### March 2, 2016 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave

. , SE Washington, DC 20590 Re: Petition of Gaia Herbs, Inc. for an Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 Director: Flight Standards Service: Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, Gaia Herbs, Inc. ("Petitioner") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles (i.e., 

### "small unmanned aircraft" or "UAS") for the purpose of conducting aerial photography, videography, and mapping for agriculture industry. This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Petitioner documents ; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as " Documents 

### & Manuals") 3. User Guide and; 4. Flight Manual' (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Petitioner submits these supporting materials as confidential documents pursuant to 14 C.F.R. 

### § 11.35(b ), as the materials contain confidential commercial and/or proprietary information that Petitioner has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. 

### § 552 et. seq .. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIALAND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER. For your convenience, this Petition is organized as follows:

1 • The term "Manufacturer's Manual" also includes all relevant manufacturer publications , including, but not limite d to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and , safety / service bulletins.U.S Department ofTransportation March 2, 2016 Page 2 

### I. Description of Petitioner II

. Description of Proposed Operations A. Aerial Videography, Photography and Mapping 

### 111. Relevant Statutory Authority IV. Petitioner's Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability B. Approva l is Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals 

### V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, Subpart H

- Airworthiness Certificates and 14 C.F.R. 

### § 9l.203(a)(l) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. 

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

### § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. 

### § 61.3, 14 C.F.R. 

### § 61. 1 13: Private Pilot Privileges and Limitations F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the A ircraft and 14 C.F.R. 

### § 91.203(a) and (b): Ca rrying Civil Aircraft Certification and Registration H. 14 C.F.R. 

### § 91.103: Preflight Actio n I. 14 C.F.R. 

### § 91.109(a): Flight Instructi on 1. 14 C.F.R. § 91. 11 9(c): Minimum SafeAltitudes K. 14 C.F.R. 

### § 91.121: Altimeter Settings L. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

### VI. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX. Federal Register Summary 

### X

. Conclusion I. DESCRIPTION OF PETITIONER Petitioner is based in Brevard , NC working in aerial photography, videography, and mapping for the agriculture industry. The Company specializes in , and will continue to focus on the photography, videography and mapping of farm land for the agriculture industry. TheU.S Department ofTransportation March 2, 2016 Page 3 Company's Principal and Chief Pilot Coty Wood has been flying UAV Quadcopters as a hobby for more than three years without incident, logging hundreds of hours flying. Petitioner will hire licensed pilots in good standing with the FAA for all commercia l operati ons. Upon the grant of the 333 Exemption the Company's business will specialize in photography, videography and mapping of fannland. Petitioner 's s taff are well trained and experienced in providing support as visual observers ("VO") for the pilot in command (" PIC ") in add ition to any other needed on s ite ass istance. All of the equipment owned by Petitioner is ofthe highest quality gear and has been able to provide these services safely and wi thout any claims or incident. Petitioner 's goal is to advise the perspective cli ent that Petitioner is following all the applicable state and federa l rules to ensure the safety of the public while providing the client with a competitive and cost effective product. Petitioner seeks an exemption to allow for photography, vi deography, inspection and other related media products. The contact information for Petitioner is as follows: Coty 

### R. Wood Gaia Herbs, Inc

. 1

0 1 Gaia Herbs Rd Brevard, NC 28712 Phone: 828.883.6000 : Email: crw@gaiaherbs.com 

### Il. DESCRIPTION OF PROPOSED OPERATION Petitioner seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI In sp ire I (referred to CRW-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations w ill occur under tightly controlled conditions on private property or approved location where Petitioner has received verifiable permission to operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance w ith the conditions and limitations of this Petition fo r Exemption and Petitioner's Operations Manuals. As detailed in Petiti oner· s Operations Manual s, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 nm away from an a irp ort reference point. Moreover, Petitioner's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologie s . A. Aerial Videography, Photography and Ins pection Petitioner seeks to use small CRW-UAS for the purpose of conducting aerial photography, videography and ins pection for the real estate, agriculture and construction industry. Petitioner has purposefully tailored its operations to meet the requirements established by the FAA in prior grants of exemption authorizing commercial use of VAS in the real estate indu stry, including:U.S Department ofTransportation March 2, 20 16 Page4

