June 3, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590 Dear Sir or Madam: Attachedplease find Sean M. Shortall's (V2 Flow Controls, LLC)request for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems ("sUASs") for Commercial Inspections and Surveying. Thankyou for your time and consideration, and please let me know ifyou have any questions. Sincerely, SeanM. Shortall V2 Flow Controls, LLC. President June 3, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.P.R. 45.23(b); 14 CFRPart 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.RPart 11, Sean M. Shortall, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits Small Unmanned Aircraft Systems ("sUASs") for commercial inspections and surveying, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed inthis document the requested exemption would permitthe operation of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already best practices safety protocols followed by Sean M. Shortall. Approval ofthis exemption wouldthereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

..establishrequirements for the safe operation of such aircraft systems in the national airspace system." Section 333 (c) ofthe Reform Act. The name and address ofthe applicant is: Sean M. Shortall PHONE# 630-962-6870**.-,·.~·~·.·~-~ ;\~**  :,',,l(.::**.,.-~-='~.~** ,·.· ..,· •)" '

< -**-~~·** • :The name and address ofthe applicant is: Sean M. Shortall PHONE# 630-962-6870 Email: sshortall@v2flowcontrols.com Address: 1333 Burr Ridge Parkway Suite 200, Burr Ridge, IL 60527

Regulations from which the exemption is requested: 14 C.P.R. Part 21 14 C.P.R. 45.23(b) 14 C.P.R. 61.113 (a) & (b) 14 C.P.R. 91.7 (a) 14 C.P.R. 91.9 (b) (2) 14 C.F.R 91.103 14 C.P.R. 91.109 14 C.P.R. 91.119 14 C.P.R. 91.121 14 C.P.R. 91.151 (a) 14 C.P.R. 203 (a) & (b) 14 C.P.R. 91.405 (a) 14 C.P.R. 407 (a) (1) 14 C.P.R. 409 (a) (2) 14 C.P.R. 417 (a) & (b) 1. STATUTORYAUTHORITY FOREXEMPTIONS The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under 40101 of the Act, including sUASs, from the requirement that all civil aircraft musthave a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulationprescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption ionthe public interest. 49 U.S.C. 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR91.203(a)(1). Section 333(b) ofthe Reform Act assists the Secretary in determining whether sUASs may operate inthe National Airspace System (NAS) without creating a hazardto the user, the public, or a threat to national security. Inmaking this determination, the Secretary must consider:

