Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE WASHI NGTON, DC 20590 INTHE MATTER OF THE PETITION FOR EXEMPTI ON OF: Brad Blosser
FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION REGULATI ONS FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS C.F. R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). CONCERNI

NG COMMERCI

AL OPERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION

AND REFORM ACT OF 2012 (PUBLIC LAW 112
- 95)

Submitted on January

17, 2016 Brad Blosser 10069 County

Road 16 Middlebury, I

N 46540 brad@goshenhealth.com 574.238.1087Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 2

Table of Contents GLOSSARY OF ABBREVIATIONS
................................ ................................ ................ 3 INTRODUCTION AND INTERESTS OF THE PETITIONER
................................ ........ 4 Executive Summary
................................ ................................ ................................ ............ 4 Expeditious Summary

Grant Approval Request
................................ ............................. 4 Description of Ty

pe, Make and Models of sUAV/UAS Requested:
.......................... 5 Commercial (Mission, Operation) Purpose:
................................ ............................... 7 Regulations from which the Exemption Relief is requested:
................................ ...... 8 The name and address of the Petitioner:
................................ ................................ ..... 9 Background
................................ ................................ ................................ ..................... 9 Commitment to Safety
................................ ................................ ................................ 9 Expertise & Experience
................................ ............. **Error! Bookmark not defined.** The Exemption Request
................................ ................................ ................................ .... 10 Operator Requirements
................................ ................................ ................................ . 11 Aircraft and Equivalent Level of Safety
................................ ................................ ....... 14 Specific Uses Public Benefits
................................ ................................ ....................... 18 Equivalent Level of Safety
................................ ................................ ............................ 19 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.
................................ ..................... 20 14 C.F.R. §91.119: Minimum safe altitudes
................................ ............................. 20 14 C.F.R. §91.121 Altimeter Settings
................................ ................................ ....... 21 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
............... 21 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections
................................ ................................ ................................ ................ 22 Federal Register Publication
................................ ................................ ............................. 22 Privacy and National Security
................................ ................................ .......................... 23 Summary
................................ ................................ ................................ ........................... 23Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate o f Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice To Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section

333 SO Safety

Observer SOP Standard Operating Procedures sUAS Small Unmanned Aircraft System sUAV Small Unmanned Aircraft Vehicle UA Unmanned Aircraft UAS Unmanned Aircraft System UAV Unmanned Aircraft Vehicle VFR Visual Flight Rules VLOS Visual Line o f Site VMC Visual Meteorological Conditions VTOL Vertical Take
- Off and LandingBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 4

INTRODUCTION AND INTERESTS OF THE PETITIONER Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Brad Blosser Operator of Small Unmanned Aircraft Systems (“sUAS ’ s”) equipped to offer on- demand commercial UAS operations for a host of industries and applications and to perform the purposes listed below , hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow c ommercial operation of its sUAVs/UAS , so long as such operations are conducted within and under the conditions outlined herein or as may b e established by

the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f) As described more fully

b elow, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance safety

and fulfill the Secretary o f Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. 1 Executive Summary Expeditious Summary

Grant Approval Request The petitioner requests the agency i ssue a summary

grant process for this application. Petitioner has provided in a confidential document attachment labeled as petitioner proprietary

information, specific exemption numbers whereb y the FAA has already granted a previous exemption similar or identical to each and every request, herein. For the FAA’s benefit, Petitioner’s C onsultant, Brad Blosser, has researched, categorized and arranged all 631 exemptions granted as of June 23, 2015 into a usable searchable database, based upon the following criteria: date submitted, date grant issued, time to petition grant, petitioner, petitioner’s state, exemption number, sUAV equipment ty pe, grant purpose (mission/operation), along with other supporting data.

1 Brad	Blosser relies	upon	the	following	exemptions	where	specific	reference	to	an exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080,	11109	through 11112,	11114,	11213,	11062	and	as	recent	as	11857.Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 5

Petitioner has identified four previous approved exemptions for each of the Petitioners FAA submission requests:

 Commercial (mission/operation) purposes;  Ty pe of sUAVs (UAS); Description of Ty

pe, Make and Models of sUAV/UAS Requested: The petitioner is seeking an exemption to commercially operate sUAV s makes and model s as follows: 1. 3D Robotics Aero

– M 101. HexaCrafter HQ
- 850 2. 3D Robotics Fixed Wing 102. HexaCrafter HQ
- 1150 3. 3D Robotics Iris 103. HobbyKing Bixler 2 4. 3D Robotics Solo 104. Hoverfly – Livesky 5. 3D Robotics X8 105. HSE UAV

