U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request Pursuant to Section 333 of the F AA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviat ion Regulations Dear Sir or Madam: We the undersigned of Air CAV Global Corporation are submitti ng this Petition for Section 333 exemption under Section 333 of the F AA Modernization and Reform Act of 2012 (“FMRA”).
Applicant Information: The name of the applicant: Air CAV Global Corp
. The primary contact fo r this application, is:
Robert Willis - CEO AirCAV Global Corporation P.O. Box 350514 Jacksonville, FL 32235 Air CAV Global is a corporation formed under the State laws of Florida on or about January 15, 2016 and Robert Willis is an Officer and Chief Exec utive Officer of Air CAV Global. Pursuant to Section 333 of the FMRA, Air CAV Global Corp . hereby requests a determination by the Secretary of Transportation authorizing co mmercial operations of UAS for the purposes of aerial phot ography & videography, mappin g, power line surveillance, agricultural crop surveillance, aerial inspections, data collec tion, augmented real estate listings, commercial videos and other work related to aerial photography in the NAS. Air CAV Global Corp. does not intend to use for closed set filming. Flight op erations will utilize the off the shelf DJI family of unmanned aircraft. Conduct of UA operations will be with respect to FMRA Section 333(c) and the UAS “Blanket COA”.Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. The attached documentation includ es detailed exemption requests that demonstrate how these exemptions are in the public int erest and will maintain at leas t an equal level of safety to existing regulations. Authorizing Air CA V Global Corp. to conduct commer cial UAS operations will result in less disruptive, safer, and more cost effective solu tions than manned aviation equivalents due to the low altitude environment, given the size , speed and inherent risk of traditional commercial helicopter operations. These commercial operations often occur in the unsafe areas of the height-veloc ity diagram requiring special p recision and skill. Air CAV Global Corp. will conduct the commercia l UAS operation in a manner tha t will meet, and in many cases exceed, the current level of safety of commercial helicopter op erations. UA that are under 10 lbs., have a low noise signature, and carry no volatile fuel , will limit collateral damage in the event of catastrophic failure. The low expense of operation com pared to cost proh ibitive manned aviation alternatives allow a gre ater economic benefit to busin esses. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interes t. UAS technology used for these commercial purposes benefit the public interest in the fo llowing ways:

 Reduces the collateral damage risks to life and property as sociated with low altitude helicopter operations in undesira ble portions of the height-vel ocity envelope.

 Increased economic wellbeing t o local businesses via cost r eductions.

 Enabling aerial business solutions to be available to a larger market.

 Reduce risks to personal sa fety by lessening personal expos ure to high risk environments such power line towers, cellular towe rs, infrastructure where inspec tion woul otherwise require a person to expose themselves to extreme heights or pote ntially dangerou s conditions.

### Table of Contents I. Exemptions Requested II. Commercial Operation/Operator III. Unmanned Aircraft System (UAS) IV. UAS Pilot-in-Command (PIC) V. Public Interest VI. Summary VII. List of Attachments I. Exemptions Requested Pursuant to 14 C.F.R. § 11.81(e), Air CAV Global Corp. requests exemption from the following regulations:

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates o Establishes: The procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 91.203(a) (1) Given the small size of the UA an d the safeguards that will be taken as outline below, an exemption from Part 21 Subpart H m eets the requirements of an e quivalent level of safety under Part 11 and Section 333 of t he FMRA with consideration “o f the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS.”

 14 C.F.R. § 45.23(b) – Aircraft Mar king and Identification Requ irements o When marks include only the Roman capital letter "N" and the registration number is display ed on limited, restricted o r light-sport category aircraft or experimental or pro visionally certificated aircraf t, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "expe rimental," or "provisional," a s applicable. Air CAV Global Corp. will ensure compliance with § 45.29(f) to meet the intent of the regulation by displaying the regis tration number in the largest practicable lettering.

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recr eational, Private and Commercial Pilot Privilege and Limitationso 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a private pilot certi ficate may act as pilot in command of an aircraft that i s carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A pr ivate pilot may, for compensati on or hire, act as pilot in command of an air craft in connection with any busin ess or employment

o 14 C.F.R. § 61.133 : (a) Privileges – (1) General. A person who holds a commercial pilot certificate may act as pilot in command of a n aircraft – (ii) For compensation or hire, provided the person is qualified in accor dance with this part and with the applicable parts of this chapter that apply to the operation. o 14 C.F.R. § 61.101 : (a) A person who holds a recreational pilot certificate may not act as pilot i n command of an aircraft:

 For compensation or hire;

 In furtherance of a business; UA operations will employ a PIC wh o holds, at a minimum, a recr eational or sport pilot certificate of any category or class and a valid driver’s licen se.