• Trudeau, Realtor® (Exemption No. 11138) • Alon Sichcrman (Exemption No. 1 1728) • Sokoler Mcdly (Exemption No. 1 1341) • Raven Executive (Exemption No. 12639) • Starnes Aviation (Exempti on No. 123 77) • Wilson Asso (Exempt ion No. 12750) All UAS photography, videography and inspection operations will occur on private property or approved location in a controll ed area away from spectators and persons not involved in the recording process. [n addition, the filming will be conducted between dawn and du sk to ensure maximum safety for the public and those involved in the manipulation and operation of th e UAS; VFR condition s, at altitudes below 400' above ground l eve l (" AGL"). As set forth below, Petitioner's operations provide an equivalent level of safety which is superior to performing the same work using conventional fix e d-wing aircraft or heli copters. Small UAS video production is also safer than tradi tional manned aircraft performing the same function. Videographer-in spectors also frequently need to climb roof tops , trees, ladders or otherwise perform elevated work, which exposes them to the risk ofdangerous fa ll s, electroc ution or other work related injuries. In addition, depending on the nature of the video needed and inspection , proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities of ten involves a risk of expos ure to hazardous conditions. The use ofCRW-UAS mitigates these hazards and is ultimately a much safer and cost efficient method of performing these and most other types of inspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations present ri sks associated with vehicles weighing tens ofthou sands of pounds (including payload) and carrying large amounts of fuel which inherently presents significant fire hazards as well as exposure to other chem ical contaminates. It is important to note the use of small UAS in this area wi ll not on ly be safer and more cos t effective to the perspective user or purchaser of the service, but the quality and expanse of acquired inform atio n wi ll be far more robust given the low cost associated with its acquisition and other potential consumers an inexpensive product. UAS video production is more rel iable, and allows for the collection, dissemination , and storage of visual and other sensory data wi th greater precision and duration at a very low cost. Small UASs will also be capab le of accessing and in specting areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other inspection methods. 

### III. RELEVANT STATUTORY AUTHORITY Tllis Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization and Reform Act of2012 ("Re f orm Act"). Congress has directed the FAA

" to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace sys tem." Pursuant to Section 333 ofthe Reform Act, the FAA Administrator is to perm it unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe to do so based on the following considerations:U.S Department ofTransportation March 2, 20 16 Page 5

• The UAS's size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within the visual line of sight ofthe operator

. Additionally, the FAA Adminis t rator has general authority to grant exemptions f rom the agency's safety regulations and minimum standards when the Administ rator decides a requested exemption is in the publ ic interest. See 49 U.S.C. 

### § 106 (f) (defining the authority of the Administrator); 49 U.S.C. 

### § 44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702

- 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: 

### (l) would benefit the public as a who le , and (2) would no t adversely affect safety (or how it would prov ide a level of safety at least equal to the existing rules). See 14 C. F.R. 

### § 11.81 (petitions for exemption). 

### IV. PETITIONER'S PROPOSED CRW-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT The small CRW-UAS operations proposed by Petitioner as noted above in this P eti tion for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are sati sfied. 

### A. Approval i s Warranted Based on the 

### VAS's Size , Weight, Speed, and Operational Capability A Grant of Exemption is appropriate for opera tions conducted using the UASs due to their size weight, speed, and operational capability

.

• The CRW-UAS utilized by Petitioner has been approved for use in prior Section 333 Grants of Exemption from the FAA. 2

• The C RW-UAS weighs less than 55 pounds , including payload

• The CRW-UAS will not be flown at a ground speed in excess of 87 knots (100 mph). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed re striction.

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation , digitally encoded b aro metric altimeter, radio a ltimeter, or any combination thereof. This information will be transmitted to the pilot via telemetric data feed. • The CRW-UAS will h ave system redundancies and independent functionality to ensure the overall safety and predictability of the system. If connection to the remote

2 See e.g. , Grant of Exemption to Trudeau, Realtor® (Exemption No. 11138) ; Grant of Exemption to AIon Sicberman (Exemption No. 11728); G rant of Exemption to Sokoler Medly (Exemption No. 11341 ).U.S Department ofTransportation March 2, 2016 Page6 control or ground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land without injury or damage.

• The radio frequenc ies used for operations and control ofthe CRW-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequen cy for the CRWUAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take

- off weight would likely exceed 6,000 pounds dependi ng on payload. The difference in weight between the CRWUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated. 

