant to 14 C.F.R. § 11.81(e), Precision UAS seeks exemptio n from the below mentioned regulations and provides reason as to why the exemption should be approved based on the level of safety at least equal to that of which the rules require.

3.1 • 14 C.F.R. Part 21 Subpart H

– Airworthiness Certificates

! Establishes: The procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1)Page! 9 of! 23

Given the small size of the UAS, the limited operating areas and meticulous procedures defined within the training and operatio ns section (re

- iterated below), an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the “Reform Act” with consideration “of the size, weight, speed, operational capability, and proxim ity to airports and populated areas of the particular

UAS.”

• No operations within one statute mile; Prior notice given to ATC tower/Airport Operator w/in five statute miles

• O perations only directly over working area within city limits; Rural areas only with a minimum distance of 250 ft from persons, structures, roads and

vehicles

3.2

• 14 C.F.R. § 45.23(b)

– Aircraft Marking and Identification Requirements

! 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

Precision UAS will ensure compliance with § 45.29(f) to meet the intent of the regulation by placing the word “experimental” on the fuselage of the air vehicle(s).

NOTE: The FAA has set precedence to this regulation within like given parameters and

an exemption should be approved on this ba sis along with previous exemptions: Nos. 10700, 10167 and 10167A. Also, see most recent exemption approvals for Blue

- Chip

UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision for further justification of approval.

3.3 • 14 C.F.R. 91.7(a)

– Civil Aircraft Airworthiness
! States: No person may operate a civil aircraft unless it is in an airworthy

condition.

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports

and populated areas. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate in the areas and under the conditions contemplated by

Precision UAS will be at least as safe, or safer, than a conventional aircraft (fixed wing orPage! 10 of! 23

rotorcraft) operating with an airworthiness certificate without the con ditions proposed in this request.

The sUAS listed in Appendix A weigh less th an 55 lbs. fully loaded, carry neither a p ilot nor passenger, and operate under tight control restrictions . Unlike other civil aircraft,

o perations under this exemption will be tightly controlled and monitored by the PIC and

VO . Operations will be conducted in compliance with the FAA and with local public safety requi rements to provide security for the area of operation. These safety enhancements provide an expanded degree of saf ety over conventional aircraft operations. Lastly, application of these same criteria demonstrates that there is no

credible threat to nation al security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materi als (fuel and/or flammable liquids) and

i nability to carry a s ubstantial exter nal load.

Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent lev el of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon considerat ion of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restri cted environment and un der the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions an d conditions proposed.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.7(a): Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. Also, see most recent exemption approvals for Blue

- Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision for further justification of approval.

3.4

• 14 C.F.R. 91.103

– Preflight Action
! States: Each pilot in command shall, before beginning a flight, become familiar

with all available information concerning that flight. This information must

include

- (paragraphs a, b, 1 and 2)

A pre

- flight mission brief must be attended by all crewmembers . This “PMB” will contain weather and all flight information including emergency and abort procedur es. A signature will be required by all crew members indicating they have received the PMB and have read any NOTAMs or other procedural updates which may have impact to standard operatin g procedures. In addition, the P IC will verify air vehicle is ready fo r flight by coordinating with the maintenance technician during pre

- flight inspection.Page! 11 of! 23

The exemption requested for this section is specifically addressed toward the requirements that do not apply to sUAS operations such as runways and air traffic control integration.

NOTE: As previously stated, air traffic control and airport operator will be notified prior to any operations being executed within five statute miles

NOTE: The FAA has recently set precedence to this regulation within like given

parameters and an exemption should be approved on this basis. See exemption approvals for Blue

- Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision.

3.5 • 14 C.F.R. 91.119 (c)

– Minimum Safe Altitudes
! States: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In th ose cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

All Precision UAS operations will be conducted at 400 ft AGL or below in uncontrolled Class G and occasionally E airspace. As sUAS are inherentl y safer than traditional aircraft due to their small size, lightweight , battery operated versus fuel and no human

on

- board; Precision UAS will not operate within 250 ft to any improved roads, vehicles persons or structures (other than those being inspected as part of the flight operation). In addition, objects/hazards will be identified and geo

- located prior to flight to be utilized within the flight planning stages to ensure this objective is met.

