# Chesapeake Aerial Solutions, LLC

April 29 , 2015

U.S. Department of Transportati on

Docket Management System

1200 New Jersey Ave.

, SE

Washington, DC 20590

Re:

Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam

This petition is being submitted on our own behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Chesapeake Aerial Solutions, LLC

( CAS ) which has filed an Article o f Organization as a n aerial photography and mapping company for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the

Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Chesapeake Aerial Solutions , LLC to

pu rsue its commercial interests in providing services to consumers
interested in aerial data capture using a small advanced sUAS in the following areas:

 Agriculture (monitoring of CREP Easement strips)
 Surveying
 Marsh Surveys (vegetation in

- fill and wildlif e habitat)
 Real Estate Photography
 Landscape Architecture

Chesapeake Aerial Solutions, LLC states that all sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge and that on ly people who have consented or otherwise have agreed to be in the area where filming will take place will be filmed.

### Chesapeake Aerial Solutions, LLC Pilot in Command Biographies:

Eric Wheatley

Eric is 44 years old and has been building and flying radio controlled (RC) model aircraft for 10 years. He is a current member of the Academy of Model Aeronautics (AMA), with a valid open membership card N o. 895693. He has experience with RC boats, cars, helicopter s, quadcopters, and propeller driven airplanes and jets, all powered by fuel, gas, or
electric . The majority of his flight time has been dedicated to precision aerobatic airplanes including giant scale aerobatic, 2

- meter pattern, and
.60 size antique patte rn airplanes. He has extensive building and maintenance knowledge of all RC interests that he is active in. Eric has also been a RC flight instructor to beginner pil ots at his regular flying

club.

Along with his RC skills, Eric also has a background in bas ic machinist skills, design, and research and development practices.

Bart Ferguson

Bart is 41 years old and has been building and flying radio controlled (RC) model aircraft for 16 years. He is a current member of the Academy of Model Aeronautics (AMA), w ith a valid open membership card N o. 675305

. He has experience with RC boats, cars, quadcopters, and airplanes, all powered by fuel, gas, or electric. The majority of his flight time has been dedicated to giant scale gas airplanes and .60 size antique patt ern airplanes. The vast majority of his airplanes have been built by him from kits or plans. Bart has also been an RC flight insrtuctor to beginner pilots both at his regular flying club and at nearby clubs and private flying fields in the area.

Bart was r aised in an aviation centered home, with his father having a
Commercial Pilot Certificate with a multi

- engine rating and a Flight
Instructor Certificate

. His father logged thousands of hours flight time over his career. Although Bart did not follow in his father’s footsteps of becoming a pilot, he still grew up with a love of aviation and spent many

hours as a boy in the right seat riding next to his father, or just hanging around the local airports trying to stay out of trouble, of

course.

Additionally bo th of these RC pilots have logged many hours flying together and spotting for each other over the years

, and communicate effectively with each other. Both are well versed in pre

- flight inspections, maintenance of aircraft and support systems, and planned

o perations within airspace. Both pilots are very knowledgeable about the general rules and risks of aviation and take flying and the safety of themselves and others seriously.

### Unmanned Aircraft System:

sUAS s are oftentimes seen as superior to full scale aircraft due to the
much smaller size and light weight , advanced use of GPS technology , low operating costs, and reduced noise and as such, a much smaller
environmental footprint which promotes public safety and comfort.

We are petitioning for exempt ion to enable Chesapeake Aeri al Solutions, LLC to operate a DJI Phantom 2 equipped with a t wo
- axis Walkera G

- 2D
Gimbal and Turnigy SJ4000 Camera. The standard gross take

- off weight for
this sUAV is 2.7 lbs. This sUAS has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace
inc luding a no fly zone feature. The Phantom 2 also has the failsafe
function of the Naza

- M autopilot system which means when the communication
between the Main Controller and the transmitter is disconnected , the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger Re turn to Home and will land safely.