### B. Approval is Warranted Based on the Operational Restrictions Set Forth in 

### Petitioner's Operations Manuals Petitioner's Operations Manuals and the Manufacturer's Manual for the selected CRW-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Petitioner's proposed operations , below is a summary of operati onal limitations and condi tions that Petitioner will adhere to , and which will ensure an equ i valent or higher level of safety to operations conducted under current regulatory guidelines: 1

. The CRW-UAS weighs less than 55 pounds, with payload. 2. A ll operations shall be conducted over private or controlled-access property with verifiable permission from the land owner /controller or authorized representative. Permission from land owner /controller or authorized representative will be obtained for each scheduled flight prior to operation. 3. All UASs operated under the Grant ofExemption will be identified by serial number, registered 

### in accordance with 14 CFR part 47, and have identification (N

-Number) markings in accordance w i th 14 CFR part 45, Subpart C. Markings w ill be as large as practicable. 4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in Command ("PIC") of the CRW-UAS , and one or more Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a private , recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver 's license issued by a state, the Di strict of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 

### in an aircraft in which the PIC is rated on hi s or her pilot certificate.U.S Department ofTransportation March 2, 20 16 Page 7 6. The CRW-UAS shall be operated within VLOS of the PIC and Observer at aJJ times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times

. 8. Electronic messaging or texting will not be permitted during flight operations. 9. The additional requirements identified in the Grant of Exem ption shall be added to the Petitioner 's Operations Manuals. The Operations Manuals will be maintained and made avai lable to the Administrator upon request. If a discrepancy exis ts between the conditions and limitations 

### in the Grant of Exemption and Petitioner's Operations Manuals, the conditions and lim itations in the Grant of Exemption shall take precedence and must be followed. Otherwise, Petitioner shall follow the procedures outlined 

### in their Operations Manuals. 10. Petitioner may update or rev ise its Operations Manuals. Revisions wi II be tracked and a revised copy of the Manual will be provided to the Administrator upon request. Petitioner will also present an updated and revised Operations Manuals if it petitions for extension or amendment to its Grant ofExemption. If an update or revision would affect the basis upon which the FAA grants the exemption, Petitioner will seek an amendment to its Grant of Exemption. Petitioner will contact the FAA's UAS Integration Office (AFS-80) if questions arise regarding updates or revisions to the operating docum en ts. 11

. Petitioner Operations Manuals and its Grant of Exemption will be available to the PIC at the ground control station anytime the CRW-UAS is operating. 12. The PIC is prohibited from beginning a CRW-UAS flight tmless (considering wind and forecast weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes

. 13. Maximum total flight time for each operational flight using the CRW-UAS will be limited to 40 minutes or the amount oftime the UAS can be flown and sti ll maintain a reserve battery power of no less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enter navigable controJied airspace without timely prio r written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the UAS wi II not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:U.S Department ofTransportation March 2, 2016 Page 8

a. Barriers or s t ructures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the even t of an accident. The operator must ensure that nonparticipating persons remain under such protection. 

### If a situati on arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immed iately and/or; b. The airc raft is operated near vessels, vehicles or structures where the owner /controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC , VO, operator trainees or essential persons do not present an undue hazard to those persons per 

### § 91. 11 9(a). 16. The CRW-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibili ty is less th an 3 statute miles from the PIC

. 17. The CRW-UAS may not operate within 5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as requi red by the FAA. The letter of agreement wi th the airport management will be made available to the Admin istrator upon request. 18. Prior to each flight the PIC shall inspect t he CRW-UAS to conftrrn that it is in a condition safe for flight. The pre-flight in spection wi ll account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents as we ll as equipment updates. The PIC shall not operate any CRW-UAS 

### if the in spection reveals a condition that affects the safe operation of the CRW-UAS until the necessary maintenance has been performed and the CRW-UAS is found to be in a condition for safe flight. T he ground control station shall be included in the prefl ight inspection. A ll maintenance and alternations must be properly documented in the UAS's records as required by Petitioner's Operations Manuals. 19. Petitioner will timely carry out its maintenance, inspections , and record keeping r equirements in accordance with the Operations Manuals. Maintenance, inspection , and alterations will be fully noted in the CRW-UAS records, including total time in service , description ofwork accomplished, date completed and the signature ofthe authorized person returning the CRW-UAS to service. 20. Any CRW-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement of a flight cri tical component) must timely undergo a functional test flight in accordance with Petitioner's Operations Manuals. The PIC who condu cts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and CRW-UAS record entry shall be included in the Petitioner 's Operations Manuals.U.S Department of Transportation March 2, 20 16 Page 9 21. The CRW

- UAS will be operated and maintained according to the Man ufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22. Pri or to the operation, a Mission Packet will be created in accordance with the requirements on Petitioner's Operations Manuals. 23. P e titi o ner will obtain an A ir Traffic Organization ("A TO ") issued Certi fi cate of Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant ofExemption. A NOT AM will be issued as required by the COA. All operations will be cond ucted in accordance with airspace requirements in the A TO issued COA including class of airspace , altitude level and potential transponder req uirements. 24. All required pem1issions and permits will be obtained from territorial, state, cotmty or city jurisdictions, including lo ca l law e nforcement , fire or other appropriate govenm1ental agencies. 25. If the C RW-UAS loses communication with the PIC, it wi ll have the capability to safely return to a pre-determined location within the operational area and land safely. 26. Contingency plans will be in place to safely terminate flight if there is a loss of communic ation between the PIC and the Observer. 27. The CRW