– DRASS Q1000 6. 3D Robotics X8+ 106. Hubsan

– X4 Microdrone 7. 3D Robotics X8
-M 107. Inova Drone

– Inova One 8. 3D Robotics Y6 108. Intuitive Aerial

– Aerigon IAH 3 9. AeroCamera
- SR 15 109. Kespry Drone Systems 10. Aerial Pixels
- Fx8Pro Elite 110. KongCopter FQ700 11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump
- 15 12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump
-20 13. AeroLogix

– Geostar 113. Latitude HQ
-20 14. Aeronavics SkyJib
- 8 Ti
- QR 114. Latitude HQ
-40 15. Aeronavics X4 Titanium 115. Latitude HQ
- 60 16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ 17. AeroVironment Puma 117. Leptron

– Avenger 18. AeroVironment Qube 118. Lockheed Martin

– Desert Hawk III 19. AeroVironment Shrike 119. Lockheed Martin

– Indago 20. Aeryon Scout 120. Mavinci

– Sirius Pro 21. Aeryon Sky

Ranger 121. Microdrones MD4 22. AgEagle 122. Microdrones

– MD4
-200 23. Agribotix Enduro Quad 123. Microdrones

– MD4
- 1000 24. Agribotix Hornet Drone 124. Microdrones

– MD4
- 3000 25. Aibotix X

– 6 125. MikroKopter

– ARF OctoXL 26. AirCover ORT
- 825 126. MLB
- Super
-Bat UAV 27. AirCover QR
-425 127. Multirotor G4 28. Airfield

– Extreme Surfer Power Glider 128. MultiRotor

– G4 Blackbird V2 29. AirRobot AR 100
-B 129. MultiRotor

– G4 Skycrane 30. AirRobot AR 100
- C 130. Parrot

– AR Drone 2 31. AirRobot AR 180 131. ParkZone

– Radian RTF 32. AirRobot AR 200 132. Parrot

– Bebop 33. Airwing UAV

– Talon 133. PrecisionHawk

– LancasterBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 6

34. Align M690L Multicopter 134. Precision Drone

– PaceSetter 35. Altavian Nova F6500 135. Prioria

– Hex 36. Altus UAS Delta X
-4 136. Prioria

– Hex Mini 37. Altus UAS Delta X
- 8 137. Prioria

– Maveric UAS 38. American Drones

– Eagle 550 138. ProJet

– RC Drone 39. American Drones

– Falcon 450 139. ProJet

– RQ
- 11 Raven 40. American Drones

– Nighthawk 550 140. Pulse Aerospace

– Scout B1
- 100 41. American Drones

– Phoenix 650 141. Pulse Aerospace

– Vapor 42. Arch Aerial

– Atlas
- 1 142. RangeVideo

– Jet 43. Arch Aerial

– OCTO 143. RF70 Aircraft 44. ARRI S

– M680 Hexa 144. RIEGL RiCopter 45. Ascending Technologies

– AscTec Falcon 8 145. Ritewing
- Drak 46. Birdseyeview

– FireFly 6 146. Ritewing
- Spade 70" 47. Blade 350 QX3 147. Ritewing
- Zephyr3 Spade 48. Blade Chroma 148. SenseFly eBee 49. Bormatec

– Maja UAV 149. SenseFly – eXom 50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace

– Magpie 51. CarbonCore

– Cortex ARTF 151. Skycatch 52. CineStar

– 6 MK Heavy Lift RTF 152. Sky hunter 53. Cinestar 8 Octo 153. Sky walker X
- 8 54. Cy ber Technology

– Cy

ber Quad 154. Splash Drone 55. Delair
- Tech

– DT

– 18 155. SteadiDrone

– Flare 56. DJI
-F450 156. SteadiDrone

– Mavrik 57. DJI
-F550 157. SteadiDrone

– Vader 58. DJI
- Inspire 1 158. Swift Radioplanes

– Lynx 59. DJI

– Matrice 100 159. T
-Rex 800E Pro 60. DJI
- Phantom 2 160. Tactical Robotics

– InstantEyeMk2 61. DJI
- Phantom 3 161. Tarot

– 450 62. DJI

– Spreading Wings S800 162. Tarot

– 690 63. DJI

– Spreading Wings S900 163. Tarot

– 960 64. DJI

– Spreading Wings S1000 164. Tarot
- 680 Pro 65. DJI

– Spreading Wings S1000+ 165. Tarot

– T18 66. DraganFlyer - Commander 166. Tarot

– T810 67. DraganFlyer - Guardian 167. Tayzu Robotics

– Quadra 68. DraganFlyer - X4
-ES 168. Tayzu Robotics

– Titan X8 69. DraganFlyer - X4
-P 169. TBS Caipirinha V2 70. DraganFlyer
– X6 170. Trimble UX5 71. Event 38
- E384 171. Trimble UX5
-HP 72. Finwing