Chesapeake Aerial Solutions, LLC will also uphold the Model Aircraft Op erating Standards as set by the Academy of Model Aeronautics National Safety Code , §A & §B , Effective January 1, 2014 :

A. GENERAL: A model aircraf t is a non

- human

- carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any additional rules specific to the flying
site.

1. Model aircraft will not be flown:

(a) In a careless or reckless manner.

(b) At a location where model aircraft activities are prohibited.

2. Model aircraft pilots will:

(a) Yield the right of way to all human

- carrying aircraft.

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540

- D.)

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an a irport without notifying the airport operator.

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement.(e) Not exceed a takeoff weight, including fuel, of 55 pounds

unl ess in compliance with the AMA Large Model Airplane
program. (AMA Document 520

- A.)

(f) Ensure the aircraft is identified with the name and
address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This does not app ly to model aircraft flown indoors.)

(g) Not operate aircraft with metal

- blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555.

(h) Not operate model aircraft while under the influence of

alcoho l or while using any drug that could adversely affect the pilot’s ability to safely control the model.

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that crea tes a hazard to persons or property.

Exceptions:

• Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight.

• Rocket motors (using solid propellant) up to a G

- series size may be used provided they remain attached to the model during flight. Model rockets may be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft.

• Officially designated AMA Air Show Teams (AST) are

authorized to use devi ces and practices as defined within the Team AMA Program Document. (AMA Document
#718.)

(j) Not operate a turbine

- powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document

#510

- A.)

3. Model aircraft will not be flown in AMA s anctioned events, air
shows or model demonstrations unless:

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event.

(b) An inexperienced pilot is assisted by an e xperienced pilot.

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply with comparable standards.

B. RADIO CONTROL (RC)1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

2. A successful radio equipment ground

- range check in accordance
with manufacturer’s recommenda tions will be completed before the first flight of a new or repaired model aircraft.

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.)

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line.

(b) At air shows or demonstrations, a straight safety line
must be established.

(c) An area away from the safety line must be maintained for
spectators.

(d) Intentional flying behind the safe ty line is prohibited.

4. RC model aircraft must use the radio

- control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly licensed by the FCC are authorized to operate equipment on Amateur Band frequenci es.

5. RC model aircraft will not knowingly operate within three (3) miles of any pre

- existing flying site without a frequency

management agreement. (AMA Documents #922 and #923.)

6. With the exception of events flown under official AMA Competition Regul ations, excluding takeoff and landing, no powered model may be flown outdoors closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline

. 7. Under no circumstances may a pilot or other person touch an

o utdoor model aircraft in flight while it is still under power, except to divert it from striking an individual.

8. RC night flying requires a lighting system providing the pilot
with a clear view of the model’s attitude and orientation at all
times. Hand

- held illumination systems are inadequate for night flying operations.

9. The pilot of an RC model aircraft shall:

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot.

(b) Fly using the assistance of a camera or First

- Person View (FPV) only in accordance with the procedures outlined in

AMA Document #550.

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in

AMA Document #560.Additionally Chesapeake Aerial Solutions, LLC will only operate its sUAS

 With in line of sight of a pilot and/or observer where both are
within clear communication and will operate at sites that are a
'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will insure that the sUA V will "not create a hazard to users of the national airspace system or the public."
 When flying sUA V within 5 miles of an airport, airport operator s will be notified and the operator will give the right of way to avoid flying in the pr oximity of full

- scale aircraft.
 Maximum flight time for each operational flight will be ~20 minutes. Flights will be terminated at 25% battery power reserve

should that occur prior to the 20 minute limit.
 The sUAS will be programmed so that it will not be operated at an
altitude of more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.
 Minimum crew for each operation will consist of the sUAS Pilot and

a Visual Observer
 The sUAS PIC’s (Pilot in Command ) will always be an experienced AMA membership holding RC pilot
 The sUA S operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, a nd gimbal).
 The sUAS will operate at speeds of no more than 50 knots, can
hover, and can simultaneously move vertically and horizontally.
 Given the small size of the sUAS and the restricted sterile environment within which they will operate, our sUAS opera tions
will adhere to the Reform Act's safety requirements

.  If a loss of precise control or mechanical failure is ever to happen, the sUAV is to be forcibly landed in the farthest and/or

safest possible location from persons or personal property so as to

preserve the safety of life. This is the same measure instituted (sometimes unwritten) at RC Flying fields to protect fellow RC pilots and spectators alike.

