The Name and Address of the Applicant is: 

September 29, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Anthony J. Marino 

President 

Low Country RC, Corporation 

31 04 River Drive 

Thunderbolt, GA 31404 

(912) 257- 9617 

RE: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. Part 11 

Dear Sir or Madam: 

LowCountryRC, Corporation (LoCoRC) located at 3101 River Drive Thunderbolt, GA 

31404 and Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

("FAA Reform Act") and 14 C.F.R. Part 11, respectfully requests exemptions from several 

provisions of the Federal Aviation Regulations ("FAR"), specifically Section 333 which 

authorizes the FAA to determine: 

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated 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; and 

2. Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

We are writing to request that LOCORC, LLC, an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") 

listed below so that LOCORC, may operate its small unmanned aircraft systems 

("UAS") commercially in airspace regulated by the Federal Aviation Administration 

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("FAA"); as 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. 

LOCORC has been actively involved in the technical development of UAS/ UAV 

service applications to provide high definition aerial photography with small, 

unmanned aircraft and lightweight UAS's. 

The substance of this request is essentially the same as that granted to 

ASTRAEUS AERIAL Regulatory Docket No. FAA-2014-0352 in that LOCORC is 

engaged in aerial photograph of structures using similar lightweight, remote controlled 

UAS's in remote areas to minimize the need to climb such structures. 

LOCORC has fully equipped each of its small unmanned aircraft for aerial 

photography, primarily for use in the inspection of towers and structures that would 

otherwise require climbing at great risk to the personnel involved, though given the 

stability and maneuverability, they may be used by law enforcement personnel, 

search and rescue and by other first responders for other photography including 

video. 

LOCORC exemption request would permit its operation of lightweight, unmanned 

(remotely controlled in line of sight) UAS's in tightly controlled and limited airspace. 

Predetermined, specifically marked areas of operation, sectioned off locations will 

allow LOCORC to operate within current safety parameters and new ones being 

implemented. As identified, similar lightweight, remote controlled UAS's are legally 

operated by amateurs with no flight experience, safety plan or controls in place to 

prevent catastrophe. 

Granting LOCORC's request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UAS's into the national airspace 

system, but to" ... establish requirements for the safe operation of such aircraft 

systems [UAS's] in the national airspace system" under Section 333 of the Reform 

Act. Further, LOCORC will conduct its operations in compliance with the protocols 

described herein or as otherwise established by the FAA. 

The Extent of Relief LOCORC Seeks and the Reason It Seeks Such Relief: 

LOCORC submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FAR's operating to 

prevent LOCORC contemplated commercial inspections, research and other flight 

operations within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our national 

airspace system as it is in the public's interest to do so. LOCORC lightweight UAS's 

meet the definition of "small unmanned aircraft" as defined in Section 331 and 

therefore the integration of LOCORC lightweight UAS's are expressly contemplated 

by the Reform Act. LOCORC would like to operate its lightweight UAS's prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing 

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such craft. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: 

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be 

operated near airports or populated areas; and, Whether the UAS will be operated by 

line of sight. 

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for 

LOCORC. 

LOCORC UAS's uses multi counter-rotating propellers for extreme balance, control 

and stability. They each typically weigh less than 55 pounds, including camera or 

other equipment. Each of LOCORC's small unmanned aircraft is designed to primarily 

hover in place and operate at less than a 50 knot maximum speed. They are capable 

of vertical and horizontal operations but operate only within the line of sight of the 

remote control pilot. In addition to the remote control pilot, LOCORC uses a camera 

operator, such that, at minimum, two LOCORC personnel govern the safe flight of an 

LOCORC aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five 

and twenty minutes. LOCORC does not operate its UAS's with less than twenty five 

percent battery capacity. Safety systems in place include a GPS mode that allows 

LOCORC UAS's to hover in place if communication with the radio control pilot is lost 

and then slowly descend the UAS at twenty five percent battery capacity. Further, 

LOCORC fleet is programmed, in some instances, to slowly follow a predetermined 

set of waypoints to return to a safety point if communications are lost. 

LOCORC does not operate its UAS's near airports and generally does not operate 

them near populated areas. 

LOCORC operation of its fleet of small unmanned aircraft will not "create a hazard to 

users of the national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). Given the 

small size and weight of LOCORC UAS's, combined with their operation in cordoned 

off and well-controlled areas, LOCORC fleet falls within Congress's contemplated 

safety zone when it promulgated the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. Indeed, LOCORC UAS's have a 

demonstrable safety record and do not pose any threat to the general public or 

national security. The FAA has the authority to issue the exemption to LOCORC 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Commercial and Public Benefits Granting LOCORC exemption request furthers the 

public interest. First, Congress has already pronounced that it is in the public's 

interest to integrate commercially flown UAS's into the national airspace system, 

hence the passing of the Reform Act. Second, LOCORC conducts research into safe 

UAS operations every time it flies one of its UAS's. Flight data, visual inspections, 

recorded observations and flight analyses are compiled to further enhance current 

safety protocols. Allowing LOCORC to log more flight time directly relates to its 

research and its ability to further enhance current safety measures. Third, the public 

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has an interest in reducing the danger associated with current aerial inspection 

methods, namely, resorting to physically climbing high or compromised structures to 

inspect. 

Granting LOCORC exemption request substantially furthers the public's interest in 

ways known and currently unknown. Permitting LOCORC to immediately fly within the 

United States furthers advancements in publicly usable technologies or 

advancements in equipment available to law enforcement personnel and first 

responders with state of the art equipment that does not cost millions of dollars. 