- UAS will have the capability to safe ly abort flight in the case of unpredicted obstacl es or emergencies. 28. PIC s and Observers will have at least a current Class ITT Medical Certificate or a valid and curre nt state driver's license issued within the United States. 29. Prior to conducting operations for filming, the PI C wi ll have accumulated and logged , in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a simila r CRW-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming , the PTC will have accumulated and logged , in a manner consistent with 14 CFR 

### § 61.51(b) , a minimum ofhours pursuant to 54 CFR 

### § 61.51 (b) as UAS pilot operating the make and model of CRW-UAS to be utili zed for operations under the exemption and three take-offs and three land ing in the preceding 90 days. 31. Operations shall occur during daytime VFR Meteorological Conditions; flights under sp ec ial visual flight rules ("SVFR") shall not be co nducted. 32. The CRW-UAS shall remain clear and yie ld the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities , parasailing activi ti es, hang gl id ers, etc.).U.S Department of Transportation March 2, 2016 Page 10 33. C RW- UAS Operati ons under Instrument Fl ight Rules, at night, or beyond VLOS are prohibited. 34. The UAS will not be operated from an elevated platform unle ss designed and engineered spec ifically for such purposes and be in compliance with the general restrictions imposed by the applicable regulations. Addi tionally no PIC will provide any film

- flight operations while in motion from atop any elevated platform vehicle or dev ice. 35. Before cond ucting operations, the radio frequency spectrum used for operation and contro l of the C RW-U AS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal Aviation Act expressly grants the FAA the authority to i ssue exemptions. TI1is statutory authority, by its terms , includes exempting civi l aircraft, as the tenn is defined under§ 4010 I of the Act, including UASs, from its sa fety regulations and minimwn standards when the Administrator decides a requested exempt ion is in the public interest. 3 Petitioner seeks an exemption from several interrelated provisions ofTitle 14 of the Code of Federal Re gulation s ("14 C.F.R") Parts 21, 45,61 and 91 for purposes of conducting the requested operations using CRW-UAS plat forms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and sa f eguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. 4 UNMANNED AIRCRAFT SYSTEM A. 14 C.f. R. Part 2 1, Subpa rt H

- Airworthiness Certificates and 14 C.F.R. §9 1 .203(a)(l) The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met and in point of fact exceeded, and therefore no exemption is needed. 5 If , however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements ofthe Reform Act, an exemption is reque s ted

.

3 49 U.S.C. § 4470 I(f) (authorizing the grant ofexemptions from requirements of regulations prescribed pursuant to Sections 4470 I(a) and (b) and Sections 44702

- 44716 ). 4 14 C.F.R § 11.81 (e), which requires a petit ion for exemption to include: The reasons why granting the exemption would not adver se ly affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek exemption.

s See G rant of Exemption No. I I062 to Astraeus Aerial (FAA-20 14-035 2 at pgs. 13-14, 22).U.S Department ofTran sportation March 2, 2016 Page 11 

### Equivalent Level of Safety Petitioner's use of the CRW-UAS is safe when taking into account its size, weight, speed, and operational capabi lity. As set forth in the description of proposed operati ons in Section IV(A), the CRW-UAS weighs l ess than 55 pounds , including payload and will not be flown at a ground speed in excess of 87 knot s. The C RW-UAS is also equipped with safety features which will a llow Petitioner to operate the C RW- UAS safely after exp eriencing certain in-fl ight contingencies or failures as noted below. 6 7 Additionally, the CRW

- UAS carries neither pilots nor passenger s, carries no explosive materials or flammable liquid fuel s, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Petitioner 's Operations Manuals

. Operations conducted under this exemption will be closely controlled and mon itored by the PIC operator and will be conducted in compliance with local public safety require ments, to provide security for t he area of operation. P etitioner will al so provide the FAA with advance notice of all op erations via NOTAM s as requi red by the applicable COA. In all cases, operation of the C RWUAS tmd er the propos e d conditions will be at least as safe as, or safer than , conventiona l rotorcraft operating wit h an airworthine ss certificate

. Lastly, the CRW-UAS s do not need a means to communicate with other aircraft or ATC, because tho se capabilities wi ll be so lel y possessed by the PIC and Observer, who are not o nb oard the C RW-UA S. 8 In addition, no senseand-avoid technology is necessary for the CRW- UASs because they will be operated at all times in VFR conditions and wi thin VLOS ofthe PIC and Operator. 9

6 See e.g., Grant of Exemption No. 11184 to Lo w Country RC, Corp. (FAA-20 14-0803 at pg. 3): "The [DJI S 1000] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an au to

pilot system to maintain UAS stabi lity and control. The UAS is also able to respond to a loss of g lobal positioning system (GPS) or a lost-link even t with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These saf ety features provide an eq uiv alent level of safety compared to a manned aircraft performing a s imil ar operation ."