3.6 • 14 C.F.R. 91.151(a)

– Fuel Requirements for Flight in VFR Conditions
! States: No person may begin 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 cruising speed

— (1) During the day, to fly after that for at least 30 minutes;

This regulation is written based on the capabilities of a traditional aircraft which have flight times of several hours or greater; therefore, with the majority of sUAS which have flight times of only an hour or less, this regulation would effectively deny the ability of the air vehicle to operate.

Using a Cessna 182 as an example, approximately 8% remaining fuel is required to meet the 30 minute flight time directed by this regulation. To meet t he intent, Precision UAS, will operate its air vehicles to no less than 10% remaining battery power to ensure safe landing and retrieval of the air vehicle. This 10% buffer is greater than the Cessna 182Page! 12 of! 23

and the ability to quickly and safely land sUAS in n on

- traditional environments ensures at least an equal level of safety.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.151(a): Exemption Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption approvals for Blue

- Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision for further justification of approval.

3.7 • 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)

– Maintenance Inspecti ons ! 91.405(a) States: Each owner or operator of an aircraft

— (a) 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 repai red as prescribed in part 43 of this chapter

! 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person au thorized under § 43.7 of this chapter

! 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it

has had

— (2) An inspection for the issuance of an airw orthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual

i nspections and is entered as an ‘‘annual’’ inspection in t he required maintenance

records.

! 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following

records fo r the periods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i

– vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1

– 3)

Pre/Post and routine inspections (not to exceed 50 flight hours) and maintenance will be conducted in accordance with the manufacturer’s guidance. In addition, to meet the intent of these regulations, Precision UAS, will maintain daily logs of pre and post flight inspections and have maintenance performed by certified technicians and/or the manufacturer themselves. In the event maintenance is required, certified technicians will verify the air vehicle is in flight readines s status prior to releasing to P IC for use in operations.

Unscheduled maintenance will be accomplished in the event of a mechanical or structural failure during flight. Upon completion of unscheduled maintenance, documentation will be provided to the Director of Operations to sign off and verify that the air vehi cle is once again ready for flight and accept the level of risk associated with returning the air vehicle to flightPage! 13 of! 23

status. At no time will there be changes made to the air vehicle that would impact the structural integrity of the airframe without the manu facturer making such changes and verifying the flight its airworthiness

.

All inspection and maintenance will be documented and maintained in

- house. These actions will meet the intent of the regulation exemption is being requested and lead to the equivale nt level of safety.

NOTE: The FAA has recently set precedence to this regulation within like given parameters and an exemption should be approved on this basis. See exemption approvals for Blue

- Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions , RC Pro Productions, Snaproll Media and Pictorvision.

4. Public Interest

The public’s best interest is achieved by the safe integration of UAS into the NAS. With the ongoing exemption process, the FAA has to identify those exemption requests with the public’s best interest in mind and select the companies who will be able to ac hieve this in a safe and responsible manner. Two of the main problems the public has with UAS are the fear of what they will be used for and whether or not they are safe to fly within the same airspace as commercial airliners. Precision UAS is more than wi lling to help with public education and that starts with conducting operations within strict operating environments and then providing the results to the public to start to sway opinion in a positive light.

With the experience this team has built from UAS operations, manned flight operations and training and aircraft maintenance; the FAA will provide a great service to the American public by approving Precision UAS s ’ exemption request herein. Precision UAS will provide any additional information requested and will diligently work with the FAA to make this approval a reality as it is in the best interest and safety of the public as directed by Congress.

5. Privacy Concerns

As previously stated, one of the main concerns the public has with the integration o f UAS into the NAS is privacy and spying; especially as of recent with the “disclosure” of the NSA’s communication programs. The media has also placed a negative light on UAS when it comes to privacy; showing only how the military has used this technology to conduct combat operations through the use of the visual and infrared sensors they carry.

Fortunately with this matter, Precision UAS is well versed in the privacy and oversight concerns which are addressed by federal government regulations: Executive O rder 12333, DoD Directive 5240.1

- R and AFI 14

- 104. Although the regulations do not apply to private commercial entities, our knowledge and experience in working within these regulations will assist and ensure any and all privacy concerns will be minimal an d immediately mitigated.Page! 14 of! 23

In addition, the most efficient and successful avenue to combat these concerns is to educate the public in how UAS technology will be used to exponentially improve all of our lives as Americans and place emphasize on how we should embrace the technology instead of fearing it. In these regards, Precision UAS will look at actions we can take to move forward with this endeavor and assist the FAA and all UAS employment companies as a whole to better public perception and create a cohes ive environment we all can operate in safely.

