### Ernest Paul Eich, IV

3535 Keith Drive Charlotte, NC 28269

November 23 , 2015

US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition of Ernest Paul Eich, IV

For an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Those Who See this Petition:

As Described in Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, I

– Ernest Paul Ei ch, IV

– do hereby apply for an exemption from the Federal Aviation Regulations (“FARs) identified below, to allow commercial operations of small unmanned aircraft and associated elements (“UAS”).

The Exemption is made based on information in the petitio n, as well as Petitioner’s General Operations and Safety Manual (“Op eration s Manual”) . Petitioner submits these supporting materials as confidential commercial a nd proprietary information that Petitioner has

not an d will not share with others. Similarly, t hese documents contain operational conditions and procedures that are not available to the public and are protected from release under the Freedom

of Information Act, 5 U.S.C. Section 552 et seq. and and other requirements established by the FAA pursuant to Section 333 of the FAA Reform Act.

Sections descriptions:

I. Description of Petitioner II. Types of Operations

III. Relevant Statutory Authority IV. Petitioner’s proposed operat ions meet the requirements of Section 333 of the Reform Act

V. Regulations from which Exemption is Requested

V I. Public Interest



### VI I. P rivacy

VIII . F ederal Register Summary

I X

. C onclusion

### I. **Description of Petitioner**

Ernest P. Eich, IV is a filmmaker and sole proprietor of a film production, special event,

and theater support business. He has previous flight training and is currently working toward a private helicopter pilot license under training from an FAA Certified Flight Instructor.

Petitioner seeks an exemption to use UASs to conduct operations offering services to film production companies and independent film makers, real estate brokers and developers, the construction industry, utilities and utility maintain ers, first responders, scientific research organizations, churches and other houses of faith, municipalities and other government entities,

non

- profit organizations, entertainment companies, and any other entities that can utilize the safe

and convenient o peration of UAS type aircraft where the use of typical certified aircraft is not possible or the cost is prohibitive.

Petitioner intends to use several models of UAS, any of which will weigh 55 pounds or less and conform to guidelines as updated and publ ished by the FAA or other relevant authority

. Initially, the DJI Phantom 3 Professional UAS will be utilized. Additionally, DJI Inspire series UAS, DJI Spreading Wings, and Typhoon Q 500 4K systems

, as well as other commercially

available UAS platforms

, will be acquired and operated as appropriate to the business and flight operation needs. All UAS systems will be commercially available, complete systems with FCC approved control systems. Any UAS operated for commercial purposes under the exemptions requested herein will be registered with the FAA and display the assigned N

- number for that

UAS on the fuselage

.

The contact information for Petitioner is as follows:

Ernest Eich

3535 Keith Drive Charlotte, NC 28269

Tel 1

- 970

- 708

- 9561

Email : e rnest peich@gmail.com

**II. Types of Operations**

Petitioner requests permission to operate UAS vehicles for support of film production companies and ind ependent film makers, real estate brokers and developers, the construction industry, utilities and utility maintainers, first responders, scientific research organizations, churches and other houses of faith, municipalities and other government entities, n on

- profit organizations, entertainment companies, and other entities that may be interested in the services provided by UAS vehicles carrying visual cameras and other sensor systems.

As set forth in the attached Op eration s Manual, flights by Petitioner will be conducted

u n der a strict set of guidel ines. UAS vehicles will be flown over Petitioner’s property, or property where permission has been obtained from the owner

, and where adjacent and area properties have been notified by posted signage by propert y owner informing of UAS operations,

### and in areas designated as UAS friendly fly zones, and not in areas designated by authorities as

no

- fly zones. Knowledge of and adherence to local ordinances related to the operation of UAS vehicles will be paramount to all flight operations. Strict safety measures will be in place to ensure that there is limited to no risk to members of the public who are not involved in the operation.

**III. Relevant Statutory Authority** 

This petition for exemption is submitted in accordance with Section 333(a) through (c) of

the FAA Modernization and Reform Act of 2012. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.”