7 See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014 -0382 at pgs. 4-5): "The CRW-UAS can be operated entirely by a touch-screen, map -b ased interface. This means the operator o n ly needs to command th e system where to go, and the system does all the flying for the operator. The CRW-UAS can be operated in both semi and fully autonomous flight modes, w ith the operator simply clicking on a map to create a pre-planned flight path f or a flight. In addition, the operator can create no fly zones or maximum flight ranges an d altitudes so the sys tem cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the CRW-UAS to detect a system fault while in the air and au toma ti cally fly back to its takeoff location and land. Faults that can be detected include : loss of communication; exceeding pre-set wind thresholds; and low battery levels ." All night operations are global positioning system (G PS) contro lled, making the system easy to nav i g ate

. At any point if the operator is not explic itl y commanding the system to move , the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors inc lud ing so nar , baro metric pressure, temperature, wind speed and others to ensure stability so long as w ind thresholds are not exceeded. Also a flight termination link- to prevent a 'fly away' or other potentially dangerous situation- is available to the operator."

8 See Grant of Exemption No. II 062 to Astraeus Aerial (FAA-20 14-0352 at pg. 13).U.S Department of Transportation March 2, 2016 Page 12 B. 

### 14 C.F.R. Part 27 Ainvorthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Petitioner's sma ll CRW-UAS would otherwise require certificati on under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified 

### in the req uest for exempt ion from 14 C.F.R. R. Part 21 , Subpart H , 

### supra. 

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

### §§ 9l.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Petitioner seeks an exemp tion 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 Pl acard requ irements , provides t hat: No person may operate a U.S.-re gistered 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 on ly the Roman capital Jetter "N" and the registration number is displayed on limited, restricted or light-sport ca tegory aircraft or experimental or provisionally certificated ai rcraft, 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 n or more than 6 inches high, the words "l imited," "res tri c ted," "light-sport , "experimen ta l, " 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 , fu selage , boom, or tail the marks required by § 45.23. In a previous Grant of Exemption, the FAA determined that exe mption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings in accordanc e with 14 C.F.R Pat145, Subpart C if the markings are as large as practicable.' 110 

### Equivalent Level of Safety All CRW-UAS flown by Pet iti oner will bear N- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart 

# c: '

10 FAA Docket No

. F AA-20 14-0352 II See , e.g., FAA Docket No

. FAA-20 14-0352, at 14.U.S Department ofTransportation March 2, 20 16 Page 13 

### D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections Petitioner seeks an exemption from the maintenance inspection requirements 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 in spection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 9 1.405(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 UASplatforms to be operated under this grant of exemption will not have. (Emphasis added) Equivalent Level of Safety An equivalen t level of safety will be achieved or exceeded because maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Petitioner's Operations Manuals, the PIC will conduct a pre- flight inspecti on ofthe CRW

- UAS and all associated equipment to account for all discrepancies and/or inoperable components

. Maintenance will be performed and verified to address any conditions potentially affecting safe operation of the CRW-UASs and no flights will occur unless , and until , all flight critical components ofthe CRW-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement of any flight-critical components

. As required by Petitioner 's Operations Manuals, the PIC who conducts the functional test flight will make an entry in the CRW-UAS aircraft records of the flight. Petitioner's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance , overhaul , replacement, inspection , and life limit requi rements for the following applicable components: powertrain system (powerplant) , propellers, avionics and contro l surfaces (including ailerons/e levons), structures & airframe, camera system, electrical systems (including batteries), ground cont rol station, hazard accessories, and spare parts. Further, Petitioner's Operations Manuals also include procedures to document and maintain a record ofthe CRW-UAS's maintenance , preventative maintenance , alterations, status of replacement /overhaul component parts, and the 

### total time in service of the CRW-UAS used under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in Petitioner 's Operations Manuals ensure that an equivalent or higher level of safety will be achieved. 

### PILOT-IN-COMMAND OF THE UAS E. 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 air craft for compensa t ion or hire , and would also require a second class medical certificate

. The purpose of Part 61 is to ensure t hat the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for h ire. 

### In this case, while the CRW-UAS will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant ofU.S Department ofTransportation March 2, 2016 Page 14 Exemption to Astraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 12 The fulfillment of the additionaJ requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. 

