The Name and Address ofthe Applicant is:

September 29, 2014

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve, SE Washington, DC 20590 Anthony J. Marino President Low Country RC, Corporation 3104 River Drive Thunderbolt, GA 31404 (912) 257- 9617

RE: Exemption Request under Section 333 ofthe FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

Dear Siror Madam:
LowCountryRC, Corporation (LoCoRC) located at 3101 River Drive Thunderbolt, GA 31404 and Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 ("FAA Reform Act") and 14 C.F.R. Part 11, respectfully requests exemptions from several provisions ofthe Federal Aviation Regulations ("FAR"), specifically Section 333which authorizes the FAAto determine:

1. Ifcertain unmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public orpose a threatto national security; and

2. Whethera certificate ofwaiver, certificate ofauthorization, orairworthiness certification undersection 44704 oftitle 49, United States Code, is required forthe operation of unmanned aircraft systems identified under paragraph (1).

We are writing to request that LOCORC, LLC, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed belowsothat LOCORC, mayoperate its small unmanned aircraft systems ("UAS") commercially in airspace regulated bythe Federal Aviation Administration

1("FAA"); as long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe 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 photographywith small, unmanned aircraft and lightweight UAS's.
The substance ofthis request is essentially the same as thatgranted to ASTRAEUS AERIAL Regulatory Docket No. FAA-2014-0352 in that LOCORC is engaged in aerial photograph ofstructures using similar lightweight, remote controlled UAS's in remote areasto minimize the need to climb such structures. LOCORC has fully equipped each of its small unmanned aircraftfor aerial photography, primarilyfor use in the inspection oftowers and structures thatwould otherwise require climbing at great risk to the personnel involved, though given the stability and maneuverability, they may be used by lawenforcement personnel, search and rescue and by otherfirst responders for other photography including video. LOCORC exemption request would permit its operation of lightweight, unmanned (remotely controlled in line ofsight) UAS's in tightly controlled and limited airspace. Predetermined, specifically marked areas ofoperation, 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 amateurswith no flight experience, safety plan orcontrols in placeto prevent catastrophe. Granting LOCORC's request comports with the Secretary ofTransportation's (FAA Administrator's) responsibilities to not only integrate UAS's into the national airspace system, but to"

... establish requirements forthe safe operation ofsuch aircraft systems [UAS's] in the national airspace system" under Section 333 ofthe Reform Act. Further, LOCORC will conduct its operations in compliancewith the protocols described herein or as otherwise established bythe 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 relieffrom any currently applicable FAR's operating to prevent LOCORC contemplated commercial inspections, research and otherflight operations within the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interestto do so. LOCORC lightweight UAS's meetthe definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration of LOCORC lightweight UAS's are expressly contemplated bythe Reform Act. LOCORC would like to operate its lightweight UAS's priorto the time period bywhich the Reform Act requiresthe FAAto promulgate rules governing

2such 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:
Theweight, size, speed and overall capabilities ofthe UAS; Whetherthe UAS will be operated near airports or populated areas; and, Whetherthe UAS will be operated by line ofsight.
112 P.L. 95 

### § 333 (a). Each ofthese items mitigates in favor ofan exemption for LOCORC.
LOCORC UAS's uses multi counter-rotating propellersfor extreme balance, control and stability. They each typically weigh lessthan 55 pounds, including camera or otherequipment. 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 ofvertical and horizontal operations but operate onlywithin the line ofsight ofthe 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 ofan 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 twentyfive percent battery capacity. Safety systems in place include a GPS mode that allows LOCORC UAS'sto hover in place ifcommunication with the radio control pilot is lost and then slowlydescend the UAS attwentyfive percent battery capacity. Further, LOCORC fleet is programmed, in some instances, to slowlyfollow a predetermined set ofwaypoints to return to a safety point ifcommunications are lost. LOCORC does not operate its UAS's near airports and generally does not operate them near populated areas. LOCORC operation ofits fleet ofsmall unmanned aircraftwill not "create a hazard to
users ofthe national airspace system orthe public." 112 P.L. 95 

### § 3 3 3 (b). Given the small size and weight ofLOCORC UAS's, combined with their operation in cordoned offand 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 intothe national airspace system. Indeed, LOCORC UAS's have a demonstrable safety record and do not pose anythreatto the general public or national security. The FAA has the authorityto issue the exemption to LOCORC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting LOCORC exemption requestfurthers the public interest. First, Congress has already pronounced that it is in the public's interestto integrate commerciallyflown UAS's into the national airspace system, hence the passing ofthe Reform Act. Second, LOCORC conducts research into safe UAS operations every time itflies 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 abilityto further enhance current safety measures. Third, the public