### S tandard flight checklist:



# CHESAPEAKE AERIAL SOLUTIONS **, LLC**

DJI PANTOM 2 V2.0

Software V 3.08

Walkera G2D Gimbal

. / Turnigy SJ4000 Action Cam.


## FLIGHT LOG/CHECKLIST: MM__DD__YY__ JOB#_____

LOCATION_______________________ FLIGHT No._____ CONDITIONS_______TEMP______ 

# □ 1. Permission Granted For Flight. 

# □ 2. Flight Battery Charged. Voltage. % ___ 

# □ 3. Transmitter Batteries Checked. No. Of Flights.___ 

# □ 4. All Props Secure. 

# □ 5. Compass Calibrated. 

# □ 6. G.P.S. Locked On All Satellites. 

# □ 7. Camera And Gimbal Secure. 

# □ 8. Gimbal Angle Set. 

# □ 9. Camera ON. 

# □ 10. Camera Record ON. 

# □ 11. Clear Line Of Sight. 

# □ 12. Wind Direction/Speed. N. NE. E. SE. S. SW. W. NW. (Circle .) 

### M.P.H.____ 

# □ 13. Take Off Time__:__ Landing Time__:__= Flight Duration: ____Min.

Address.____________________________________________

City.____________________________ State.____ Zip.______

Lat.___________ Lon.___________Elv.____Ft./Meters. (Circle one.)

Pilot. X__________________ Observer. X__________________ Property. Owner. X_________________

### Similar Exemption Requests Granted:

01/06/2015 Advanced Aviation Solutions

02/09/2015 Viafield

0 2/10/2015 Blue

- Chip UAS,

02/13/2015 Capital Aerial Video, LLC

02/18/2015 Bosh Precision Agriculture, dba Digital Harvest

03/03/2015 Singer’s Creations

04/03/2015 CineDrones, LLC

04/08/2015 Altavian, Inc

04/08/2015 Charles J. Lesowske

04/08/2015 Cherokee UAS, LLC

04/08/2015 Chustz Surveying, Inc

04/08/2015 Price Aviation Group

04/08/2015 Sydor Aerial Photography, LLC



## EXEMPTION REQUEST S AND EQUIVALENT LEVEL OF SAFETY

Chesapeake Aerial Solutions, LLC requests an exemption from the following listed Federal Aviation Regulations (FARs) as well as any additional regulations that may technically apply to the operation of the sUAS , 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.

List of FAR’s from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) an d (b)

14 C.F.R. 61.23

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. (91.401

- 91.417)

### 14 CFR Part 21, Subpart H

Airworthiness Certificates

Subpart H establishes the procedural requirements for the issuance of
airworthiness certificates as required by FAR 91.203 (a) (1).

Given the size and limited operating area associated with the aircraft to be utilized by Chesapeake Aerial Solutions, LLC , an exemptio n from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from t he requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular s UAS. In all cases, an analysis of these criteria demonstrates that the s UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without
the restrictions and c onditions proposed.



### 14 CFR 45.23 & 14 CFR 45.29

Display of Marks: General & Size of Marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft m ust display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot
station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration num ber assig ned to it by the FAA.

T

he word "EXPERIMENTAL” will be affixed to the top of the sUAV, where the Pilot in Command, Visual Observer and others in the vicinity of the aircraft while it is preparing for launch will b e able to see the designation. We will also be placing a decal noting Chesapeake Aerial Solutions, LLC ’s name and address. The command station of the aircraft is to be as openly visible as possible, so that anyone that enters near the area of sUAS operations can easily find the Pilot in Command and the
Visual Observer.

