January 23, 2015 U.S.Department ofTransportation DocketManagementSystem 1200 NewJersey Ave., SE Washington, DC 20590

Dear SirorMadam:
Attached please find Aerial Industrial's request for an exemption from the listedFederal Aviation Regulations to allow commercial operation ofits Small Unmanned Aircraft Systems ("sUASs") for aerial imaging and monitoring ofsecured and controlled environments with respect to construction sites, flare stacks, transmissiontowers, other related industrial elevated structures. This exemption request is exclusively for the use of the DJI

### Spreading Wings S-1000 octocopterto be used by Aerial Industrial LLC.
Also attached to this letter is the Aerial Industrial Flight Operations Manual (FOM) and Aircraft FlightManual (AFM) (both hereinafterreferred to as Manuals), both proprietary and confidential documents, which outline the operating requirements, limitations, and technical specifications for the Aerial Industrial's operation ofthe DJI S-1000 system. Aerial Industrial has reviewed the Manuals and has found themto be acceptable for sUAS operations for commercial operations as detailed above. The Applicant submits these Manuals (FOM and AFM) as proprietary and confidential information pursuant to 14 CFR 11.35 (b). The Manuals (FOM and AFM) contain operating conditions and procedures that
are not available to the public and are protected from release underthe Freedom of Information Act 5 USC 552 et. seq.
Please be advised thatthis exemption request being submitted by Aerial Industrial is extremely similar in nature to the exemption submittedto the FAA by Clayco, Inc. For purposes ofexpediting the exemption process, Aerial Industrial is agreeable to abide by and acceptthe Conditions and Limitations stipulated in Clayco, Inc, Trudeau, and other recent approvals. Grant ofExemptionNos. 11109 & 11138.
Thankyou foryourtime and consideration, and please letmeknow ifyou have any questions.

Sincerely,



### ~ .



# ~~~/ President & Founder Aerial Industrial L.L.C

### January 12, 2015 U.S.Department ofTransportation DocketManagementSystem 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 oftheFAA Reform Actand Part 11 oftheFederal Aviation Regulations from 14 C.P.R. 45.23(b); 14 CFRPart21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) &(b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). Dear Sir orMadam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.P.R. Part 11, Aerial Industrial L.L.C. ("Aerial Industrial"), a imagery and inspection firm, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits Small Unmanned Aircraft Systems ("sUASs") for aerial imaging for inspection, and monitoring of secured and controlled environment with respect to construction sites, flare stacks, transmission towers, otherrelated industrial elevated structures, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA asrequired by Section 333. As detailed in this document, and the attached Manuals, the requested exemption would permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide for safer inspections thus preventing the use ofconventional aircraft overindustrial sites and eliminates the need to place personnel in harms way when attempting to access elevated structures without conventional access. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to"

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: Aerial Industrial L.L.C MickeyLandry Phone: 409-504-8234 1580 Liston Rd. Orange, Texas 77630

Regulations from which the exemption isrequested:
14 C.P.R. Part21 14 C.F.R.45.23(b) 14C.F.R.61.113 (a) &(b) 14 C.P.R. 91.7 (a) 14 C.P.R. 91.9 (b)(2) 14 C.P.R. 91.103 14 C.P.R. 91.109

### 14 C.P.R.91.119 14 C.P.R. 91.121 14 C.P.R. 91.151 (a) 14 C.P.R. 91.203 (a) & 

### (b) 14 C.P.R. 91.405 (a) 14 C.P.R. 407 (a) (1) 

### 14 C.P.R. 409 (a)(2) 14 C.P.R. 417 (a) & 

### (b)

I.STATUTORY AUTHORITY FOR EXEMPTIONS 

### TheFederal Aviation Actexpressly grantsthe FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40 101 ofthe Act, including sUASs, from therequirement that all civil aircraft must have a current airworthiness certificate. The Administratormay grant an exemption from a requirement ofaregulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §4471 1(a); 49 USC §44704; 14 CFR §91.203(a) (1). Section 333(b) ofthe Reform Act assists the Secretary in determiningwhether sUASs may operate in theNational Airspace System (NAS) without creating ahazard to the user, the public, or a threat to national security. In makingthis determination, the Secretary mustconsider: The sUAS's size, weight, speed, and operational capability;

