Remote Imagery Solutions LLC 9304 Wyndham Hill Lane Spotsylvania, VA 22551 Kris@RemoteImagerySolutions.com (mobile) 202

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September 25, 2015

U

. S

. Department Of Transportation

Federal Aviati on Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, Remote Imagery Solutions LLC , owner and operator of Small Unmanned Aircraft Systems (UASs), requests to be exempted from the Federal Aviation Regulat ions (FAR) listed below so that Remote Imagery Solutions LLC may operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as

re quired by Section 333.

Remote Imagery Solutions LLC (a n aerial photography and videography company) is owned by Kristoffer John Buquet, a Virginia resident, with a Virginia

Drivers license. Mr. Buquet is currently studying for his sport pilots license (S PL )

and will be the PIC upon obtaining his SPL . All operations will be performed with the public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for sa fe operation of such aircraft systems in national airspace systems.” Section 333(c), of the Reform Act.

Remote Imagery Solutions LLC UAS (The 3DR SOLO quadcopter) is a rotorcraft weighing less than 55 pounds including payload. It operate s at a s peed

less than 50 knots and has the capability to hover and move in the vertical and

horiz ontal plane simultaneously. It has an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight within aprotected flight area as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the

environment.

Remote Imagery Solutions LLC respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 ( b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

Remote Imagery Solutions LLC submits this application in accordance with the Reform Act , 112 P.L. 95 331-334, seeking relief from any currently

ap plicable FAR’S operating to prevent Remote Imagery Solutions LLC future commercial use of small UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil

unmanned aircraft into our national airspace system as it is in the public’s interest

to do so. Remote Imagery Solutions LLC UAS meet s the definition of “small

unmanned aircraft” as defined in Section 331 and t herefor the integration of this

UAS is expressly contemplated by the Ref orm Act. Remote Imagery Solutions

LLC would like to operat e its lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consi der whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability Operation of the UASs in close proximity to airports and populated areas Operation of the UASs within visual line of sight of the operator

.

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System , the secretary shall establish requirements for the safe operation in national airspace.

Remote Imagery Solutions LLC rotorcraft weighs less than 55 lbs. and it operate s at sp eeds less than 50 knots and has the capability to operate in the

vertical and h orizonta l plane simultaneously. The UAS will operate only within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.The very small nature of these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear

direct ion given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of grea tly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on opera tions of Remote Imagery Solutions LLC

,

Flights will only occur in the daylight hours, Flights will be operated in the line of sight of the operator (PIC) and Observer,(VSO) Flights will be terminated at any time weather and wind deteriorate to “unsafe f or flight” by manufacturers recommendations,

The UAS will weigh less that 55 lbs., Flights will be operated at 200 feet AGL or less. Crew will be at a minimum of operator(PIC) and an observer and/or camera operator(VSO), Operator and crew will remain i n contact during the flight operation, The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area, Consent will be obtained from all persons within the video capabilities of the units

to further re duce the chance of violating anyone’s privacy. All required FAA clearances, will be obtained and distances from airports strictly

observed. All UASs will have the capability to return automatically to the operator in a safe

manner with the auto return fu nction checked and working. Flights will only operate in VFR conditions. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining. Flight team will communicate by voice and the use of two-w ay radio if the area is too big to hear voice from all team members.

UASs will be used to video for commercial consulting and sales

. When operating over or near water the UASs will be equipped with flotation devices so that recovery can be made as to prev ent lithium battery exposure to

the water table.14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Remote Imagery Solutions LLC UAS flights permits exc eption from Part 21 because it meet s an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorize d to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, s ize, speed, maneuverability and proximity to areas such as airports and dense populations. Remote Imagery Solutions LLC

meets or exceeds each of these elements.

As of March 23, 2015 the FAA has stated that it will automatically grant a

“blanket” COA for f lights at or under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of sa fety will be achieved by maintaining such certifications and registrations at Remote Imagery Solutions LLC operations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applic able in the form contemplated by FAR’s this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight

Manual in Aircraft

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Remote Imagery Solutions LLC operations

center. The FAA has previously issued exemptions to thi s regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A ,10602,10700 and

32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain

conditions. Remote Imagery Solutions LLC will only operate its UAS at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private property that the owner has

consen ted and all persons within this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public.Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing

the overall risk associated with traditional aircraft. Tra ditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury of p eople on the ground or the crew has been reduced or almost erased.

Granting Remote Imagery Solutions LLC the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the masse s.

Remote Imagery Solutions LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by West Edge Collective, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely

,

Kristoffer John Buquet CEO & Manager Remote Imagery Solutions LLC 9304 Wyndham Hill Lane Spotsylvania VA 22551 Kris@RemoteImagerySolutions.com (mobile) 202

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