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 Eich, 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 petition, as well as Petitioner’s 

General Operations and Safety Manual (“Operations Manual”). Petitioner submits these 

supporting materials as confidential commercial and proprietary information that Petitioner has 

not and will not share with others. Similarly, these 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 operations meet the requirements of Section 333 of the Reform Act

V. Regulations from which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Register Summary

IX. Conclusion
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 maintainers, 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 operation 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 published 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: ernestpeich@gmail.com

II. Types of Operations

Petitioner requests permission to operate UAS vehicles for support of film production 

companies and independent 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, non-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 Operations Manual, flights by Petitioner will be conducted 

under a strict set of guidelines. 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 property 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 minimum 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 safety (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 operations meet the requirements of Section 333 of the Reform 

Act

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

Section 333 of the Reform Act; each of the statutory criteria and other relevant factors are 

satisfied:

A. Approval 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 the 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 40 mph, vertical ascent speed of 15 mph, and a maximum weight of fifty 

(50) pounds. 

Each of the UAS 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 controller 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 Operations Manual and the manufacturers’ maintenance and flight 

manuals contain all of the procedures and limitations necessary to successfully and safely 

perform commercial flight operations. To assist the reviewer in its safety assessment of 

Petitioner’s operations, 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 ascent 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 designated 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, search 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 safety 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 exemption 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 exemption 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 

conducting 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 – Airworthiness 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 exemption 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 weighs less than 50 pounds and will be flown at less than 40 miles 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 than 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 capabilities 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 an 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 registration 

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 these

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 is required by § 21.5 of this

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved 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 unless 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

by 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 requests an exemption from this section, and requests that compliance with the 

intent of this regulation be deemed met with the UAS flight manual, registration certificate and 

other documentation kept at the control station with the PIC during flight. The Chief Counsel's 

Office has held that for all UAS operations, this alternate method constitutes full compliance 

with the regulations.

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

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be 

in airworthy condition to be operated. 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 requires a PIC to become

familiar with specific information before each flight, including information contained in the FAAapproved 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 the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actions, including 
performing all required checklists and reviewing weather, flight requirements, battery charge, landing and 

takeoff distance, aircraft performance 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 and 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 sterile, 

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 operating 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 Settings
Petitioner 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 GPS altitude read out, and that the 

point of departure and landing are unlikely to be an Airport.

Equivalent Level of Safety

As the attached Operations 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.l5l(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 reserve. Petitioner proposes 

that all flights comply with this requirement by 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 is provided if the UAS flight is

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

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 apply 
to aircraft with an airworthiness certificate, which the UAS vehicles will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections 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 unless a

flight operations checklist is performed, which includes a check of all of the aircraft's

components. The Operations Manual also sets requirements for maintenance log books and

record keeping as well as routine and post-flight inspections and maintenance. The Operations 

Manual sets requirements for both annual maintenance and preventative maintenance based on hours 

of flight. 

L. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

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

holders from flying aircraft for compensation or hire, and would also require a second 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 if 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 additional 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 competency and proficiency for its PICs. Petitioner's PICs will have at 

least an FAA Private Pilot license with at least a Class III medical certificate. 

VI. Public Interest

Granting Petitioner's exemption request furthers the public interest. National policy set by

Congress favors early integration of UAS into the National 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 associated with alternate use of helicopters to conduct similar 
inspection 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 safely and effectively survey,

photograph and evaluate certain real estate, construction sites and public utility equipment

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 by the general public, fall well below the typical noise signature of

manned aircraft without the use of traditional petroleum based fuels.

VII. Privacy

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

privacy.

VIII. Federal 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 by reducing risk to the general public and property

owners from the substantial hazards 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.

IX. Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- size,

weight, speed, operating capabilities, proximity to airports and populated areas, operation within

visual line of sight, and national security - provides more than adequate justification 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 maintainers, 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 operation 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 many
ways, including (1) significantly improving safety and reducing risk by alleviating human

exposure to danger, and (2) improving the quality of services and decreasing operating costs

compared with conventional flight operations.