• Whetherthe s UAS operates withinthe visual line ofsight ofthe operator

• Whether the sUAS operates outside ofhighly populated areas and away from close proximity to airports Reform Act §333(a). Ifthe Secretary determines that a sUAS "may operate safely in the national airspace system (NAS), the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." Id. §333(c). Aerial Industrial's sUASs are multirotor vehicles, weighting 25 or fewer lbs. including payload. They operate under normal conditions at a speed ofno more than 50 knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. The sUASs will operate only in the pilot's visual line ofsight at all times and will operate only within the sterile area described in the Manuals, attached as Exhibit 1. Such operations will insure thatthe sUASs will "not create a hazard to users ofthe national airspace system orthe public." Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted and sterile environment within which they will operate, our application falls squarely within the
zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of sUASs to commence immediately.Also due to the small size ofthe UASs, the low altitudes, and restricted areas in which our sUASs will operate, approval ofthe application does not present a national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surroundingthe proposed operations, and the significantpublic benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, Aerial Industrial respectfully requests thatthe FAA grantthe requested exemption without delay.

II.PUBLIC INTEREST

This exemption application is expressly submittedto fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to considerwhether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAA will fulfill Congress's intentofallowing sUAS to operate utilizing significant safety precautions in low risk environments. The use ofsUASs in an industrial settingto inspect and monitor elevated structures and towers can significantly reducethe riskto workers offalls while inspecting, surveying, or monitoring such structures. sUASs can inspect, photograph, andcollect data on hard to getto
areas that otherwise would require dangerous worker inspections. Historically, falls are the leading source ofworkplace fatality and injury on construction sites1

, and reducing falls through sUAS use for site imaging could save workers lives. Additionally, sUASs could replacethe use ofhelicopters and small aircraftto monitor sites. The sUASs we propose to fly in this application is undertwenty-five (25) pounds, and carries no combustible material on board, as opposedto the much larger conventionally powered small aircraft. Shiftingto sUASs from helicopters presents a marked safety increase for our workers andthe public. · Lastly, sUASs reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection over a construction site. Our sUASs use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation ofsmall aircraftthat are many hundreds oftimes heavier.

III.EQUIVALENT LEVEL OF SAFETY Aerial Industrial proposes thatthe exemptionrequested herein applyto civil aircraft that have the characteristics andthat operate with the limitations listed herein. These limitations provide for at least an equivalent, oreven higher, level ofsafetyto operations underthe currentregulatory structure becausethe proposed operations represent a safety

1"Commonly Used Statistics", Occupational Safety &Health Administration. Available at: https://www.osha.gov/ oshstats/ commonstats.htmlenhancementto the already safe protocols followed on industrial sites and imaging and surveying operations conducted with helicopters and other conventional aircraft. Aerial Industrial will be bound by the following limitations when conducting its sUAS operations under anFAA issued exemption:

1. The sUAS will be less than 25 pounds. 2. Flights will be operated within

**~isualline** ofsight ofa pilot. 3. Maximum total flight time for each operational flight will be 30 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude never exceeding 400 feet AGL. 5. Flight Crewfor each operationwill consist ofthe sUAS pilotwho will keep the sUAS within his visual line ofsight at all times, and a Visual Observerto assist the pilot. 6. The sUAS pilot and the Visual Observer will be trained in flight, operations, and safety procedures as detailed in the Manuals. 7. The sUAS will only operate within a confined "Sterile Area" as defined in the Manuals. TheManuals also require the establishment ofa "Security Perimeter" for the flight operations area. 8. A briefing will be conducted in regard to the planned sUAS operaticms prior to each day's flight activities. Itwill be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeterbe presentfor this briefing. 9. All onsite personnel will consentto the UAS flyover on site bywaiver, and the pilotwill obtain additional verbal orwritten consent ofall persons who will be allowed within 1 00 feet ofthe flight operation. 10.Written and/or oral permission from the relevant property holders will be obtained. 11.All required permissions andpermits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orother appropriate governmental agencies. 12.Ifthe sUAS loses communications or loses its GPS signal, it will have capability to return to a pre-determined location within the Security Perimeter and land. 13.The sUAS will have the capability to, and the pilotwill initiate a, flight abort in case ofunpredicted obstacles or emergencies.