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness o No person may operate a civil ai rcraft unless it is in an airwo rthy condition. The PIC will conduct daily pre and post flight inspect ions in accordance with manufactures maintenance manual(s ) and guidance. During flight, the PIC will adhere to § 91.7(b) and abort air ope rations immediately upon ide ntification of an in-flight emergency or other unsafe cond ition. By complying with procedur es outlined by the manufacturer, an equivalent leve l of safety will be achieved.

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and pl acard requirements o (b)(2) prohibits operation of U.S .-registered civil aircraft un less there is available in the aircraft a curr ent approved Airplane or Rotorc raft Flight Manual, approved manual mate rial, markings, and placards, or any combin ation thereof. By keeping all operating documents , manuals, authorizations and exemptions in a binder co-located with the GCS, Air CAV Global Corp. meet the intent o f the regulations and therefore achieve an equivalent level of safety.

 14 C.F.R. 91.109(a) – Flight Instruction o No person may operate a civil airc raft (except a manned free ba lloon) that is being used for flight instructi on unless that aircraft has full y functioning dualcontrols. The majority of sUAS by design are developed with single operat ional control through the use of pre-determined GPS enabled waypoints programmed befo re or during flight in addition to the use of a single hand held transmitter or contro l station controlled by the PIC. The design does not allow for dual controls during flight training and therefore the exemption is requested to train operators, build experience, an d maintain proficiency. An equal level of safety will be ac hieved by conducting all traini ng in sterile environments. Training sessions will be accomplished separately f rom flights conducted for compensation or hire.

 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes o Except when necessary for takeoff or landing, no person may ope rate an aircraft below the following alti tudes: (b) Over any congested area of a city, town, or settlement, or over an y open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radiu s of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet ab ove the surface, except over open water or sparsely populated areas. In those ca ses, the aircraft may not be operated closer than 500 feet to any perso n, vessel, vehicle, or structure. (d) Helicopters, pow ered parachutes, and weight-shif t-control aircraft. If the operation is conducted without hazard to persons or propert y on the surface— (1) A helicopter may be opera ted at less than the min imums prescribed in paragraph (b) or (c) of this sec tion, provided each person oper ating the helicopter complies with any routes or altit udes specifically prescribed f or helicopters by the FAA. Commercial UAS opera tions will be conducted at or below the maximum altitude authorized by COA. Given the size, weight and lack of fuel; combined with operation limitations listed below, the operation will be conducted with a greater level of safety than exists with current m anned aviation operations.

 14 C.F.R. 91.121 – Altimeter Settings Each person operating an aircraft shall maintain the cruising a ltitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating... SUAS are equipped with Global Positioning System (GPS), which p rovide altitude and geolocation data to the operator without utilizing an altimeter. D ue to this fact, an exemption is required. GPS are precise within a few feet and combined with f ail-safes and a visual observer the operation will meet an equivalent level of safety.

 14 C.F.R. 91.151(a) – Fuel Requirem ents for Flight in VFR Condi tionso No person may begin 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; This regulation is written based on the capabilities of a tradi tional aircraft, which have flight times of several hours or greater; therefore, with the m ajority of sUAS which have flight times of only an hour or less, this regulation would eff ectively deny the ability of the air vehicle to operate. The PIC will achieve an equivalent level of safety by complying with all manufacturer guidelines and the DJI low b attery failsafe system.