– Penguin 1720 172. Trimble ZX5 73. FlyPro PX400 173. Turbo Ace

– Cinewing 6 74. FoxTech FPV

– D130 X8 V2 174. Turbo Ace

– Matrix G 75. FoxTech FPV

– K130 V3 175. Turbo Ace

– Matrix I 76. Freefly – Alta 176. Turbo Ace

– Matrix EBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 7

77. GB
-250z 177. Turbo Ace

– Matrix S 78. GB
-450z 178. Turnigy Talon Quad 79. Germap

– G47
-X8 179. UAV Solutions

– Phoenix 30 80. Germap

– G65
-Y6 180. UAV Solutions

– Phoenix 60 81. Germap

– G180 181. UAV Solutions

– Phoenix 60LE 82. Germap

– G212 182. Vanguard Defense Industries ShadowHawk 83. Germap

– SmartOneC 183. Viking UAS

– Patriot X4 84. Gry phon Dy namics

– Dodeca 184. Viking UAS

– Patriot X8 85. Gry phon Dy namics

– Hexa 185. Viking UAS

– Ranger EX 86. Gry phon Dy namics

– Octo 186. Viking UAS

– VikingOne 87. Gry phon Dy namics

– X8 187. Viking UAS
- VK X6 Model 800 88. Gry phon Dy namics

– Y6 188. Volt Aerial Robotics
- Venture 89. Hawkeye 1700 189. Vulcan

– Black Widow 90. Hawk UAS

– Silex Systems F15 190. Vulcan

– Mantis 91. Helipal
- Storm Drone AntiGravity 191. Vulcan

– Raven 92. Helipal
- Storm Drone 4 192. Walkera

– QR X350PRO 93. Helipal
- Storm Drone 4 Mini 193. Walkera

– QR X800 94. Helipal
- Storm Drone 4 Naza 194. Walkera

– QR X900 95. Helipal
- Storm Drone 6 Naza 195. Walkera

– Scout X4 96. Helipal
- Storm Drone 8 Naza V2 196. Walkera

– Tali H500 97. HexaCrafter HC
- 650 197. Walkera

– Vo yager 3 98. HexaCrafter HC
- 800 198. Yamaha RMAX 99. HexaCrafter HC
- 1100 199. Yuneec
- Tornado H920 100. HexaCrafter HO
- 1250 200. Yuneec
- Ty phoon Q500 201. Shotover

– U1 Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. Commercial (Mission, Operation) Purpose: This exemption request, once granted would allow the petitioner to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection, photography and videography o f residential and commercial real estate, weddings , aerial inspection, photography and videography o f utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspecti on and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aeri al surveying, construction site inspection and monitoring, public entity supp ort operations, Aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search andBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 8

rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs , research, risk management and assessment, surface mining, closed set filming2 , disaster and catastrophe events. Regulations from which the Exemption Relief is requested : 14 C.F.R. § 61.113 (a) & (b) 14 C.F.R. § 61.133(a) 14 C.F.R. § 91.7(a) 14 C.F. R.§ 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151 (a) 14 C.F.R. § 91.405 (a) 14 C.F.R. § 407 (a) (1) 14 C.F.R. § 409 (a) (2) 14 C.F.R. § 417 (a) & (b)Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 9

The name and address of the Petitioner : Brad Blosser 10069 County

Road 16 Middlebury, I

N 46540 brad@goshenhealth.com 574.238.1087 Please direct any question or comment regarding this petition to Petitioners Consultant: Brad Blosser 10069 County

Road 16 Middlebury, I

N 46540 brad@goshenhealth.com 574.238.1087 Background The Petitioner, Brad Blosser is a highly accomplished, capable, experienced and trusted professional. Commitment to Safety As part of its commitment to safety and innovation, Brad Blosser is asking for this exemption in part, to reduce the risk of injury to its employees and contractors who participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natural habitat, buildings and other structures within the United States.Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 10