### IV. DESCRIPTION OF SPECIFICREGULATIONS
14CFRPart21,SubpartH:Airworthiness Certificates 14C.F.R. §91.203(a)(l)
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating areaassociated with the aircraftto be utilized by the Aerial Industrial, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 33 3 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. Aerial Industrial's sUAS will be operated at low speed in a controlled environment, at least five miles from an airport and morethanthree miles from any city ordensely populated area. An analysis ofthese criteria demonstrates thatthe 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 (fixed wing orhelicopter) operatingwith an airworthiness certificate withoutthe restrictions andconditions proposed. The sUAS to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manuals. Like othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by the pilot, pursuantto the Manual's requirements, and underthe requirements, and in compliance with, local public safety requirements, to obtain aerial imagery ofconstruction sites, industrial complexes and structures. The FAA will have advance notice ofall operations as prescribed in the Manuals. These safety enhancements, which already applyto civil aircraft operated in connection with construction sites, provide a greater degree of safetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the UAS, due to its size, speed of operation, location of operation, lack ofexplosive materials orflammable liquid fuels, and abilityto carry an external load no greaterthan seven (7) lbs.


### 14 C.F.R.45.23(b): Marking ofthe Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or light- sport category aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station. Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAS, two-inch lettering will be impossible.The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level ofsafety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) wherethe pilot, observer and others working with the sUAS will see the identification oftheUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A.



### 14 CFR 61.113 (a) & 

### (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a UAS flight training course as prescribed in the Manuals, and have accumulated at least twenty-five (25) hours oftotal time as a UAS pilot, with at leastten (10) hours logged as a UAS pilot with similarUAS type, before flying a UAS for Aerial Industrial in commercial operations. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with no livingthing orcargo on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manuals. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a pilot who has metthe minimum requirements stated in the Manuals exceeds the present level ofsafety achieved by 14 C.P.R. §61.113 (a) & (b).

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

### Civil aircraftairworthiness

Theregulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft andthe requirements contained in the Manuals for maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided.


### 14 CFR 91.9 (b)(2): Civil aircraftflight manual, marking,and placard requirements

The sUAS, given its size and configuration has no ability orplace to carry such a flight manual onthe aircraft, not only because there is no pilot on board, but because there is
no room or capacity to carry such an item onthe aircraft. The equivalent level ofsafety will be maintained by keeping the Manuals at the ground control point wherethe pilotflying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,32827, and 10700.



### 14 C.F.R. 91.103: PreflightAction

This regulation requires each pilot in command (PIC) take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checkingfor weatherconditions, checking flight batteryrequirements, checkingtakeoffand landing areas, and all other actions in the Preflight Checklist as prescribed in the Manuals. These actions will provide an equivalent level ofsafety and are prescribed by the Aerial Industrial sUAS operations.



### 14 C.F.R. 91.109: Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUASs and remotely piloted aircraft do not have fully functional dual



### contr~ls. Flight control is accomplished through the use ofa control boxthat communicates withthe aircraft viaradio communications. The FAAhas previously approved exemptions for aircraftwithout fully functional dual controls. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilotnorpassengers will be carried in the aircraft, the ability to control the sUAS viaradio signals from the controller, and by the size and speed ofthe aircraft.


### 14 

### C.F. R. 91.119: Minimum SafeAititudes

Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less thanthe minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. This exemption is for a multirotor craftthat flies similarly to a helicopter, with vertical take offand vertical landing, which will typically operate at altitudes below 400'AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted areawith security perimeter, where buildings and people will notbe exposedto operations withouttheir pre-obtained consent. Seethe Manuals for detailed procedures. The equivalent level ofsafety will be achieved giventhe size, weight, speed ofthe UAS as well as the locationwhere it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel as outlined in the Manuals, all affected individuals will be aware ofthe planned flight operations. Comparedto flight operations with aircraft or rotorcraft weighting far more thanthe sUAS proposedherein, and carrying flammable fuel, anyrisk associated with ouroperations is far less thanthose presently presented with helicopters and other conventional aircraft operating at orbelow 500 AGL in the construction industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations andthe operations ofconventional aircraftthat must comply with Section 91.119.



