Jam es Hall DBA Aerial Advantage

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the“Reform Act”) and 14 C.F.R. Part 11, operators at James Hall DBA Aerial Advantage seek an exem

ption from Federal Aviation Regulations detailed herein for the operation of lightweight aerial imaging equipment, also referred to throughout as Unm anned Aerial System s (UAS), as well as their ground based operation equipm ent described within.

O ur Aircraft: Our operation will include a single UAS, manufacturer DJI, referred to hereinafter as the Phantom 3 Professional. (UAS manuals attached). The Phantom 3 Professional has the following flight and safety relatable features:

• Phantom 3 is a UAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the bottom. Phantom 3 has a maximum weight of 1280 grams including propellers and battery, and a maximum range of 2000m outdoors and unobstructed. • Phantom 3 has bu ilt in telemetry to allow the operator to see all onboard inform ation relating to the safety of flight including but not limited to battery percentage remaining, overall health of the operating system, built

- in GPS for position hold and automatic return

- to

- home, and multiple fail

- safes for maximum safety. • The onboard camera allows the operator to record High Definition video, as well as take camera stills. The video is transmitted real

- tim e to the control and operator allowing the operator to see images to all sides of the UAS utilizing an Apple iPad Mini 2.

• Phantom

3 Pro is limited to a maximum assent rate of 5 m/s an d has a maximum decent rate of 3 m/ s. It also has a l imitation of m axim um speed of 16 m

/s.

• Phantom

3 Pro will be operated with a 6000 maH LiPo 25 lithium polymer battery allowing f

or flight times not to exceed 23 mi nutes.

Our Ground Based Guidance and Control System:

• Phantom

3 Pro is controlled using a DJI transmitter, operating on a 2.4GHz fre quency to a maximum range of 2000 meters. These specifications fall within FCC guidelines for operators. Powered by a lithium polym er battery it has an approximate 40 minute charge time

.• The Phantom 3 pro transmitter has a built in GPS allowing the UAS to always

know where to return to in the event of a failure.

• The Phantom 3 Pro transmitter will be controlled by a single operator, but will utilize a Visual Observer when necessary.

Our Operator:

• Aerial Advantage will use a single operator for each flight, and when able/necessary use a V isual Observer to assist in keeping sight of the Phantom 3
Pro at all times. At no time will the UAS be flown outside of visual line

- of

- sight and Visual range.

Our Business intent: Aerial Advantage will be utilizing the UAS for mult iple projects. These in clude:

Tower Inspections: Inspecting microwave towers (including cellular telephone towers) traditionally requires a human inspection. Utilizing a UAS to inspect these towers greatly im proves safety and will prevent deaths of tower Inspectors. We have a significant

amount of interest in doing business in Massachusetts to conduct such inspections.

• Bridge Inspections Similar to inspecting towers with the use of UAS, the required inspections of local bridges and overpasses will see a significant amount of increased safety.• Insurance Inspections of Home and Property : Aerial Advantage is very interest ed

in working with Insurance companies and adjusters to utilize the UAS to conduct inspections of property and struc tures. By utilizing the Phantom 3 Pro to conduct inspections of rooftops, farm fields, and other property, the insurance company stands to save a significant amount of time inspecting such property after storms. Also , utilizing the UAS will increase safety by preventing adjusters from having to clim b tall ladders and roofs to make such inspections. • Factory Inspections (both internal and external)

Similar to tower and bridge inspectio ns, we plan to use the Phantom 3 to conduct inspections within and outside of manufacturing facilities. The se dangerous and costly inspections will be m ade safe r and less expensive with use of our UAS. • Commercial Advertising Video and Photography

Aerial Advantage has a significant amount of interest in taking video and photos for advertising in our local area. Utilizing the UAS will offer a significant im provem ent to the agency with regards to bo th safety and cost. Using a small UAS compared to a gas turbine helicopter or aircraft will offer a considerable safety margin as well as cost savings advantage.