The Exemption Request Brad Blosser proposes the use of the sUAV s will be for capture of high resolution imagery and video of residential or commercial applications and purposes to a level of quality that allows the Petitioner to use the imagery to identify, record, memorialize events and objects ac cording to the purposes noted. The imagery

and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings , aerial inspection, photography and videography o f utility

infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography f or public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools , colleges, professional sports, open air events and fairs research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events. The UAS will be operated by a Brad Blosser and or contracting operators on occasion to capture high
-resolution imagery /video of large structures (wide and tall) such as warehouses, high rise buildings, bridges, and construction sites, as well as “bird ’ s eye” views of fire and explosion sites. Given the small size of the sUAV s involved, no more than 5 5 lbs., majority of the speed of operation be between 5
- 15 mph and the restricted environment within which they will operate, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately
. This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary o f Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion o f the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary i s required to determine which ty pes of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UA S’ size, weight, speed, and operational capability;Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 11

 Operation of the UAS in close proximity to airports and populated areas; and  Operation of the UAS within visual line of sight of the Operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system. ” Id. §333(c) (emphasis added). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

a uthority, by

its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702
-44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC § 44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of commercial operation of aircraft without an FAA issued pilot’s license. Brad Blosser in filing this application is requesting that the FAA combine the grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its Brad Blosser ’s sUAV without the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may b e imposed by the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from other aircraft. Inaddition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained, Brad Blosser requests that operations over congested or densely p opulated areas be allowed. The new sUAV s do have GPS geo
- fencing, it will operate at a very low altitude, within confined areas, at low speed and weighs no more than 55 lbs. Such operations will only

b e under
-taken with the approval of the land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building unless the land owner has provided permiss ion, and the Operator has made a safety assessment of the risk from such operations. Operator Requirements Given the sUAV proposed by Brad Blosser, Operators should not be required to hold a private pilot license. Brad Blosser believes that 1) the operator, instead of understanding how to operate a passenger carrying aircraft, should have knowledge and experience that enables the safe operati on of a small, remotely piloted sUAV should understand airspace restrictions and know how to ensure separation from other aircraft as well as nonparticipants and property; 2) the sUAV has built
- in technical capabilities that limit the potential for unsafe operation and 3) there are other security s creening mechanismsBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 12

already in existence that Brad Blosser will utilize to ensure the operators are acting cons istently

with national security interests. Given the sUAV safety features outlined below, Brad Blosser proposes that its operations under this Exemption request should not be required to hold a commercial or private pilot certification. Instead, Operators should be required to: have completed Brad Blosser ’s training program for operation of the UAS. Brad Blosser notes that 1) the FAA has found that safety factors permitted operation of sUAV s b y Operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present; and 2) that the Notice of Proposed Rulemaking entitled Operation and Certification of Small Unmanned Aircraft Systems, 80 F.R. 9544 (February 2 3, 2015) (“NPRM”), does not require the operator to hold a private pilot license or a third class medical. Advanced sUAV s have a navigation and control system and auto -pilot that allows it to execute very

accurate pre -programed flights. Flights are pre -programmed with GPS way point to establish perimeters beyond which the aircraft will not operate. Flights under auto -pilot are not directed by p ositive manual input, but through pre -programmed flight parameters that are executed by the auto -pilot. Inthe case of unplanned events, the Operator inputs preprogrammed evasive maneuvers from the control unit, and the autopilot executes those maneuvers. Pre
-programmed Operator interventions include : initiation of holding at present position; suspension of mission; fly b ack to launch point; abort mission and land immediately; and emergency p ower cut off and land (flight termination system). Additional automated safety functions and safety enhancing features of the advanced sUAV s may include the following: 1) Auto
-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low power below 10 % triggers an immediate landing, 3) If the auto -pilot detects a lost
- link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute a return to home and land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un- commanded devi ation from the flight path, 5) The aircraft, weighs less than 55 lbs., fully loaded, 6) The motors are driven by pulse width modulated signals , not analog signals, 7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum of 400 fe et AGL. See Federal Aviation Administration, Notice N
- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20
-21 (July 3 0, 2013); As the FAA has determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing theBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 13

requirements for private pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, was sufficient to allow private pilots to operate sUAV s under those exemptions. A handheld radio controller controls the sUAV and the vehicle is operated within the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55
-pound aircraft, operating at less than 30 mph during filming operations are those taught in flight training with the particular UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs and landings at controlled and uncontrolled airports. As to national security