### 14 C.F.R. 91.121: AltimeterSettings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, butinstead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuanttothe Manual's preflight requirements and checklists confirming the altitude ofthe launch site before flight.



### 14 CFR 91.151 (a): 

### Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. OurUAS is limited to operations in sterile and controlled environments as outlined in the Manuals, and has a limited range and flight time whichrequire an exemption from 14 CFR91.151(a).

The batterypoweringthe sUAS provides no greaterthan 30 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limitedto approximately 0 minutes in length. Given the limitations onthe UAS' s proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ornightVFR conditions is reasonable. Aerial Industrial believes that an exemption from 14 CFR §91.151 (a) falls within the scope ofprior exemptions. See Exemption 10673 (allowingLockheed Martin Corporation to operate without compliance with FAR91.151 (a)). Operatingthe small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender thetype ofrisks that Section 91.151(a) was intendedto alleviate giventhe size and speed of the small UAS. Additionally, limiting sUAS flights to 0 minutes would greatly reduce the utility for which the exemption will be granted. An equivalent level ofsafety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensurethatthe sUAS lands atthe ground station with at least 20% ofbattery power (as determined bythe onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its plannedlanding zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,5745, 10673,and 10808.



### 14 CFR 91.203 (a) 

### &(b): Carrying civil aircraftcertification and registration
The regulation provides inpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) Noperson may operate acivil aircraftunless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legibleto passengers or crew.

The UAS fully loaded weighs no more than 25 lbs. and is operated without an onboard pilot. Therefore there is no ability orplace to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground flight control pointwhere the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 10700.


### 14 CFR 91.405 (a); 

### 407 (a)(l); 409 (a)(2); 

### 417 (a) & 

### (b): Maintenance inspections

Theseregulations require that an aircraft operator or owner "shall have that 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 part43 ofthis chapter

...," and others shall inspect ormaintainthe aircraft in compliance with Part 43. Given thatthese section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Aerial Industrial. Maintenance will be accomplished by the operator pursuantto the Manuals and manufacturer guidance. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL and within visual line ofsight ofthe pilot. As provided in the Manuals, the pilotwill ensure thatthe UAS is in working orderprior to initiating flight, has the required maintenance, and keep a log ofany maintenance performed/needed. Moreover, the pilot is the person most familiar withthe aircraft and best suited to maintain the aircraft in
an airworthy conditionto provide the equivalent level ofsafety.


### *******

Pursuantto 14 C.P.R. Part 11, the following summary is provided for publication in the Federal Register, should itbe determined that publication is needed:Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R45.23(b); 14 C.F.R. §§ 61.113( a) 

### & (b);91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs
or less) in construction operations. Approval ofexemptions allowing commercial operations ofsUASs in the construction industry enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greaterrisk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 25 lbs. and powered by batteries eliminates virtually all ofthat risk given the reducedmass and lack of combustible fuel carried onboard. The sUAS will carry no passengers orcrew and, therefore, will notexpose themto the risks associated with manned aircraftflights.

The operation ofsmall UASs, weighting less than 25 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant of the exemptionsrequested herein, including exemptingthe applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweightaircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. 

### Privacy

All flights will occur overprivate orcontrolled access property withthe property owner's prior consent and knowledge. Images taken will be ofindividuals who have also consentedto being filmed or otherwise have agreedtobe in the area where aerial photography will take place. 

## *******
Satisfaction ofthe criteriaprovided in Section 333 ofthe ReformActof2012--size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security -provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's UASs in construction industry pursuantto the Manual appended hereto.

Sincerely,



# ~;;

**#~yLandry**

President & Founder Aerial Industrial L.L.C.