• Real Estate Photography and Videography

Real Estate photography will see a significant impact with our services, allowing real estate agents a much more competitive product at a much lower price. Safety will also be increased as well as productivity by utilizing out services

. • Yacht Sales Photography and Videography

Aerial Advantage has seen a significant interest in utilizing out UAS to capture video an d photos for Yacht, Boat and water vessel photography on Cape Cod. We will utilize the UAS to incr ease scope of sales to the yacht brokers. We can offer again a more cost competitive product and a much more safe development method over the current use of airplanes and gas/turbine helicopters. • Police/Fire/Search and Rescue

Aerial Advantage intends to offer our services on a voluntary and pro bono basis for m ultiple local services including but not limited to Police services, fire fighting services, and search and rescue. These services will increase safety associated with law enforcement and search and rescue. The services will be offered free of charge to the community.Our Safety and Operating Plan:

Utilizing our UAS in a safe manner is of upmost importance. Safety will be the guiding principle of our operation, both with respect to the National Airspace System , as well as those on the ground. including persons and property. Our Safety plan will start with complying with all Federal Aviation Regulations, as well as conducting audits of safety pro cedures set forth within Aerial Advantage to keep up to date with the safest practices. Our initial safety philosophy will be based on the premise of “Be Safe Before Takeoff”. We will complete preflight checklists set forth by DJI, the UAS manufacturer, as well as do thorough post

- flight inspections.We will also complete post

- flight checklist and debriefs to constantly monitor our

procedures and identify any changes that can be made, similar to those set forth on airline flight decks. Maintenance and repair of our UAS will be conducted solely by the manufacturer, DJI, by its employees or designated technicians. With respect to safety, Aerial Advantage believes the manufacturer holds higher maintenance abilities. Aerial Advantage will comply with the following at all times when conducting commercial o perations: 1. All operations will remain outside Class A,B,C,D airspace.
2. Our operating system are pre programmed to avoid airports such not to accidentally fly too close to one. The onboard sys tem will not allow the Phantom 3 Pro to fly into such airs pace. This is an automatic safety feature within the Phantom 3 Pro.

3. Operations conducted by Aerial Advantage will always remain within visual line

- of

- sight of the UAS. Never to exceed the limitations of our operator’s eye sight. We will limit the maximum range of the UAS to not exceed a single person’s visual eye

- sight range. Utilizing the software within the UAS will help to maintain this limit, not to exceed 300m. (.186 miles)
4. Our UAS will never carry an implement not approved by the manufacturer a nd will never exceed a weight of 55 lb. as stated within this exemption.

5. All operations conducted by Aerial Advantage will be at an altitude of less than 400ft AGL, while the majority of our operations will be at an altitude les s than 200ft AGL. The Ph antom 3 Pro has an automatic altitude limit built in and will be set and checked by our operator prior to every flight operation as part of the pre

flight inspection

. 6. Aerial Advantage will not conduct operations with a speed in e xcess of 27 knots. The Phantom

3 Pro UAS has an automatic speed limiter that will be set and checked prior to every flight by the operator as part of the pre

- flight inspection checklist.
7. All operations will be conducted in Day VFR conditions. Minimum flight visibility for al l operation will be 5 miles. Minimum cloud ceilings will be 2000ft OVC (overcast) or BKN (broken).
8. Aerial Advantage will work with local officials to make sure any required local docum ents or permits are attained prior to each flight.9. Prior to each flight our operator will conduct a safety audit of the area to be

flown. An assessment will be made with regards to persons, property, and weather. This assessment will allow our operator to determine whether a safe operation and
outcom e will be expected.The current regulations that we seek exemption from are:

A. 14 CFR Part 21 (h) Airworthiness Certification • Under this part we seek exemption to apply for and maintain airworthiness certification for our UAS. Model and serial number of our UAS will be provided within. B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness • Under this part, “no person may operate a civil aircraft unless it is in airworthy condition.” • We seek exemption from this part, as we will keep our UAS in a safe, reliable, and airworthy condition, it may not meet all standards as set for by this part of the FAR’s. Our operator will assume all responsibility for determining that the UAS is in a condition safe for flight, as well as a condition that wil l not harm other people or property. This will be accomplished using specific guidelines from the manufacture, DJI, as well as following any guidance set forth regarding routine maintenance.

C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required

• Under this part, (a) no person may operate an aircraft unless it has within it the following; An appropriate and current airworthiness certificate. This part also includes regulations regarding the use of fuel tanks, which do not apply

. • We seek exemptio n from this part as an airworthiness certificate does not apply to our specific UAS. D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude • Under this part, (a) no person may operate an aircraft below an altitude allowing, if power fails, an emergency landing without undue hazard. (c) over other than congested areas an altitude below 500ft AGL. • We seek exemption from this part due to the nature of the operation, as well as the safety procedures set forth will have little to no risk of damaging any person or
structure. E. 14 CFR Part 91 Subpart B; 91.121 (a)(1) Altimeter Setting • This section pertains to setting an altimeter setting belo w 18000ft to a reported altim eter reporting station setting. • We seek expedition from this part as our UAS has no way of setting an alternate altim eter setting. With a b uilt

- in barometer, the Phantom 3 Pro uses real

- time data to determine altitude each f light. Operating less than 400ft AGL, we feel our UAS will have little to no impact on other participating aircraft. Als o, with flights not to exceed 23 mi nutes (22 minute battery, and landing at 30% battery remaining) our UAS will not need to recalibrate its altimeter while in flight. F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight• This section contains requirements for fuel in VFR flight for combustion engines.