Within Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS where it is safe to do so based upon the following considerations:

- The UAS vehicle’s size, weight, speed, and operational capability;

- Operation of the UAS in close proximity to airports, stadiums, and populated areas;

- Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency’s safety regulations and minimu m standards when the Administrator decides that a requested exemption is in the public’s interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely

affect safet y (or how it would provide a level of safety at least equal to the existing rules). With the FAA’s publicly available information, the petitioner offers this submission for Request of Exemptions to the FAA Rules as noted.

**IV. Petitioner’s proposed operat ions meet the requirements of Section 333 of the Reform** 

**Act**

The proposed operations in this Petition for Exemption qualify for approval under

Secti on 333 of the Reform Act; ea ch of the statutory criteria and other relevant factors are

satisfied:

A. Approva l is Warranted Based on the UAS’s Size, Weight, and Operational Capability

Petitioner will employ the UAS vehicles identified in Section 2 of the accompanying Operations Manual. These UAS vehicles will be used for all of the operations as set forth in th e Operations Manual, each of which has characteristics in common that warrant approval. All of the UAS vehicles will be limited to a maximum flight speed of 4 0 mph , ve rtical ascent speed of 15 mph , and a maximum weight of fifty (50) pounds.

Each of the U AS vehicles has an integrated GPS system to calculate its position and height and to relay that information via a secure connection to the operator. In addition, each UAS contains a failsafe mode that will guide the UAS if its connection to

### the remote cont roller is lost. The system permits the vehicle to return to a predetermined location and land in order to prevent injury or property damage.

B. Approval is Warranted Based on the Operational Restrictions set forth in the Operations Manual

Petitioner’s Oper ations Manual and the manufacturers’ maintenance and flight manuals contain all of the procedures and limitations necessary to successfully and safely

per form commercial flight operations. To assist the reviewer in its safety assessment of Petitioner’s ope rations, the operational limitations and conditions, listed below, will be adhered to. This will ensure a level of safety equal to or exceeding the level of safety for operations conducted under current regulatory guidelines:

1. The UAS vehicles employed by Petitioner will weigh fifty (50) pounds or less.

2. Flights will be operated within line of sight of a pilot and an observer.

3. Maximum total flight time for each operational flight will be limited to the amount of

time the UAS can be flown and still maintain a reserve battery power of no less than

25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not be conducted within navigable airspace. Flight will be conducted only in VLOS during daylight hours and in VFR conditions.

5. Flights will be operated at a lateral distance of no less than 100 feet from any persons or property not associated with the operation who have not given prior permission for more proximate operation.

6. Flights will be limited to a speed of 40 mph and vertical asce nt of 15 mph

7. Minimum crew for each operation will consist of the UAS pilot

- in

- command (“PIC”), one or more visual observers, as necessary to safely conduct the mission, and a sensor operator, if the sensor requires human direction or control.

8. The PIC will have at least a private pilot’s license and current Class III medical certificate and will have sufficient experience and recurrent training to safely conduct the flight in accordance with the standards set forth in the Operations Manual.

9. The observer desi gnated for any operation will be in constant voice contact with the

PIC.

10. UAS vehicles will operate in accordance with the safety and operational requirements of their respective Manuals.

11. Prior to the operation, a mission plan will be prepared setting forth the limitations for the flight as well as relevant contact and hazard information.

12. All required permissions and permits will be obtained from the FAA, Federal Agencies, territorial, state, county or city jurisdictions, including local law enforcement, se arch and rescue, fire or other appropriate governmental agencies.

13. The operator will coordinate all flights as required/requested by the appropriate Flight

Standards District Office including issuance of NOTAM as required

. 14. If a UAS loses communications or has other operational issues that pose sa fety issues, it will have the capability to autonomously return to a pre

- determined location within the operational area and land.

### 15. Contingency plans will be in place to safely terminate flight operations if there is a

loss of communication between the PIC and the observer(s).

**V. Regulations from which Exemption is Requested** 

The Petitioner requests e xemption from a variety of regulations and standards

, and offers solutions to exceed or meet the safety considerations of the FAA regarding integration of UAS vehicles with the national airspace.

The Federal Aviation Act grants the FAA the authority to issue exemptions from Code of Federal Regulations from its safety regulations and minimum standards when the Administrator decides that a requested exe mption is in the public interest. The Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of

c onducting the requested operations using a UAS. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought.