review of pilots, each of Brad Blosser ’s pilots/operators will obtain internally

provided certified training (Ground and Practical) from Brad Blosser to operate the sUAV
. This review and certification could reasonably vet the Operators against any known terrorist or no fly listings that are relevant and publically available. Brad Blosser additionally asks that the exemption be issued without the requirement for a visual observer. As set forth herein, an equivalent level of safety is provided by the size, speed and control capabilities o f the aircraft, as well as the operational procedures that will be applicable to all flight hereunder. These obviate the need for the visual observer. The Operator will be operating the aircraft, always within line of sight. He or she will walk and follow the aircraft around the inspection area so that while it is flying its pre programed and at times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator will not be distracted by viewing the pictures taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances from the launch area will not be necessary as the Operator will always have the aircraft in his or her direct sight. The observer also will not be necessary

b ecause the Operator will conduct a pre - flight inspection of the area, will and if needed, cordon off the area and will perform frequent visual scans of the area while the vehicle is operating. Brad Blosser again notes that the NPRM does not require the use of a visual observer. Given the clear direction in Section 333 of the Reform Act; the authority c ontained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery

p owered sUAVs for these functions instead of turbine or gas powerBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 14

aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant of the requested exemptions is in the public interest. 3

Aircraft and Equivalent Level of Safety The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112, and 112 13 and as recent as 11857. These limitations and conditions to which Brad Blosser (referred to as “Operator”) agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1) Operations authorized by this grant of exemption are limited to the aircraft described in the Operator’s manual, which is a multi
-rotor weighing up to 5 5 pounds. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2) The UA may

not be flown at an indicated airspeed exceeding 30 mph ( 10 mph during inspections). 3) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must b e in feet AGL. 4) The UA must be operated within visual line of sight (VLOS) of the Aircraft Operator at all times. This requires the Aircraft Operator to be able to use human vision unaided by any device other than corrective lenses.

3 Should the FAA determine that it cannot grant such an exemption for operations without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the FAA already has, Brad Blosser will operate its aircraft with pilots holding at least a private pilot certificate issued by the FAA. In that event, Brad Blosser requests that the exemption be granted with conditions similar to those	contained	in	numbered	paragraphs	14
- 15	in	Exemption	11136Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 15 5) The Exemption Holder’s Manuals must be amended to include all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may u pdate or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents if it petitions for an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition for amendment to its exemption. 6) Prior to each flight, the Aircraft Operator must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption Holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption Holder’s Operator’s manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may

not be addressed in the manufacturer’s manuals. 9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of workBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 16 accomplished, and the signature of the authorized technician returning the UAS to service. 10) The authorized technicians must receive and document training referenced in the Exemption Holder’s Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer System and Safety Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancie s discovered between inspections. 13) Prior to commencing operations, the Aircraft Operator shall have logged at least 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA ty pe and 5 hours in the make and model. 14) If the UAS loses communications or loses its GPS signal, the UA must return to a pre - determined location within the private or controlled
- access property and land or be recovered in accordance with the Exemption Holder’s Manuals. 15) The Aircraft Op erator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption Holder’s Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the exempti on must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N
- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be madeBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 17 available to the Administrator or any law enforcement official upon request. 20) The UA must remain clear and yi eld the right of way to all other manned operations and activities at all times (including, but not limited to, ultra
- light vehicles, parachute activities, parasailing activities, hang gliders, etc.). 21) The UA may

not be operated by

the Aircraft Operator from any moving device or vehicle. 22) UAS operations may not be conducted during night, as defined in 14 CFR 1.1. 23) All operations must be conducted under visual meteorological conditions (VMC). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally f rom a cloud or when visibility is less than 3 statute miles from the Operator. 24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA
published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required by the Operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 25) The UA may

not be operated over congested or densely p opulated areas unless the conditions set for in #26 are satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1). 26) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations must cease immediately and/or;Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 18 b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of the risk of operating closer to those objects and;
c. Operations near the Aircraft Operator do not present an undue hazard to the Operator per § 91.119(a). 27) All operations shall be conducted over private or controlled
- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS
- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
. Specific Uses Public Benefits Brad Blosser proposes use of its sUAV provided equivalent or augmented levels of safety for each of the uses proposed herein: The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are now conducted by either a person wading through swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or otherwise hazardous or by the use of conventional aircraft. The current procedures can result in significant injuries to the people who must climb on the roofs or require the use of aircraft that are orders of magnitude greater in size than the sUAV
. Either method, manual inspection or large conventional aircraft, results in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those undertaken with a sUAV
. The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site because the aircraft must be flown to and from the site. By

c ontrast, the sUAV is carried to the site and transits no other property.Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 19