### Equivalent Level of Safety The restrictions Petitioner has placed on its CRW-UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. Petitioner will operate on private property away from persons and property not involved in the operation. Petitioner will also obtain an ATO issued COA prior to conducting any operations under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, alt itude level and potential transponder requirements. A NOT AM will also be is sued as required by the applicable COA. 

### 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 CRW-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in CRW-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf ofPetitioner. The pilot qualification, training, and currency requirements in the Operations Manuals ensure that P etitioner pilots are competent and proficient in the CRW-UAS they are operating. Petitioner 's training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption , and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level of safety to the public. 

### OPERATING PARAMETERS OF THE UAS F

. 14 C.F.R. 

### § 91.7(a): Civil Aircraft Airworthiness Inasmuch as there will be no airworthiness certificate issued for the UASs, 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 for 14 C.F.R. § 91.7(a) to the extent that the requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with Section V(A), supra. 

### G. 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

12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352). 13 See ld. at 13 -14 , 22

.U.S Department ofTransportation March 2, 20 16 Page 15 Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airwmthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft

- (2) For wh ich an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this chapter, unless t h ere is available in the aircr aft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 9 1. 203(a) and (b): (a) Except as provided in 

### § 91.715, no person may operate a civi l aircraft unless it has within it the following: (l)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 passenge rs or crew. Given the small size and configuration of the CRW

- UAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the CRW

-UAS because there is simply no room and the CRW-UAS has no cabin or cockpit. As a way to comp ly w ith the code Petitioner will maintain the documents with the PIC and make them available for inspect ion. 

### Eq u iva len t Lev e l of S a

fety In an FAA Office of Chief Counsel 's Opinion dated August 8, 2014, and prepared by Dean E

. Griffith, Attorney, AGC

-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by enstLring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS. 

### H. 1 4 C.F.R. § 9 1.1 03 : P re flig ht 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 Fl ight 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 FAAapproved Flight Manual is required.

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-20 14-0352 at 16- I 8.U.S Department ofTran s portation March 2, 2016 Page 16 

### Equivalent Level of Safety An equivalent level of safety will be provided by following the Petitioner ' s Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists des igned to identify any defects or inoperable components in accordance with the Petitioner's Operations Manuals, incl uding checklists covering Pre-Flight, Launch, Landing, and Post-Fl ight procedures. The PIC will also be required to review weather , flight requirements, battery charge, landing and takeoff distance, UA performance data , and contingency landing areas- before initiation offlight. Petitioner ' s Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS. 

### I. 14 C.F.R. 

### § 91.109(a): Flight Instruction Petitioner seeks an exemption from 14 C.F.R. 

### § 91.109(a), which provides in pertinent part 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 function ing dual controls." UASs 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. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a). 

### Equivalent Level of Safety Given the size and speed ofthe UASs that Petitioner intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the Petitioner ' s Operations Manuals , all persons will be a safe distance away in the event that the UAS experi ences any difficulties during flight instruction. Moreover , as required by the Petitioner ' s Operations Manuals , all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Petitioner's Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level of safety than that provided by the flight instruction regulations. 

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

### § 91.119(c): Minimum Safe 

### Altitudes Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119( c). 15 Section 91.119 pre scribes the minimum safe altitudes under which aircraft may not operate , includjng 500 feet above the surface and away from any person, vessel , vehicle , or structure in non-congested areas. See 14 C.F.R. 

### § 9 1. 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."

15 Relief from§ 9l.ll9(a) will not be necessary because Petitioner will be able to perfonn an emergency land ing without undue hazard to persons or property on the ground in the event of a failure

. Petitioner's proposed UAS operations will not occur over congested areas , and therefore an exemption from § 91.119(b) will not be necessary. See e.g. , Grant of Exemption No. 11157 to Slugwear, lnc ., dba Like on a tree Aerial {FAA-20 14-0534 at 15)

.U.S Department ofTransportation March 2, 2016 Page 17 An exemption is required because the proposed CRW-UAS operation will normally need to occur below 400 feet AGL. In circumstances where the CRW-UAS is used to inspect a stru cture whose height exceeds 400 feet AGL, the CRW-UAS will not be operated more than l 00 feet above the highest point on the structure, and wi thin 50 feet horizontally of the structure. Additionally, due the nature of the proposed operat ions, the Pilot and/or Observers(s) may need to be le ss than 500 feet away from the CRW-UAS. 