### 14 CFR 61.113 (a) and (b)

Private pilot privileges and limitations: Pilot in Command

These regulations limit private pilots to non

- commercial operations

.

Because the sUA V cannot carry a pilot or passengers and all the operational flights are carefully preplanned and adjusted to each individual locations’ possible complications, we strongly feel that our experience we have with RC model aviation and full scale aviation that our flights will be carried out in a very struc tured and professional methodology , that will meet or exceed a commercial pilot that has limited RC aviation experience.

Furthermore, there are no standards for either private or commercial sUAS pilot certificates, knowledge of airspace regulations and dex terity in the control and operation of the sUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. It cannot be assumed that a commercial pilot, approved to operate a manned heli copter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within controlled airspace.



### 14 CFR 61.23

Medical Certificates

T h i s r e g u l a t i on r eq u i r e s p i l o t s of m a nned a i r c ra ft to h o l d a me d i c a l

c e r t i f i c a t e.

S

i

n c e r i sk s a ss o c i a

t

e

d w i

th t he o p e r a

t i on of the p r

op o s ed sUAS ar e s o d

i

m

i

n i s h e

d f r

o

m t h

e l e

v

e l of r i s k a s s o c i a

t

ed w i

th a n

y m a

nn e d a i r c r

a f t ; t

h

e sUAS i s of a s i z e , w e i g

h

t

, s p

e e d

, a nd op e r a

t

i

on a l c a

p

a

b

i

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i

t

i

es w h

i

c

h

m

a k es i t m u c h s a f e r t h

a

n a n

y m a

nned a i r c r

a f t ; s i n c e op e ra t

i

o

ns w i

l

l o c c ur i

n t i

g

ht l

y co n

t

r

o l l

ed a nd li m

i

t

ed a i r s p a c e ; a nd c o

n s i d

e r i n

g t h

a

t a l l

ope r a

t i o

n s w il l be on p r i v

a

te p r

op e r t

y th a

t i s c l ea r o f a l l p eo p l e ,

o

bt a i n i n

g a nd m a i n

t

a i n

i

n

g a me d

i

c

a l c e r t

i f i

c

a

t

e w ou l d n o t i m

p r o

v

e t h

e

s a fe t

y of t he o p

e ra t i o

n. I n t h

e v er y r ar e c a s e of a m i

s h a

p , the sUAS
b

e i n

g f l

o

w

n w i

l

l p o s e s i g

n i f

i

c

a

nt l

y l e s s of a t h

r

e a t th a

n m a

n

n ed

h

e l i

c

op t

e r s a nd f i

x

ed w i

n

g a i

r c r

a ft b e c a

u s e t h

e sUAS’s a r e a f ra c t

i

on of

t

he s i z e , a f r

a c t

i

o

n of the w e i g

ht, w i

l

l b e f l

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i

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p

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, c arr y no f l

a

m

m

a

b

l

e fu e l

, a nd c a rr y n o c re w or p a ss e n

g

er s

. In the case that the Pilot in Command should suffer from a medical emergency, the sUAS will either come to a stop and hover, or continue its pre

- programmed course if the control inputs are released, as they are programmed to remain in flight autonomously.

### 14 CFR 91.7 (a)

Civil Aircraft Airworthiness Certificate

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 inapplicable. It will be the Pilot in Command of the sUAS that will make the final determination and accept responsibility of Airworthiness on a per flight basis.



### 14 CFR 91.9
Civil aircraft flight manual, marking, and placard requirements

This regulation provides tha t no person may operate an aircraft unless a current, approved fl ight manual is in the aircraft.

We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual (product information manual) must be
available to t he crew at the ground station anytime the aircraft is in, or preparing for, flight.