6. FAA Collaboration

Precision UAS is committed to the safe integration of UAS into the NAS and will provide any and all information on its flight operations to the FAA to assist in the rules making process. As stated in the operations section, post flight logs will be required to be completed to produce monthly flight summaries which will include both positive and negative reporting placing emphasize on any issues which may arise during any segment of the ope rations. Precision UAS offers the monthly summaries to the FAA as input and flight data to ensure accurate information is utilized along with offering our expertise and knowledge in the rule making process.

7. Summary ~ Federal Register

Pursuant to Section 333 of PL 112

- 95 commonly known as the “FAA Modernization and Reform Act of 2012” or “The Reform Act”, Precision Unmanned Aerial Systems LLC (d/b/a Precision UAS), hereby applies for authorization to conduct commercial unmanned

aerial s ystems (UAS) operations for agriculture, oil and gas and energy production, mining, structural mapping and inspection, landscape modeling, infrastructure management, surveying, aerial mapping and photography and videography, emergency and disaster response , forestry, humanitarian aid, conservation, and wildlife preservation

industries , within the United States National Airspace System (NAS); within Class G and occasionally E airspace.

Rules in which Precision UAS seeks exemption:

• 14 C.F.R. Part 21 Subpart H

• 14 C.F.R. § 45.23(b)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.103

• 14 C.F.R. § 91.119

• 14 C.F.R. § 91.151(a)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(2)

• 14 C.F.R. § 91.417(a) & (b)

Throughout this exemption request, Precision UAS has shown how their expertise and knowledge with UAS technology will ensure the public’s best interest is at hand and assist the FAA with their charge to: “...safely accelerate the integration of civilPage! 15 of! 23

unmanned aircraft systems into the national airspace system ...” as directed by Congress. They have also shown how the approval of this request will meet and exceed “...at least an equivalent level of safety...” for the regulations they seek exemption.

At each level through process refinement, Precision UAS will capture and document the best practices to develop proven tactics, techniques and procedures and provide that information to the FAA to incorporate into the UAS integration process.

When it comes to the public and what is in their best interest you will be hard pressed to find a team more qualified for an exemption under Section 333 than Precision UAS. It will be a great service to the country and in the “public’s best interest” to include this team in the UAS integration endeavor in which an equivalent level of safety will be ensured by operations being conducted by the undisputed experts they are.Page! 16 of! 23



### Appendix A

Specific sUAS T ypes, M ake, and M odel

Fixed Wing

#1 SenseFly eBee

See Attached:

eBee User Manual V16

#2 Precision Hawk Lancaster

See Attached: 2015 Lancaster tech specs

Additional Information : The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11172Page! 17 of! 23

#3 Quest Q

- 200

See Attached: Manufacturer did not provide documentation at time of request.

#4 HoneyComb Ag Drone

Additional Information : The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11223Page! 18 of! 23

#5 C Astral Bramor

See Attached: Manufacturer did not provide documentation at time of request.

#6 Swift Radioplanes Lynx

See Attached: Lynx User Manual 2

- 5Page! 19 of! 23

#7 AgEagle

See Attached: Manufacturer did not provide documentation at time of request.

#8 Skywalker X

- 8

Additional Information: The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11172Page! 20 of! 23

#9 Marcus UAV INC Zephyr 2

See Attached: Manufacturer did not provide documentation at time of request.Page! 21 of! 23

Multirotor

#1 SenseFly eXom

Additional Information: The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11263A

#2 DJI Inspire

See Attachments: DJI Inspire User Manual V1.4 DJI Inspire Maintenance Manual V1.0 DJI Inspire Safety GuidelinesPage! 22 of! 23

#3 DJI Phantom 3 Professional

See Attached:

DJI Phantom 3 Professional User Manual V1.4 DJI Phantom 3 Safety Guidelines

#4 DJI S1000+

See Attached:

DJI S1000+ User ManualPage! 23 of! 23

#5 Altus X8

Additional Information : The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11172

#6 3DR X 8+ /M

See Attached:

X8 Checklist VB X8 Operations Manual VC

Additional Information: The FAA has set precedent by previously issuing exemptions for this aircraft: Exemption

No. 11172