3has 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 substantiallyfurthers the public's interest in ways known and currently unknown. Permitting LOCORC to immediatelyfly within the United States furthers advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel and first responders with state ofthe art equipmentthat does not cost millions ofdollars.
ReasonsWhy LOCORC Exemption Will NotAdverselyAffect Safety Or HowThe Exemption Will Provide a Level ofSafetyAt Least Equal To Existing Rule: LOCORC exemption will not adversely affectsafety. Quite the contrary, forthe various reasons stated, permitting LOCORC to log moreflight time will allow LOCORC to innovate and implement new and as ofyet undiscovered safety protocols. LOCORC UAS'sweigh less than 55 pounds complete with cameras. LOCORC only operates its UAS's below400 feet;
LOCORC UAS's only operatefor 5-45 minutes perflight; LOCORC lands its UAS's when they reach 25% battery power; LOCORC remote control pilots operate LOCORC UAS's by Visual Line ofSight (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 GPSflight modes wherebythey hover and then slowly land if communication with the remote control pilot is lost or battery power is below25%; LOCORC actively analyses electronicflight data and othersources ofinformation to constantly update and enhance safety protocols; LOCORC only operates in secured areas that are strictly controlled, are awayfrom airports and populated areas; LOCORC conducts extensive briefings priorto flight, during which safety carries primary importance; LOCORC always obtains all necessary permissions and permits priorto operation; LOCORC provides a level ofsafety at least equal to existing rules, and in nearly every instance, greaterthan existing rules. It is importantto note that absentthe integration ofcommercial UAS's into our national airspace system, helicopters are the primary means ofaerial photography. Whilethe safety record ofsuch helicopters is remarkably astounding, it is far saferto operate a battery powered lightweight UAS.

4First, the potential loss of life is diminished because UAS's carry no people on board and LOCORC only operates in specific areas awayfrom mass populations. Second, there is no fuel on board a UAS and thus the potential forfire orexplosions 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 objectsthey are focused on. Accordingly, LOCORC UAS's have operated and will continue to operate atand above current safety levels.



### Summarythe 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, setsforth 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 meetan equivalent level ofsafety pursuantto Section 3 3 3 ofthe 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 ofthe Reform Act. Both pieces of legislation permitthe FAAto exempt UAS'sfrom the airworthiness certificate requirement in consideration oftheweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. LOCORC UAS's meet orexceed each ofthe elements. 14 C.F.R. 91.7 (a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in theform contemplated bythe FARs, this Regulation is inapplicable.
14 C.F.R. § 91.9 (b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafetywill 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 altimetersettings 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 forthe carrying ofcivil aircraft certifications and registrations. They are inapplicableforthe same reasons described above. The equivalent level ofsafetywill be achieved by maintaining such certifications and registrations atthe LOCORC flight operations center.

5B. 14 C.F.R. 

### § 45.23: Marking ofthe Aircraft. Applicable Codes of Federal Regulation require aircraftto be marked according to certain specifications. LOCORC UAS's are, by definition, unmanned. Theytherefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficultto place on such small aircraft. The FAA has previously issued exemptions tothis regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700.

C. 14 C.F.R. 

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

### §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. LOCORC can achieve an equivalent level ofsafety 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 pilotvetting and training programs (based upon completion ofan FAAApproved Ground School and a self-administered UAS flight training program and internal procedures) will. All Further, the risks attendantto the operation of LOCORC UAS's is far lessthan the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

### § 61, etseq.

D. 14 C.F.R. 91.119: Minimum SafeAltitudes. 14 C.F.R. 

### § 91.119 prescribes safe altitudes forthe operation ofcivil aircraft. It allows Helicopters to be operated at lower altitudes in certain conditions. LOCORC UAS's will never operate at an altitude greaterthan 400AGL. LOCORC will, however, operate its UAS's in sectioned offareas with security perimeters, providing a level of safety at least equivalentto those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofLOCORC UAS's, an equivalent level of safetywill 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 otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph C ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter."
These Regulations only applyto aircraftwith an airworthiness certificate. Theywill not, therefore, applyto LOCORC should its requested exemption be granted. LOCORC conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment ofany damaged hardware. Therefore, an equivalent level ofsafetywill be achieved. LOCORC has researched and developed its own designs.



### 6F. 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 ofsmall unmanned vehicles and lightweight unmanned aircraftvehicles and to conduct its own research and to develop economic platformsfor aerial survey, law enforcement
,first responders, search and rescue. Granting LOCORC requestfor exemption will reduce current risk levels and therebyenhance 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 ofa flight operations manual that exceeds currently accepted means and methods ofsafe flight. There are no people on board LOCORC UAS's and therefore the likelihood ofdeath orserious bodily injury is significantly limited. LOCORC operation of its UAS's, weighting less than 55 pounds and traveling atspeeds lowerthan 50 knots in cordoned offareas will provide at least an equivalent level ofsafety asthat achieved under current FARs.

LOCORC respectfully requests thatthe FAA grant its exemption requestwithout delay. The FAA has the authorityto issue the exemption sought by LOCORC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

# By~~ AnthonyJ. Marino President



### 7 for: LowCountryRC, LLC
3104 River Drive Thunderbolt, GA 31404
912 257 9617 SSS@LowCountryRC.com