Conventional aircraft carry f lammable fuels that are not carried by the UAS and emit pollutants associated with inter nal combustion engines. The sUAV s proposed herein are battery powered and have no emissions. Equivalent Level of Safety 14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command; Section 61.113(a) & (b) limit private pilots to non- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, Brad Blosser ’s sUAV is remotely c ontrolled with no passengers or property o f others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Brad Blosser respectfully proposes that Operator requirements should take into account the characteristics of the particular UAS. Brad Blosser ’s sUAV has a high degree of pre programmed control and various built
- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. Brad Blosser ’s sUAV has navigation and control system comprised of a Ground Control Station (GCS) and auto -pilot system that can be pre -programmed to set operational boundaries
. All flights are pre -programmed with precision GPS guidance
. In the case of unplanned events, the Operator may input pre -programmed evas ive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre
-programmed Operator interventions include initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immedi ately; and emergency

power cut off and land (Flight Termination System). Additional automated safety f unctions and safety

enhancing features of Brad Blosser ’s sUAV s may include the following: 1.1. Auto
-pilot detection of lost GPS or of insuf ficient satellites initiates an immediate landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low power below 10% triggers an immediate landing. 1.3. If the auto -pilot detects a lost
- link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute a return to home and land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un- commanded deviation from the flight path. 1.5. The aircraft, weighs less than 5 5 lbs., fully loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum of 400 AGL.Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 20

Given these safety features, Brad Blosser proposes that the sUAV should not be required to hold a commercial or private pilot certification. Brad Blosser notes that the FAA has found that safety factors permitted operation of UASs by Operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Federal Aviation Administration, Notice N
- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20
-21 (July 30, 2013). Likewise, Brad Blosser notes that the NPRM does not require that the Operator hold a private pilot license issued by the FAA. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the Brad Blosser ’s sUAV without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein. The risks associated with the operation of the Brad Blosser ’s sUAV (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a). 14 C.F.R. § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by

insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helic opters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by

the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 4 00 AGL, an exemption may be needed to allow such operations.Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 21

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner, facility

owner, and/or local officials. Because of the advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by

c onventional aircraft operating at or below 500 AGLin the aerial photography industry
. Inaddition, the low
- altitude operations of the sUAS will ensure separation between these small
-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110. 14 C.F.R. §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 appropriate altimeter setting available before departure.” As Brad Blosser ’s sUAV , in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) 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 40 minutes of powered flight. To meet the 30
-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UA S’ proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight is reasonable. Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only p eople and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does notBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 22

engender the ty

pe of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Petitioner believes that an equivalent level of saf ety can be achieved by

limiting flights to 30 minutes or 25% of remaining battery p ower whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from any where in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110. 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (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 to the Petitioner
. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits an equivalent level of safety will be achieved because the se small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy c ondition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 11110.
********* Federal Register Publication Pursuant to 14 C.F.R. Part 11, the following summary i s provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules: 14 C.F.R. §§ 6 1.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 23

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control , aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually

or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs , research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events. Privacy and National Security All flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Inspection will be of inanimate objects in areas where the owners will have consented to the inspections or otherwise have agreed to allow the UAS and the Operator to be in the area where operations will take place. The size of the UAS, its speed and restricted area of operation do not raise national security issues. Summary Approval of exemptions allowing commercial operations of sUAV s for petitioner to operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility
-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control , aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority o fficials, aerial video and photography f or public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to incre ase awareness and improve safety for current and future UAS operations within the NAS , special events: including high schools. colleges, professionalBrad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 24

sports, open air events and fairs , research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events , will enhance safety b y reducing risk. Conventional operations, using jet or piston powered aircraft, ladders or placing people in swamps, on roofs or tall, hazardous or weakened structure s, exposes them to higher risks than those created by

use of a sUAVs . Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly

to and from the project location. Inc ontrast, a sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weighing less than 5 5 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people or the use of individuals to climb the structures to conduct the operations
. Satisfaction of the criteria provided in Section 333 o f the Reform Act of 2012

–size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Petitioner ’s UAS for the Purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11 171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely, Brad Blosser 10069 County

Road 16 Middlebury, I

N 46540 brad@goshenhealth.com 574.238.1087Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087 Page 25