• • The sUAS's size, weight, speed, and operational capability; • • Whetherthe sUAS operates withinthe visual line ofsight ofthe operator • • Whether the s UAS operated outside ofhighly populated areas and away from close proximity to airports. Reform Act 333(a). Ifthe Secretary determines that a sUAS "may operate safelyinthe national airspace system, the Secretary shall establishrequirements for the safe operation ofsuch aircraft inthe national airspace system." Id. 333(c). Sean M. Shortall's sUASs are multirotator vehicles, weighing 10 or fewer lbs. including payload. He operate under normal conditions at a speed ofno more than 50 knots and have the capability to hover, and move inthe vertical and horizontal plane simultaneously. The sUASs will operate only inthe pilot's visual line of sight at all times. Such operations will insure that the sUASs will "notcreate a hazardto users ofthe national airspace system orthe public. "Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted environment within which they will operate, our application falls squarely within the zone ofsafety (an equivalent level ofsafety) in which Congress envisionedthatthe FAA must, by exemption, allow commercial operations ofsUASs to commence immediately. Also due to the small size ofthe sUASs and the low altitudes andrestricted areas in which our sUASs will operate, approval ofthe applicationpresents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significantpublic benefit, including enhanced safety, the grant ofthe requested exemptions is inthe public interest. Accordingly, Sean M. Shortall respectfully requests thatthe FAA grant the requested exemption without delay. II. PUBLIC INTEREST This exemption application is expressly submittedto fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportationto consider whether certainunmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAA will fulfill Congress' intent ofallowing UAS to operate with significant safety precautions in lowrisk environments. The use ofsUASs have numerous applications and benefits where we will no longer need to risk human lives to complete basic tasks at high altitudes, environmentally friendly as there are no combustible fuels to exhaust. Additionally, sUASs could replace the use ofhelicopters and small aircraft to inspect/survey sites. The sUASs we propose to fly inthis application are under five pounds, as opposedto the much larger conventionally powered small aircraft. Shifting to sUASs from helicopters presents a marked safety increase for workers and the public.Lastly, sUASs reduce the environmental impact by dramatically reducing the energy used for aerial imaging and data collection over a construction site. Our sUASs use rechargeable lithium ionbatteries, as opposedto fossil fuels burned in operation ofsmall aircraft that are many hundreds oftimes heavier. III. EQUIVALENT LEVEL OF SAFETY Sean M. Shortall proposes thatthe exemptionrequested herein apply to civil aircraft that have the characteristics and that operate withthe limitations listed herein. These limitations provide for at least an equivalent or evenhigher level ofsafety to operations under the current regulatory structure because the proposed operations represent a safety enhancementto the already safe protocols followed on construction sites and imaging and surveying operations conducted withhelicopters and other conventional aircraft. Sean M. Shortall will be boundby the following limitations when conducting its sUAS operations under anFAA issued exemption: 1. The sUAS will be less than 10 pounds. 2. Flights will be operated within visual line ofsight ofa pilot. 3. Maximum total flight time for each operational flight will be less than 30 minutes. The UAS calculates the battery reserve inreal time and will return with at least 25% ofbattery charge remaining. 4. Flights will be operated at an altitude of300 feet AGL, never exceeding 500 feet AGL. 5. Crew for each operation will consist ofthe sUAS pilot who will keep the sUAS within his visual line ofsight at all times. 6. The sUAS pilot will be trained in flight, operations, and safety procedures. 7. The sUAS will only operate within a confined area. 8. A briefing/scope ofoperationwill be conducted inregardto the planned sUAS operations priorto each flight. 9. All onsite personnel will consentto the UAS flyover on site by waiver, and the operator will obtain additional written consent ofall persons who will be allowed within 50 feet ofthe flight operation. 10. The pilot will have beentrained in operation ofUASs generally and received upto-date information onthe particular UAS to be operated. 11. Written and/or oral permission from the relevantproperty holders will be obtained. 12. All required permissions andpermits will be obtained from territorial, state, county, or city officials including butnot limited to: LawEnforcement and other Government Agencies. 13. Ifthe sUAS loses communications orloses its GPS signal, itwill have the capability to
returnto a pre-determined location withinthe security perimeter and land.14. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies. IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFRPart 21, Subpart H: Airworthiness Certificates 14 C.F.R 91.203(a)(l) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR 91.203 (a)(1). Giventhe size and limited operating area associated with the aircraft to be utilizedby SeanM. Shortall, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part II and Section 333 ofthe Reform Act. The Federal AviationAct (49 U.S.C 44701 (f) and Section 333 ofthe Reform Actboth authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports andpopulated areas ofthe particular UAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from an airport or densely populated area. An analysis of these criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft (fixed wing orhelicopter) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations underthis exemptionwill betightly controlled andmonitoredby the operator, and underthe requirements and in compliance with local public safety requirements, to provide security for the area ofoperation as is currently done on active construction sites. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with construction sites, provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posedby the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and ability to carry and external load no greaterthantwo lbs. 14 C.F.R. 45.23(b): Marking ofthe Aircraft This regulationrequires certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high "limited", "restricted", "light-sport", "experimental", or "provisional", near each entrance to a cabin, cockpit, orpilot station.Eventhough the UAS will have no airworthiness certificate, an exemptionmay be needed as the UAS will have no entrance to the cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Giventhe size ofthe sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed onthe fuselage in compliance with 45.29(±). The equivalent level ofsafety will beprovided by having the sUAS marked onits fuselage as required by 45.29(±) where the pilot, observers and others working withthe sUAS will see the identification ofthe UAS as "Experimental" The FAAhas issued the following exemptions to this regulation. Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 CFR 61.113 (a) & (b): Private pilotprivileges and limitations: Pilot in command Sections 61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the pilot operating the aircraft to have completed a UAS flight training course of 100 hours before flying a UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo onboard. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a pilot who has metthe minimum requirements exceeds the present level ofsafety achieved by 14 C.F.R. 61.113 (a) & (b). 14 C.P.R. 91.7 (a): Civil aircraft airworthiness The regulationrequires that no personmay operate a civil aircraft unless it is in airworthy condition. As there is no airworthiness certificate issued for the aircraft, shouldthis exemption be granted, no FAAregulatory standard will exist for determining airworthiness. Giventhe size of the aircraft and the use ofsafety checklists priorto each flight, as set forth in Section B and Section G, an equivalent level ofsafety will be provided. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements The sUAS, given its size and configuration has no ability or place to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAAhas issuedthe following exemptions to this regulation: ExemptionNos. 8607, 8737,8738,9299,9299A,9565,9565B, 10167, 10167A, 10602,32827,and 10700.14 C.P.R. 91.103: PreflightAction This regulationrequires each pilot in command to take certain actions before a flight to ensure the safety offlight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoffand landing distances, and all other actions inthe Preflight Checklist inthe Manual. These actions will provide an equivalent level of safety. 14 C.F.R. 91.109 Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraft viaradio communications. The FAAhas previously approved exemptions for aircraft without fully functional dual controls. See ExemptionNos. 5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilotnor passengers will be carried inthe aircraft, the ability to control the uUAS viaradio signals from the controller, and by the size and speed ofthe aircraft. 14 C.P.R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, providedthe person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craftthat flies similarly to a helicopter, with vertical takeoffand vertical landing, which will typically operate at altitudes of300 AGL, so an exemption may be needed to allow such operations. The UAS will never operate at altitude higher than 500 AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposedto operations without their pre-obtained consent. The equivalent level ofsafety will be achieved giventhe size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel, all affected individuals will be aware ofthe planned flight operations. Comparedto flight operations with aircraft or rotorcraft weighing far more thatthe maximum 1 0 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations ofthe sUAS will ensure separationbetweenthese small UAS operations andthe operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. 91: 121: Altimeter SettingsThis regulation requires eachperson operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

