## Petition for Exemption

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

U.S. Depart ment of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

Septem b er 1 5 th, 2015

RE: Petitioning for Exemption under Section 333

Collins Constructio n Inc.

, DBA C ollins Inspection Services and Collins Real Estate Services

, ( hereafter
referred to as CCI ) respectfully request to submit our Petition for Exemption for Unmanned Aircraft System (UAS) operations. We are a well

- established , licensed and insured business. We have curr ently logged over 1000 hours of flight time wit h Multi Rotor UAS and model helicopters. We are looking to
operate our UAS for use in commercial applications for the real esta te, cons truction and inspection
industries. We would further like to extend o ur scope to photography and videography. We are request ing exemption of the sections identified below. Approving this request will serve the public, i ts economic interest and will contribute to the public safety

. We are kno wledgeable of the FAA ruling s and
restricted operational airspace. We put safety of the public , operators and personal property as our top priority. By allowing us this exemption

, we will be able to further our research and development of new marketing and inspection methods to best benefit the general public and our specific indust ries as a
whole

.

Sections of the Code of Federal Regulations that we are seeking exemption from;

14 C

. F

. R: part 21 Subpart

- Airworthiness Certificates
14 C.F.R. §45.23(b )

- Display of marks; general 14 C.F.R. § 45.27

- Location of marks; nonfixed

- wing aircraft

. 14 C.F.R. § 61.113(a) and (b )

- Private pilot privileges and limitations: Pilot in command

. 14 C.F.R. § 61.1 33 (a )

- Commercial pilot privileges and limitations

. 14 C.F.R. § 91.7 (a )

- Civil aircraft airworthiness

. 14 C

. F

. R

. § 91.9(b ) ( 2 )

- Civil aircraft flight manual, marking, and placard requirements

. 14 C.F.R. § 91.119 (b) and (c )

- Minimum safe altitudes: General

. 14 C.F.R. § 91.121

- Altimeter settings 14 C.F.R. § 91.151(a) and (b )

- F uel requirements for flight in VFR conditions

. 14 C.F.R. § 91.405(a )

- Maintenance required

. 14 C.F.R. § 91.407(a ) ( 1 )

- Operation after maintenance , preventive maintenance, rebuilding, or alteration.
14 C.F.R. § 91.409(a ) ( 1) and (2 )

- Inspections

. 14 C.F.R. § 91.417(a) and (b )

- Maintenance records. Please also include any other sections from previously granted exemptions that y ou feel would be helpful in our operations.Airworthiness Certification

CCI proposes to utilize the following professional grade Unmanned Aircraft System s ; DJI S900; DJI S800 EVO, and DJI F550. All units are equipped with DJI Wookong Control Systems with GPS. This control
system significantly exceeds the precision and stability of the control systems of previously approved DJI
Phantom units.

The extent of relief we are seek ing and the reason we are seek ing t he relief:

W e are requesting relief and exemption from the listed Federal Aviation Regulations and any other applicable rules in order to allow the use of a Small Unmanned Aircraft System (UAS). We are looking to provide aerial marketing of real estate and building, bridge, dam and roof inspections

. In addition

, to survey construction sites and potential developmen t sites. We would also like to utilize the excellent photography and videography capabilities of these units for photography and filming as requested by
clients

, not limited to closed

- set motion picture and television filming

.

How our request would benefit the public as a whole:

1. Eliminate t he need for aerial photography by a manned aircraft, increasing safety.

2. Eliminate use of ladders, scaffolding and other means of access that put construction and inspection personnel at risk of falls.

3. Provide faster results to the public for services.

Reasons why the exemption would not adversely affect safety ;

The exemption will not adversely affect safety due to the following safety protocols ;

1. A visual observer (VO) in addition to the Pilot

- in

- Command (PIC) will be mandatory at all times.

2. C ommunication will be maintained between the VO and PIC at all times.

3. The UAS will neve r be flown near manned aircraft or airports

. 4. A consent form will be required to be signed by private property owner s during operations

. 5. All non

- participating persons will be asked to move to a safe area beyond the perimeter of operations

. 6. During operations maxi mum of 400 feet above ground level (AGL ) will be maintained

7. A barrier with signage will be set up at every flight location to alert the public of an UAS operations in progress.
8. A GPS controlled perimeter range from point of takeoff will be enabled on the UAS so the
aircraft will be limited to th e airspace above the property where operations are being
conducted.

9. The UAS will always be in the line of sight of the PIC and VO at all times.

10. UAS will never carry any dangerous materials or flammable liquids.

11. T he UAS flight will end at 29 mi nute s of flight time or when the battery level reaches a point of
25%.

12. All UAS controls will be equipped with a return to home switch to help prevent loss of control
due to malfunction or loss of orientation.13. The UAS has integrated GPS pilot syste m and on screen display system provides distance from

point of takeoff, height AGL, speed, battery voltage , and can be programmed for no

- fly zones.

14. The PIC will have access the manufacturer operation manual and will be available upon request.

15. The PIC and UAS flight will abide all pre

- flight checks and suggested flight protocols from
manufacturer

. 16. A log will be kept of all flights and l ocations.

17. T ake

- off, landing and emergency landing zones will be designated before the beginning of the flight.

18. All radio frequency used for the operation and controls of the UAS will comply with the FCC and any othe r agencies.
19. Operations will not occur under IFR conditions.

20. CCI will maintain a $1,000,000 insurance liability policy at all times during the operation of the

UAS.
21. The UAS will have all the proper contact informatio n and the federal exemption number attached to it permanently.

22. In the event that that UAS fails any pre

- flight inspections, the UAS will be grounded permanently until the manufacturer issues a compliance certificate stating that the UAS has been fixed and has been inspected and deemed safe to fly again.

Summary;

a) Rules we are seeking exemption from ;

CCI is seeking exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.1 33 (a) ; 14 C.F.R. § 91.7 (a) ; 14 C

. F

. R

. § 91.9(b)(2) ; 14 C.F.R.§
91.119 (b) and (c); 14 C .F.R. § 91.121; 14 C.F.R. § 91.151(a) and (b) ; 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b)

b) A brief description of the exemption s we are seek ing ;

CCI is seeking exemption for the above listed sections of the Code of Federal Regulations so that we may legally provide better and safer services to the general publi c and our industries. By the use of a UAS to perform work that would require ladders, scaffolding or low flying manned aircraft we are improving the overall safety of the general public and workers. Furthermore we are able to provide a much quicke r turn around for services to the public.

We do not wish to use the rights of our exemption outside of the United States.

Thank You,

Scott A. Collins
Collins Constructio n Inc.

, DBA C ollins Inspection Services and Collins Real Estate Services 1135 Terminal Way #209 Reno, NV 89502
916

- 705

- 5542 CollinsConstructionInc@Gmail.com