 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Eq uipment and Use. o All airspace. Unless otherwise authorized or directed by ATC, n o person may operate an aircraft in the a irspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mo de S capability, replying to Mode 3/A interrogati ons with the code specified by ATC and intermode and Mode S interrogation s in accordance with the appl icable provisions specified in TSO C-112, and that aircraft is equipped wi th automatic pressure altitude re porting equipment hav ing a Mode C capabili ty that automatically replies to Mode C i nterrogations by transmitting pressure altitude information in 100-foot increme nts. This requirement applies— (1) All aircraft. In Class A, Cla ss B, and Class C airspace are as; (2) All aircraft. In all airspace within 30 nautical miles of a n airport listed in appendix D, section 1 of this partfrom the surface upward to 1 0,000 feet MSL; (3) Notwithstanding paragraph (b )(2) of this section, any aircr aft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed, ballo on or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted— (i) Outside any Class A, Class B, or Class C airspace area; and (ii) Below the altitude of the ceiling of a Class B or Class C airspace areadesignated for an airport or 10,000 f eet MSL, whichever is lowe r; and (4) All aircraft in all airspace above the ceiling and within t he lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and (5) All aircraft except any airc raft which was not originally c ertificated with an engine-driven electrical system or which has not subsequently b een certified with such a system instal led, balloon, or glider— (i) In all airspace of the 48 c ontiguous states and the Distric t of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,50 0 feet above the surface; and (ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile radius of any airport listed in appendix D, section 2 of this p art, excluding the airspace below 1,200 feet outsi de of the lateral boundaries of the surface area of the airspace designat ed for that airport. The sUAS to be used in the proposed operation does no t come equipped with a transponder. No transponder exists for the sUAS, which can be i nstalled. The petitioner requests relief from the exempti on to the extent required to op erate in areas in which a transponder is required accordi ng the applicable regulations inthis part. The PIC will achieve an equivale nt level of safety by complying with all provisions of the COA under which operations a re to be conducted. By issuing appropriate NOTAMS and prior ATO coordination, an e quivalent level of safety can b e achieved as other manned aircraft, which receive authorization to fly in airspace where a transponder is required but not operable. In or der to give proper notice to th e ATO, the PIC will comply with the provisions of 91.215(d)(3 ). The sUAS flown under this exemption will comply with all altitude limits and airp ort standoff distances require d by COA, which mitigate hazards to aircraft controlle d by the ATO in congested airspace

.

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance Inspections o 91.405(a) States : Each owner or operator of an aircraft—(a) Shall have that aircraft inspected as pr escribed in subpart E of this part and shall between required inspections, exce pt as provided in paragraph ( c) of this section, have discrepancies re paired as prescribed in part 43 o f this chapter o 91.407(a)(1) States : (a) No person may operate any aircraft that hasundergone maintenance, preventive maintenance, rebuilding, or a lteration unless— (1) It has been approved for retur n to service by a person auth orized under § 43.7 of this chapter o 91.409(a)(2) States: (a) Except as provided in para graph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had—(2) An inspection for the issuance of an airworthine ss certificate in accordance with part 21 of this chapter. No inspection performe d under paragraph (b) of this section may be substituted for any inspect ion required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ‘‘annual’’ inspection in the r equired maintenance records. o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this sect ion: (paragraphs 1 (i – iii), 2 (i – vi)); (b) The owne r or operator shall retain the following records for the periods prescribed: (paragraphs 1 – 3) The PIC will conduct Pre/Post fli ght inspections and maintenanc e in accordance with the manufacturer’s guidance as stated in the operations manual. If maintenance is required, the PIC will conduct a dedicated test flight w h i c h will be cond ucted to ensure safety before resuming commercial ope rations. All inspection, maintenance and alterations will be documented and maintained in a record. These act ions will meet the intent of the regulations from which ex emption is being requested and lead to an equivalent level of safety.
II. Commercial Operator/Operation Any UA flown under this exemption will be controlled by a certi ficated PIC. The PIC will hold, at a minimum, a recreational or sport pilot certificate. For each flight, Air CAV Global Corp.:
 Will contact the controlli ng air traffic organization to is sue a NOTAM.

 Will conduct a comprehensive w orksite inspection and analys is, identifying limits of customer property or authorized access areas.

 Will conduct preflight planni ng in accordance with Section 91.103 Preflight Action.
 Will operate in those areas only with the consent of the landowner or designated representative.

 Will identify potential obstructions or other hazards to sa fe operation.
 Will clear the area of pers onnel or bystande rs that are non -essential to the operation, maintaining at a minimum, 500 feet away from non-par ticipating persons.

 Will conduct a preflight safety briefing to Visual Observer (VO) andparticipating persons.