### Equivalent Level of Safety Compared to flight operations w ith rotorcraft weighing far more than the maximum weights proposed herein , and given the Jack of flammable fue l with the above noted UASs, any risk associated with these operations is far Jess than those which presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the CRW-UASs, as well as the controlled location where the operations wi ll occur. In order to avoid any ri sk to manned aircraft, 

### flight operations will be restricted to 400 feet AGL or below, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, w ithin 100 feet above the highest point on that structure and 50 feet hori zon tally of the structure. As set forth in the Operations Manuals, the CRW-UAS will be operated in a restricted area, and all flights w ill be operated at a lateral distance of at least 500 feet from any nonparticipati ng person s, unless that person is in a p osition where he or she is shielded from the CRW-UAS and any possible debri s resulting from its failure. As required by the Operations Manual s, flights will be terminated i f a nonparticipating person with i n 500 feet of the CRW-UAS leaves a shielded position. Further, its operations wi ll occur at least 500 feet away from vehicles or s tructures unless the property owner/controller timely has granted permission and the PIC has made a safety assessment of the risk of operatin g closer to those objects and, operations near the PIC or Observer will not present an undue hazard per§ 91.119(a). Adherence to these restrictions in Petitioner 's Operations Manuals will ensure operations can be conducted without compromising public safety. 16 K. 

### 14 C .F.R. 

### § 91.121: Altimeter Settings Petitioner seeks an exemption from 14 C.F.R. 

### § 9 1

. 1 21, which requ ires a person operating an aircraft to maintain cruising altitude o r flight level by r eference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exempt ion is required to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

16 Sec e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-20 14-048 l at 19): "If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner / controller of any such vessels , vehicles or structures grants permission for the operation and the PIC makes a safety assessment o f the risk of operating closer to those objects and determines that it does not present an undue hazard."U.S Department ofTransportation March 2, 2016 Page 18 

### Equivalent Level of Safety The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 can be achieved in circrunstances where: (1) the UASs will be operated below 400 feet AGL or below 17

, (2) within VLOS, (3) where GPS based altitude infom1ation is relayed in real time to the operator at a ground-based on-screen display and, ( 4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS

. 1 8 The CRW-UAS that Petitioner intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Petitioner 's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants ofExemption, the CRW-UAS Petitioner intends to use, and the safety mitigation procedures contained in the Operations Manuals , both ensure that an equivalent level of safety or gr eater level wi IJ be achieved, and a Grant ofExemption to the requirements of§ 191.121 is therefore appropriate. L. 

### 14 C.F.R. 

### § 91.1Sl(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 (cons idering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landin g 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 battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.15l(a) is therefore required. Moreover , it is not Petitioner's intention to fly the CRW-UASs at night. 

### Equivalent Level of Safety In the Grant of Exemption to VDOS (Exemption No. 111 12), the FAA detem1ined that an equivalent level of safety to the fue l requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a CRW-UAS flight unless (considering wind and forecast weather conditions) there was enough power to fly to the first intended point of l anding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the CRW

- UAS provide approximately 50 minutes ofpowered flight (with payload) and provided battery level and battery time

17 lfthe beight of the structure being inspected exceeds 400 feet AGL, the VAS will not be operated more than 100 feet above the highest point on the structure

. 18 See Grant of Exemptio n No. 11062 to Astraeus Aerial { FAA-20 14-0352 at 21 )

.U.S Department of Transportation March 2, 2016 Page 19 remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the CRW-UAS operating manual states: "start every flight with a fully charged battery in the aerial vehicle", and that in the event that the CRW-UAS should nm low on power, the PIC will be alerted and can safely land the- CRW-UAS as soon as possible. Like the VDOS Grant of Exemption, Petitioner's use ofthe CRW-UAS, combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level of safety can be achieved and in fact exceeded. Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a flight with the UA unless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. Petitioner will adhere to this limitation for its CRW-UAS flights. The CRW-UAS includes a low battery warning system and the amount of battery reserve power remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from the CRW-UAS to a ground-based-on-screen display?0 As required by Petitioner's Operations Manuals, the PIC will promptly fly the CRW-UAS back to the home launch location or predetennined abort location where it may safely land, while still maintaining a minimum of25% reserve battery power. Petitioner submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds , and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent or higher level of safety to the public to that provided by the regulations from which exemption is sought. VI. DRUG AND ALCOHOL PROGRAM Petitioner will have policies in place to ensure that no person may participate in CRW-UASs flight operations if they are under the influen ce of alcohol or any drug. VII. PUBLIC INTEREST The public interest will be served by granting Petitioner 's Petition for Exemption. Congress has established a national policy that favors early integration of UAS into the NAS in controlled, safe working environments such as tho se proposed in thi s Petition. Granting this P etition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act-the FAA Administrator's assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily required rulemaking.