A. 14 C.F.R. Part 21, Subpart H

– Air worthiness Certificates and 14 C.F.R. § 91.203(a)(1) The Petitioner does not intend to employ UAS systems that do not readily meet the requirements of the Reform Act. Also, maintaining documents on board a UAS could serve to decrease safety. As such, an e xem ption is requested for these rules with the described procedures to maintain safe operations:

**Equivalent Level of Safety**

The UASs identified in Section 2 of the Operations Manual are safe when taking into account their size, weight, speed, and operational capability. As set forth in Section II, each of the UASs weigh s less than 50 pounds and will be flown at less than 40 mil es per hour and completely outside controlled airspace. Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials and/or flammable liquid fuels, and operate exclusively within the parameters stated in the Operations Manual.

Operations under this exemption will be closely controlled and monitored by the operator and will be conducted in compliance with local public safety requirements to provide security for the area of operation. Petitioner will also provide the FAA with advance notice of all operations if requested/required through communication with the local Flight Standards District Office or as otherwise stipulated. In all cases, the UASs operated under the proposed conditions, will be at least as safe as, or safer th an conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

The aircrafts themselves do not need a means to communicate with other aircraft or ATC, because those capabiliti es will be possessed by the PIC and observer(s) who are not onboard. In addition, no “sense and avoid” technology is necessary on the UAS because it will be operated at all times by visual line

- of

- sight.

### B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent the Petitioner's UAS vehicles would otherwise require

certification under Part 27, Petitioner seeks a n exemption from Part 27's airworthiness standards

for the same reasons identified in the request for exemption from 14 C.F.R. Part 21

, Subpart H

.

C. 14 C.F.R. § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Petitioner seeks an exemption from the aircraft marking and identification requirements

contained in 14 C.F

. R. § 91.9(c)

, 45

. 23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c) (Civil Aircraft Flight Manual, Marking and Placard requirements), provides that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is

identified in accordance with Part 45 of this chapter.

• 14 C.F.R. § 45.23(b) (Markings of the Aircraft), states:

When marks include only the Roman capital letter "N" and the r egistration

number is displayed on limited

, restricted or light

- sport category aircraft or experimental

or provisionally certificated aircraft, 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

, "experimental," or "provisional

, " as applicable.

• 14 C.F.R. § 45.27(a) (Rotorcraft) states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both

surfaces of the cabin, fuselage

, boom

, or tail the marks required by§ 45.23.

In a previous Grant of Exemption

, the FAA determined that exemption from the s e requirements were warranted provided that the aircraft "have identification (N

- Number) markings in accordance with 14 CFR Part 45, Subpart C if the markings are as large as practicable."

**Equivalent Level of Safety**

Petitioner will mark all aircraft with their N

- Number in a prominent spot on the fuselage with markings that are as large as practicable.

### D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R

. § 91.9(b)(2):(b)

No person may operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual i s required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual

, approv ed manual material

, markings

, and placards

, or any combination

thereof.

Pursuant to 14 C.F.R

. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unle ss it has

within it the following: ( 1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required

b y paragraph ( a) of this section or a special flight authorization issued under § 91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Petitioner request s an exemption from thi s section , and requests that compliance with the intent of this regulation be deemed met with the UAS flight manual

, registration certificate and

other d ocumentation kept at the control station with the PIC during flight. The Ch i ef Counsel's

Office has held that for all UAS operations

, thi s alternate method constitutes full compliance

with the regulations.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exe mption from 14 C.F.R. 

### § 91.7(a), which requires that a civ il aircraft be in airworthy condition to be operat e d. The FAA has stated that no exemption is required to the extent

that the requirements of Part 21 are waived or found inapplicable

. Accordingly

, Petitioner requests
that the requirements for Section 91. 7 (a) be treated in accordance with Section V(A) of this Petition.

F. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103

, which requir es a PIC to becom e familiar with specific information before each flight, including information contained in the FAA

approved Flight Manual on board the aircraft. While the PIC will be familiar with all information

necessary to safely conduct the flight

, an exemption is requested to the extent that an FAA

- approved Flight manual is required

.