Reasons Why LOCORC Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

LOCORC exemption will not adversely affect safety. Quite the contrary, for the 

various reasons stated, permitting LOCORC to log more flight time will allow 

LOCORC to innovate and implement new and as of yet undiscovered safety 

protocols. 

LOCORC UAS's weigh less than 55 pounds complete with cameras. 

LOCORC only operates its UAS's below 400 feet; 

LOCORC UAS's only operate for 5-45 minutes per flight; 

LOCORC lands its UAS's when they reach 25% battery power; 

LOCORC remote control pilots operate LOCORC UAS's by Visual Line of Sight 

(VSOL) 

LOCORC remote control pilots have video backup should they somehow lose sight of 

the UAS; 

LOCORC staffs each flight with a remote control pilot and camera operator; 

LOCORC UAS's have GPS flight modes whereby they hover and then slowly land if 

communication with the remote control pilot is lost or battery power is below25%; 

LOCORC actively analyses electronic flight data and other sources of information to 

constantly update and enhance safety protocols; 

LOCORC only operates in secured areas that are strictly controlled, are away from 

airports and populated areas; 

LOCORC conducts extensive briefings prior to flight, during which safety carries 

primary importance; 

LOCORC always obtains all necessary permissions and permits prior to operation; 

LOCORC provides a level of safety at least equal to existing rules, and in nearly 

every instance, greater than existing rules. It is important to note that absent the 

integration of commercial UAS's into our national airspace system, helicopters are the 

primary means of aerial photography. While the safety record of such helicopters is 

remarkably astounding, it is far safer to operate a battery powered lightweight UAS. 

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First, the potential loss of life is diminished because UAS's carry no people on board 

and LOCORC only operates in specific areas away from mass populations. Second, 

there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. Third, the small size and extreme maneuverability of LOCORC UAS's 

allow our remote control pilots to avoid hazards. Lastly, given their small size and 

weight, even when close enough to capture required images, LOCORC UAS's need 

not be so close to the objects they are focused on. Accordingly, LOCORC UAS's 

have operated and will continue to operate at and above current safety levels. 

Summary the FAA may publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 

C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). 

The size, weight and enclosed operational area of LOCORC UAS's permits 

exemption from Part 21 because LOCORC UAS's meet an equivalent level of safety 

pursuant to Section 3 3 3 of the Reform Act. The FAA is authorized to exempt aircraft 

from the airworthiness certificate requirement under both the Act (49 U.S. C. § 44701 

(f)) and 

A. Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas such as airports and dense 

populations. LOCORC UAS's meet or exceed each of the elements. 

14 C.F.R. 91.7 (a) 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. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are 

no pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual at 

the flight operations center. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 

10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as LOCORC 

UAS's utilize electronic global positioning systems and internal gyroscopes to provide 

spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications 

and registrations. They are inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining such certifications and 

registrations at the LOCORC flight operations center. 

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B. 14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. LOCORC UAS's are, by definition, unmanned. They therefore 

do not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such small aircraft. The FAA 

has previously issued exemptions to this regulation through Exemptions Nos. 8738, 

10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. PIC 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. LOCORC can achieve an equivalent level of safety as achieved by 

current Regulations because LOCORC UAS's do not carry any pilots or passengers. 

Further, while helpful, a pilot license will not ensure remote control piloting skills, 

though LOCORC pilot vetting and training programs (based upon completion of an 

FAA Approved Ground School and a self-administered UAS flight training program 

and internal procedures) will. All Further, the risks attendant to the operation of 

LOCORC UAS's is far less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R. § 61, et seq. 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C. F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

Helicopters to be operated at lower altitudes in certain conditions. LOCORC UAS's 

will never operate at an altitude greater than 400 AGL. LOCORC will, however, 

operate its UAS's in sectioned off areas with security perimeters, providing a level of 

safety at least equivalent to those in relation to minimum safe altitudes. Given the 

size, weight, maneuverability and speed of LOCORC UAS's, an equivalent level of 

safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to "have [the] 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." 

These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to LOCORC should its requested exemption be granted. 

LOCORC conducts an extensive maintenance program that involves regular software 

updates and constant inspection for assessment of any damaged hardware. 

Therefore, an equivalent level of safety will be achieved. LOCORC has researched 

and developed its own designs. 

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F. Summary 

LOCORC seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 

(a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 

14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.P.R.§ 91.409 (a)(2); 14 

C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its 

fleet of small unmanned vehicles and lightweight unmanned aircraft vehicles and to 

conduct its own research and to develop economic platforms for aerial survey, law 

enforcement , first responders, search and rescue. Granting LOCORC request for 

exemption will reduce current risk levels and thereby enhance safety. 

Further, LOCORC operates at lower altitudes and in controlled airspace. LOCORC 

has been analyzing flight data and other information in compiling novel safety 

protocols and the implementation of a flight operations manual that exceeds currently 

accepted means and methods of safe flight. There are no people on board LOCORC 

UAS's and therefore the likelihood of death or serious bodily injury is significantly 

limited. LOCORC operation of its UAS's, weighting less than 55 pounds and traveling 

at speeds lower than 50 knots in cordoned off areas will provide at least an equivalent 

level of safety as that achieved under current FARs. 

LOCORC respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by LOCORC 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

By~~ Anthony J. Marino 

President 

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for: LowCountryRC, LLC 

31 04 River Drive 

Thunderbolt, GA 31404 

912 257 9617 

SSS@LowCountryRC. com