### 14 CFR 91.109
Flight Instruction

This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruc tion unless that aircraft has fully functioning dual controls.

sUAS’s and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use
of a control box that communicates with the airc raft 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 experimen tal aircraft. An equivalent level of safety
is provided by the fact th at neither a pilot nor passengers will b e carried in the aircraft and the size and speed of the aircraft is such that the likelihood of severe damage to personal property or severe injury to persons is unlikely in the event of a loss of control, as compare d to a
full scale aircraft.

### 14 CFR 91.119

Minimum safe altitudes: General

The regulat i on states that over sparsely popu l ated areas the aircraft

cannot be operated closer than 500 feet to any person, vessel, vehicle,

or structure.

S

i

nce the typical m i

ss i on of the sUA V would be photography or survey of

persons or property it will be necessary to operate within the 500 feet safety envelope. Operations will only be flown over property or persons where permission has been obtained , people involved in the photography, filming, or surveying operations are within communication and understand typical pilot distress calls, and careful pre
- planning has been performed. The a i rcraft will be operated at a l ow altitude allow i

ng, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface. Therefore we maintain that due to the physical size and weight of the s UA V

, the hazard to persons, veh i

cles

and structures i s m i

n i mal compared to manned aircraft, wh i

ch shou l

d be

cons i dered in granting the exemption.



### 14 CFR 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 appropri ate altimeter setti ng available before departure.”

The sUAS does not have a barometric altimeter with a read out, using GPS
coordinate solutions instead. The GPS information is provided via electronic downlink to a ground station or cellular phone connecti on broadcasting, among other details, the altitude of the sUAV. To maintain a margin of safety by not accidentally flying above the 400’ AGL threshold, it will be part of the Pilot in Command and sometimes a qualified visual
observer to confirm the altitud e before and during a flight.

### 14 CFR 91.151
Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast

weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly
after that for at least 45 minutes.”

The battery powering the sUAS provides approximately a total of 25

- 30 minutes of powered flight. That would make it impossible to meet the 30 minute reserve requirement. Given the limitations on the sUAS’s proposed flight area and the location of its propo sed operations within a predetermined area, 30 minutes of flight time of reserved battery power (fuel) is unnecessary for safe operation of the sUAS.

An equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power (w hichever occurs first). This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating range

.



### 14 CFR 91.203 (a) & (b)

Civil Aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpi t entrance so that it is legible to passengers or crew."

A

t a maximum gros s weight of 2.7 pounds, the sUAV is too small to carry documentation, does not have an entrance or hatch , and it is not capable of carrying passengers or crew. To obtain an equivalen t level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the ai rcraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the pilot names, company name, telephone number, address, and. The word "EXPERIMENTAL" will be added to satisfy the requirement of 14 CFR 45.23, if deemed necessary.

### 14 CFR 91.401;

14 CFR 91.405 (a);

14 CFR 91.407 (a )( 1);

14 CFR 91.40 9 (a)(1);

14 CFR 91.409 (a)(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. Maintenance will be accomplished by t he Pilot in Command; pursuant to the DJI Phantom 2 User Manual v1.4, Quick Start G uide , and Smart Flight Battery Safety Guidelines manual; as provided by DJI . An equivalent level of safety will

be a chieved because these small sUAV s are very limited in size , will carry a small payload, and operate only in controlled areas for limited periods of time. If mechanical issues arise, the sUA V can land immediately and will be operating less than 400 feet AGL. As outlined in the Chesapeake Aerial Solutions, LLC Chec klist , the Pilot in Command will ensure that the sUAS is in working order prior to initiating flight and perform
maintenance as required. Moreover, the Pilot in Command is the person most familiar with the aircraft and it will be his ultimate responsibilit y that the aircraft in an airworthy condition to provide the highest level of safety.

We respectfully request exemption under Section 333 to enable Chesapeake Aerial Solutions, LLC to operate efficient, limited, low

- risk commercial

sUAS operations for the activities stated respecting at all times the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely

Bart S. Ferguson

Partner

Chesapeake Aerial Solutions, LLC

3951 Main St

P.O.Box 443

Trappe, MD 21673