**Equivalent Level of Safety**

An equivalent level of safety will be provided by following th e Aircraft Operations Manual and flight manual provided by the manufacturer. The PIC will take all required preflight actions

, includingperforming all required checklists and reviewing weather, flight requirements

, battery charge

, landing and takeoff distance, aircraft perform ance data

, and contingency landing areas

- before initiation of flight. The Operations Manual and manufacturer's flight manual will be kept at the ground station with the operator
at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F

. R. 

### § 91.109(a), which provides that "[n]o 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." UAS vehicles an d remotely piloted aircraft, by their design

, do not have functional dual controls. Instead

, flight control is accomplished through the use of a device

that communicates with the aircraft via radio communications.

**Equivalent Level of Safety**

Given the size and speed of the UAS employed by Petitioner

, an equivalent level of safe training

can still be performed without dual controls because no pilot or passengers are aboard the UAS, and all

persons will be a safe distance away in the event that the UAS experiences any difficulties during flight

instruction. In addition

, Petitioner will conduct flight training at its own property or other controlled sites,

which locations are shown in the Operations Manual. These training flights will be conducted in a st erile

, safe area and will otherwise comply with the provisions in the Operations Manual for flights at a controlled facility. Accordingly

, Petitioner's proposed method of operation provides superior levels of safety required by the FAA. In addition

, all UAS operations will be conducted by an experienced FAA certificated private helicopter pilot with a minimum of a Class Ill medical certificate.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements required by 14

C.F.R. 

### § 91.119. Section 91.119 prescribes the minimum safe altitudes under which an aircraft may not

operate

, including 500 feet above the surface and away from any person
, vessel

, vehicle

, or structure in

non

- congested areas. See 14 C

. F .R. 

### § 91.119( c)

. Section 91.119( d) allows for a helicopter to operate at

less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operatin g the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

**Equivalent Level of Safety**

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is

far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size

, weight

, and speed of the UAS vehicles

, as well as the location where it is operated. In order to avoid any risk to aircraft

, flight operations will be restricted to 400' AGL from the highest point in the operational area or below. As set forth in the Operation Manual

, the UAS

vehicles will be operated in a restricted area, away from persons or structures not involved in the operation. All UAS operations will be conducted by at least a FAA certificated private helicopter pilot.

I. 14 C.F.R. 

### § 91.121: Altimeter SettingsPetitioner seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the

elevation of the departure airport or barometric pressure. An exemption is required to the extent that

the UAS vehicles do not have a barometric altimeter, but rather a G PS altitude read out, and that the point of departure and landing are unlikely to be an Airport.

**Equivalent Level of Safety**

As the attached Ope rations Manual indicates, the chosen UAS vehicles meet these requirements

, and

a zero altitude initiation point will be obtained prior to flight. Information equivalent or superior to

Altimeter information is relayed in real time to the operator, including location and orientation of the aircraft portion of the UAS.



### J. 14 C.F.R. 

### § 91.l5 l(a): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.F

. R. § 91.151 ( a)'s fuel requirements for flight

in VFR conditions. Section 91.151 states:

(a) 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; or (2) At night, to fly after that for at least 45 minutes.

Here

, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30

- minute re s erve

. Petitioner proposes that all flights comply with this requirement b y mandating that the aircraft with 25% of battery life remaining be safely landed at the first opportunity.

**Equivalent Level of Safety**

The FAA has stated that an equivalent level of safety i s provided if the UAS flight is

terminated with at least 25% reserve battery power still available. The Operations Manual conform s

to this limit

, providing an equivalent level of safety.

K. 14 C.F.R. § 91.405(a) , 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Petitioner seeks an exemption from the maintenance inspection requirement s contained in

14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections

... have discrepancies repaired as prescribed in part 43 of this chapter").

An exemption from these regulations is needed because Part 43 and these sections only applyto aircraft with an a irworthiness certificate, which the UAS vehicles will not have

.

**Equivalent Level of Safety**

An equivalent level of safety will be achieved because maintenance and insp ec tion s will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Operations Manual. As provided in the Operations Manual, flights will not be conducted unle ss a flight operations checklist is performed, which includes a check of all of the aircraft's components. The Operations Manual also sets requirement s for maintenance log book s and

recor d keeping as well as routine and post

- flight inspections and maintenance. The Operations

Manual se ts requirements for both annual maint ena nce and preventative maintenance ba se d on hour s of flight.