• We seek exemption from this part as our UAS operates off of battery pow er only. We feel our operations will not compromise safety to either the operator or property as we have set forth a procedure to land our UAS when the battery level reaches 30%, or approximately 6 minutes flig ht time remaining. The Phantom 3 Pro has built in battery telemetry that feeds information real time to the operator and an alarm notifies the operator of minimum battery level remaining. (See attached manual for more information) G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Required • This secti on contains requirements for the operator to maintain and have inspected the aircraft in accordance with Part 43 of the CFR. Under this section it is required to keep maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the inoperative equipment. • We seek exemption from this part as our UAS will not be operating with inoperative equipment and is too small to carry logbooks. We also seek exemption due to no certified maintenance technicians will work on the UAS. Unde r this

exem p tion Aerial Advantage will be completing pre

- flight and post

- flight inspections, and any required maintenance or repairs will be completed by the manufacturer, DJI, or one of its certified technicians. H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance • This part requires an aircraft that has undergone repair, rebuilding, alterations, or general maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11. • We seek exemption from this part as these insp ections do not pertain to our operation of the UAS. The operator will be responsible for determining the airworthiness of the UAS prior to each flight. After maintenance provided by the manufacturer, the operator will complete test flights before any opera tion in the vicinity of persons or property to assure all systems are functioning normally. I. 14 CFR Part 91 Subpart E; 91.409 Inspections • This section provides details of the required inspection on an aircraft. No person will operate an aircraft unle ss in the preceding 12 months has has (1) an annual inspection (2) an issuance of an airworthiness certificate. • We seek exemption from this part as the inspection and airworthiness certificate to not apply to our UAS. Our operator will be responsible for the inspection and airworthiness determination prior to each flight and will have the UAS repaired by the m anufacturer or one of its certified technicians, if the UAS is found to be in a state other than intended but the manufacturer.

J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Records• This section requires the owner/operator to complete and retain a list of all

records pertaining to the work preformed, the date of completion, the signature of the inspector, and all work per formed on the aircraft. • We seek exemption from this part as the inspections and technician work will not apply. Our operator will be responsible for determining the airworthiness of the UAS prior to each flight and will not operate the UAS in any condition other than intended by the manufacturer. The operator will keep records of all work

com pleted by the maintenance facility. K. 14 CFR Part 91 Subpart B; 91.103 Preflight Action • This section requires each pilot prior to flight will become familiar will all available information pertaining to that flight including runway lengths, flight inform ation, weather, etc. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information include; all applicable information relating to aircraft performance, airport elevation, runway slope, aircraft gross weight, wind and temperature. • We seek exemption from this part as our operator, while utilizing all available inform ation for the safe operation of the UAS, will not have the above inform ation available for most flights. The operator will use good judgment and all resources available to ascertain the information necessary for the safe operation of the UAS. A preflight inspection will be accomplished according to the manufactures ins tructions prior to each flight. L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew members Stations • This section pertains to the required crew members being at their stations during all phases of flight, and requires the use of seat belts and shoulder har nesses. • We seek exemption from this section as it pertains to aircraft with flight crew

me mb er stations. Our UAS does not have such stations. M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manual • This part states no aircraft may operate without a manual onboard the aircraft. • Our UAS is not large enough to carry such operating manual. We will however carry a current manufacturer manual in the UAS carrying case along with the operator on all fli ghts. N. 14 CFR Part 45.23 • Under this part, it is required that each operator must display on that aircraft marks consisting of the Roman capital N followed by the registration number of the aircraft. • Our UAS is too small to attach the “N” number. W e seek exemption from this part as we will be attaching the registration or serial number as required on the UAS

.Aerial Advantage and its owners are committed to a “Safety First” atmosphere. We

are committed to conducting our operation in accordance wit h all Federal Aviation Regulations and maintaining a safety margin of at least those regulations while striving to exceed expectations set forth by the FAA. We are confident we can approach our operations with safety while adding a significant advantage to our community both through private and civil services. Aerial Advantage is prepared to respond to any concerns and look forward to working with you on this important exemption. Please contact us with any other questions or concerns.

Sincerely yours,

Jam es Hall Aerial Advantage