19

. Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-20 14-0382 at 10). 20

. The CRW

- UAS gro und control station displays, the UASs position, navigation route, tail number, altitude, heading, no1th seeking arrow, range to targets, calculated target position, date/ time, and sensor heading and orientation relative to the VAS

.U.S Department ofTransportation March 2, 2016 Page20 The proposed CRW-UAS operations in this Peti ti on for Exemption significantly improves the safety and reduces risk of harm, physical injury and property damage to the public at large, the property owners from whom permiss ion was granted for use by Petitioner and abutting properties , staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be 

### in the local vicinity. Traditional method s of inspecting and monitoring potential locations and relevant si tes and facilities requires locat ion personnel to climb towers , trees , venture onto precarious roofs and other dangerous scenarios , perform elevated work for which the indi vidual is neither trained nor equi pped to perform, which exposes them to unnecessar y risk of serious phy s ica l injury from dangerous falls or other physical mishaps. Moreover, inspectors/s urveyors are often unnecessarily exposed to hazardous conditions, w1safe environments , culturally tense situations and other hazards associate d with identifying specific locati ons for potential recording sites to be used in the end product. The use of small UASs can eliminate these hazards and ultimately create a much safer method of performing these types of inspections creating a safer environment for the public as well as Petitioner employees. The use of small UAS also enhances safety and reduce s ri sk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of an accident, Petitioner's s mall battery powered CRW-UAS presents signifi cantly le ss danger to persons on the ground when compared to operations by conventional manned airc raft. 21 As Petitioner's CRW-UAS are battery powered , the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing in the same func ti ons proposed herein. Ai r quality will naturally be improved with the reduction of fuel power ed vehicles. Lastly, as recognized by the FAA in prior Section 333 Grants ofExemption to filmmakers , UASs provide an additional econom ic tool for the aerial filming notwithstanding the industry, adding a greater degree of flexibility , which supplements the current capabilities offered by manned aircraft

. 22 The quality of the finished product is e nhanced and provides a greater finished product demand which will aid the current UAS industry and prov ide additional jobs as the cost of providing the needed product is greatly reduced while r educing the difficulty with which the fini s hed product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility of production ; therefore , g iven the lower cost, o wner /operators and others in the relevant indus try will be more inclined to utili ze the services of commercial UAS along with an appropr iate licen sed PIC's.

2 1 See Grant of Exemption No. 11158 to Team 5 , LLC (FAA-20 14

-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an on board pilot, in addition to other on board crewmembers , as necessary. The petitioner's UAS will weigh le ss than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantl y reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident Risk to an onboard pilot and crew dur ing an incid ent or accident is eli minated with the use of a UA for the aerial filming operation." 22 See e .g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-20 14-0794 at 18).U.S Department ofTransportation March 2, 20 16 Page 21 

### VIII. PRIVACY All CRW-UAS operations will be conducted in accordance with applicable federal, state, and local laws rega rding privacy. All operations shall be conducted over private or co ntrolled-acce ss property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY Pursuant to 14 C.F.R. Part II , the following summa ry is provid ed for publication in the FEDERAL REGISTER, should it be determined that publication is needed: Petition er seeks an exemption from the following rules in Title 14 of the Code ofFederal Regulation s: Part 21, Subpart H ; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c) ; 91.103; 91.109(a); 91.119(c); 91.12 1 ; 91.151(a); 91.203 (a) & (b); 9 1.405(a) ; 91.407(a)(l); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with convention al fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Petitioner 's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operation within VLOS and national security

. The proposed CRW-UAS operations will benefit the public as a whole by improving safety and reducing ri sk by alleviating human exposure to danger while lowering the attendant related costs thereby increas ing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemption provides the FAA with more than adequatejustification for granting the reque sted exemptions allowing Petitioner to use small CRW-UAS s in the recorded production of its product. We thank you for your prompt consideration of our requested exemption s. Respectfully Submitted,

# ~#= Coty R. Wood Gaia Herbs, Inc. 10 l Gaia Herbs Rd Brevard, NC 28712 Phone: 828.883.6000 Email: crw@gaiaher bs.comU.S Department ofTransportation March 2, 2016 Page 22 (The following attached items contain proprietary and commercial information exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. 

### § 11.35(b )). Attachments: 1. General Operat ions Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. P ost Fli ght Checklist I0. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance M anuals

PETITIONER REQUESTS THAT GOOD CAUSE EXISTS TO EXEMPT ANY PART OF THIS P ETITION FROM B E ING PUBLISHED IN THE FEDERAL REGISTE R PUBLIC FORUM BECA USE THE R E QUESTED EXEMPTION WO U LD NOT SET A PRECEDENT, AND ANY DELAY IN ACTING ON THIS PETITION WOULD BE DETRIM ENTAL TO THE J> ETITIONER.