### L. 14 C

. F.R. § 61.113: Private Pilot Privileges and Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts privat e pilot certificate

holders from flying aircraft for compensation or hire

, and would also requir e a seco nd class medical

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications i f the private pilot is carrying passengers or cargo for hire.

In this case
, while the UAS vehicles will be operated as part of a commercial operation

, it carries neither passengers nor cargo. In the Grant of Exemption in previous requests published publicly, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the addition al cost and restrictions attendant with requiring a PIC to have a commercial pilot certificate and class II medical certificate.

Petitioner will operate in a contained area away from persons and property not involved in

the operation. 

### All UASs will be flown based on VLOS at 400' AGL or below. Any required

notifications of the flight will be coordinated with the applicable Flight Standards District Office

.

**Equivalent Level of Safety**

In addition to these flight restrictions, Petitioner will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators, but also in the unique aspects of UAS flight. Each PIC will also be required to conduct training flights to obtain flight experience with UAS generally and with

the specific models used for commercial operations in particular. Petitioner believes that this system
will provide a higher level of compete ncy and proficiency for its PI Cs. Petitioner's PI Cs will have at
least an FAA Private Pilot license with at least a Class III medical certificate.



### V **I. Public Interest** 

Granting Petitioner's exemption request furthers the public interest. National policy set by Congress favors early integration of UAS into the N ational Air Space in controlled, safe working

environments such as those proposed in this petition. In addition

, the public also has an interest in reducing the hazards and emissions associat ed with alternate use of helicopters to conduct similarinspection operations. The UAS proposed for the exemptions are very light, under a 55

- pound

maximum gross weight. They do not carry any flammable liquid fuel and are capable of autonomous return to a safe landing point

, further reducing the risk from any potential accident.

Additionally, Petitioner has the knowledge and expertise to safe l y and effectively s ur vey, photograph and evaluate certain real estate, construction sites and public utility e quipment whereby typical larger manned aircraft may be a hindrance to the public

, noisy and not
accessible. Petitioner will have the capability to effectively dispatch in minutes a UAS that in

most cases will go unnoticed b y the general public, fall well below the typical noise signature of

manned aircraft without the use of traditional petroleum based fuels

.



### VII **. P rivacy** 

All flights will be conducted in accordance with any federal, state or local laws regarding pri vacy.



### VIII **. F ederal Register Summary** 

Pursuant to 14 C.F.R. Part 11

, the following summary is provided for publication in the Federal Register

, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45

. 23(b) ; 14 CFR 

### § 61.113; 14

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103 ; 14 CFR 91.109(a) ; 14 CFR 91.119; 14 CFR
91.121; 14 CFR 91.15l(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a) ; 14 CFR 91.407(a)(l);

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b).

The exemption will enhance safety b y reducing risk to the ge neral public and propert y owners from the substantial ha za rds associated with performing equivalent work with conventional

aircraft and rotorcraft. The exemption will further benefit the public by enhancing commerce in a wide range of fields and providing safety

- related services that would otherwise be unavailable.



### I **X**

**. C**  **onclusion**

Satisfaction of the criteria provided in Sect ion 333 of the Reform Act of 2012

- size, weight, speed

, operating capabilities, proximity to airports and populated areas

, operation within

v isual line of sight, and national security

- provides more than adequate ju st ification for the grant

of the requested exemptions to permit Petitioner to operate the selected UAS vehicles and provide 

### services to film production companies and independent film makers, real estate brokers and developers, the construction industry, utilities and utility maintaine rs, first responders, scientific research organizations, churches and other houses of faith, municipalities and other government entities, non

- profit organizations, entertainment companies, and any other entities that can utilize the safe and convenient op eration of UAS type aircraft where the use of typical certified aircraft is not possible or the cost is prohibitive.

Granting the requested exemption will benefit the public interest as a whole in manyways, including (1 ) significantly improving safety a nd reducing risk by alleviating human

exposure to danger

, and (2) improving the quality of services and decreasing operating costs compared with conventional flight operations.