..to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may nothave a barometric altimeter, but instead a GPS altitude read out, an exemptionmay beneeded. An equivalent level ofsafety will be achieved by the operator, pursuantto the Safety Checklist, confirming the altitude ofthe launch site shown onthe GPS altitude indication before flight. 14 C.F.R. 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFRconditions. Our UAS is limited to operations in sterile and controlled environments as outlined above and has a limited range and flight time whichrequire an exemption from 14 CFR91.151 (a). The battery powering the sUAS provides approximately 35 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR 91.151, sUAS flights wouldbe limitedto approximately 5 minutes in length. Given the limitations onthe UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight ornight VFR conditions is reasonable. Sean M. Shortall believes that an exemption from 14 CFR91.151 (a) falls withinthe scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporationto operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people andproperty owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type ofrisks that Section 91.151 (a) was intendedto alleviate giventhe size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for whichthe exemptionwill be granted. An equivalent level ofsafety canbe achieved by limiting flights to 30 minutes, or enough battery reserve to ensure thatthe sUAS lands atthe ground station with at least 20% of battery power (as determined bythe onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere inits limited operating area. Similar exemptions have been grantedto other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification andregistration. The regulationprovided inpart:
1. (a) Except as provided in 91.715, no person may operate a civil aircraftunless it has within itthe following:.,·

(1) An appropriate and current airworthiness certificate

.... 2. (b) No person may operate a civil aircraft unless he airworthiness certificate required by paragraph (a) ofthis 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 orcrew. The UAS fully loaded weighs no more than 10 lbs and is operated without an onboard pilot. Therefore there is no ability orplace to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS. The FAAhas issued numerous exemptions to this regulation. A representative sample ofother exceptions includes ExemptionNos. 9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 CPR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections, except as provided in paragraph 

### © ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter

...," and others shall inspect ormaintainthe aircraft in compliance with Part 43. Giventhat these sections and Part43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Sean M. Shortall. Maintenance will be accomplished by the operatorpursuantto the flight manual and operating handbook as referenced inthe Manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS canland immediately and will be operating from no higher than 400 feet AGL. Asprovided inthe Manual, the operator will ensure thatthe UAS is inworking order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar withthe aircraft and best suitedto maintainthe aircraft in an airworthy conditionto provide the equivalent level ofsafety.

Thankyou for yourtime and consideration onthis matter.