 Will at all times yield to manned air traffic.
 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communicatio ns with VO and participatin g persons.
 Will operate under visual fli ght rules, in visual meteorolo gical conditions, for the airspace in which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA under which flight authorized, as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder co- located with the GCS.
 Will immediately terminate fl ight, in the safest manner pos sible, when safety to persons or property become compromised.
 Will terminate flight, in the safest manner possible, when unable to comply with these limitations or any other lim itations granted as part of this exemption. In order to remain at an altitude at or below the attitude pres cribed by the applicable COA, relief is needed from Section 91.119 (c). By following these operating st andards, the commercial operation will meet an equivalent level of safety to the regula tion in which relief is sought.
III. Unmanned Aircraft System Air CAV Global Corp. seeks exemption to operate DJI UAS. Other UAS types may be requested in future amendments. The DJI Matrice 100 is the prim ary aircraft in our operation for which we seek exemption. The UA will be flown via a combin ation of RC control and tablet GCS. This UA type is a GPS equipped, multirotor helicopt er. A quad-copter type rotorcraft utilizing four motors . Lithium-polymer batteries pow er the UA. The UA also has several fail-saf es for loss of RC signal, loss of GPS, and low battery as outlined in the respective Operation Manuals. The UA display visual and emit an audible low battery alerts at which time the UA will automatically engage the landi ng sequence. Based upon those safeguards, I request exemption from Section 91.151(b) Fuel req uirements for flight in VFR conditions. Given the size, weight, speed, and controlled operating area as sociated with the UA to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworth iness Certificates) and § 91.203 (a) and (b) is requested. Exemption is sought from § 45. 23 Marking of the aircraft. The UA will display the registration number in the largest practicable lettering. Air CAV Global Corp. seeks to be exempt from § 91.405(a), 91.407(a)(1), 91.409 (a)(2) and 91.417(a) and (b) Maintenance inspections will be conducted according to operations manual and prudent judgment as previously outlined to determine the integrity and safety of the UA and associatedequipment. Further, relief is required from 91.7(a), which proh ibits the operation of an aircraft without an airworthiness certi ficate and 91.9(b) (2) requiring an approved flight manual in the aircraft. The UA will not be operating with an airworthiness ce rtificate therefore, this would be inappropriate. The UAS are too small to carry the operating doc uments so an equivalent amount of safety can be achieved thr ough keeping the operating documen ts and manuals at the GCS.
IV. UAS Pi l ot in Command (PIC) Under part § 61, recreational, sport and private pilots are lim ited to non-commercial operations, however Air CAV Global Corp. can ensure UA operations will achi eve an equivalent level of safety as current regulation be cause UA do not carry any pilots or passengers. A commercial pilot certificate will not ensure RC p iloting ability, as the psychom otor skills are different. The inherent risks of operating a UAS are far less than in the comm ercial activities outlined in 14 CFR part 61, et seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges and Limitations. PICs will maintain recent flight experience on the UAS. Training and experience flights will be conduct ed separate from commercial o perations.
V. Public Interest Given the above stated evidence, procedures, and precautions op erating UAS commercially for the purposes of aerial phot ography & videography, mappin g, power line surveillance, agricultural crop surveillance, aerial inspections, data collec tion, augmented real estate listings, commercial videos and other work related to aerial photography will ultimately be in the public interest. These operations, when e xecuted with prudence, will e xceed the current level of safety as the regulations from which exemption is sought. UA operation s will allow greater access to commercial aerial services that were not previously economicall y feasible for many firms. This will provide a muc h needed economic uplift to the comm unity and hence the public. UA operations are associated with less risk of collateral damage t o persons and property while limiting disruptive noise polluti on associated with low altitud e aviation operations. VI. Summary Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform Act of 2012”, Air CAV Global Corp., hereby applies for authorization to conduct commercial unmanned aerial system s (UAS) operations for the pur poses of aerial photography & videography, mapping, power line surveillance, agricultural cro p surveillance, aerial inspections, data collection, augmented real estate listings, commercial vid eos and other work related to aerial photography listings Rules f or which exemption is sought :

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b) 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)
 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103
 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119
 14 C.F.R. § 91.121
 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.215(b)
 14 C.F.R. § 91.405(a)
 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

Thank you for your prompt attent ion and consideration. Air CA V Global and its clients are committed to safe UAS operation and ambas sadors. Please do no t hesitate to con tact me directly with any questions or concerns at 904-405-5137. Very truly yours, Air CAV Global Corp. Robert Willis Chief Executive Officer