Corey L. Hart

2428 South 48 th Street Omaha, NE 68106

October 18, 2015

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

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

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION

REGULATIONS FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 14 C.F.R. Part 21, Subpart H, 91.203(a) (1); 45.23 (b). 91.7(a); 91.9 (b) (2); 91.103; 91.119 (c); 91.121; 91.1 51(a); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). CONCERNING COMMERCIAL OPERATION OF

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Dear Sir or Madam:

I am an owner of a video production company based in Omaha, Nebraska and have been working in the film and video industry for 15 years. It is my desire to add aerial observation, inspection, photography, and cinematography to the list

of services that I ca n provide in an effort to remain competitive in the industry. Existing regulations regarding small, unmanned aircraft inhibit this pursuit.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, I, Corey L. Hart (Petitioner), Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on

- demand commercial UAS operations for a host of industries and applications and to perform the purposes listed below, hereby apply for an exemption from t he listed Federal Aviation Regulations (“FARs”) to allow commercial operation of my sUAVs/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f).

As described more fully below, the requested exemption would permit operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in t he fields in which it operate s . Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system” (Section 333(c) of the Reform Act).Name and Address of Petitioner

Corey Lee Hart

2428 South 48 th Street Omaha, NE 68106

Regulations from which the Exemption Relief is requested:

14 C.F.R. Part 21, Subpart H 14 C.F.R. § 91.203(a) (1) 14 C.F.R. § 45.23 (b) 14 C.F.R. § 91.7(a) 14 C.F.R. § 91.9 (b) (2) 14 C.F. R.§ 91.103 14 C.F. R.§ 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151 (a) 14 C.F.R. § 91.405 (a) 14 C.F.R. § 407 (a) (1) 14 C.F.R. § 409 (a) (2) 14 C.F.R. § 417 (a) & (b )

Background

In 1995 I earned my Private Pilot’s license and attained my instrument rating in

1997. I have held a Commercial Pilot’s license since 1998 and was last active in

2003. I have been involved in the building and piloting of remote controlled

aircraft as a hobbyist since 1998

, currently own a DJI Inspire 1, and have an in

depth understanding of the capabilities and safety concerns involved in using this technology as an asse t to the community.

Public Benefit

The present systems of photography, videography, mapping and inspecting agricultur al land, inspecting buildings or large structures

, site surveys, monitoring wild life, and insect control, are now conducted by humans or by the use of

conventional aircraft. Current procedures can result in significant injuries due to personnel falling, or flying debris from low altitude flyovers by conv entional

aircraft. In the instance of low altitude flyovers by conventional aircraft, the lives

of pilots and camera operators are also at increased risk.

Orders of magnitude larger than sUAVs, conventional aircraft carry flammable

fuels that are not carr ied by a UAS and emit pollutants associated with internal combustion engines. The sUAV’s proposed herein are battery powered and have no emissions. In the case of conventional aircraft, t he present system exposesthose not only in the immediate area of ope rations, but those who are along the path of flight associated with arrival and departure at the operation site. By contrast, the sUAV is carried to the site and transits no other property. Additionally, conventional flights are significantly more expensive than those

undertaken with a sUAV.

Commercial Mission

Petitioner’s use of sUAV’s will be for t he capture of high

- resolution imagery and

video to identify, record, memorialize events and objects a ccording to the purposes noted below.

The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure, to conduct bridge inspections, flare stack inspection, utility

- power generation s ystem inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lin es, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, constructio n site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video

feed to as sist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, live feed and live newsgathering, training to persons individu ally or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events including high schools, colleges, professional sports, open air events and fairs resear ch, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events.

The UAS will b e operated by Corey L. Hart and/ or contracting operators on occasion, to capture high

- resolution imagery/vide o of large structures (wide and tall) such as warehouses, high rise buildings, bridges, and construction sites. Given the small size of the sUAV’s involved (no more than 55 lbs.), an average speed of operation between 5

- 35 mph, and the restricted environme nt within which they will be operated, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraftsystems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the pub lic or pose a threat to national security in light of the following:

• The UAS’ size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; • Operation of the UAS within visual line of sight of the Operator.

Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system” (Id. §333(c))

.

Given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeronautical chart

, unless a letter of agreement with that airport’s management is obtained, Petitioner requests that operations over congested or densely populated areas be allowed. The sUAV’s have GPS geo

fencing, operate at a low altitude within confined areas, operate at low speed, and weigh no more than 55 lbs. Such operations will only be under

- taken with the approval of the land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building unless the land owner has provided permission and the Operator has made an assessment of safety risk(s) from such operations.

Description of Type, Make and Models of sUAV/UAS Requested

Corey L. Hart is seeking an exemption to commercially operate sUAV’s makes

and mode l s as follows:

3DRobotics Aero 3DRobotics Solo

3DRobotics X8 DJI Inspire 1

DJI Matrice 100 DJI Phantom 2

DJI Phantom 3 DJI Spreading Wings S800 DJI Spreading Wings S900 DJI Spreading Wings S1000 Freefly Alta Freefly Cinestar

- 8

In tuitive Aerial Aerigon IAH3 SABRE HL48 Skyhorse SenseFly eBee Yuneec Q500 Typhoon

Each separately weighs 55 lbs. or less, with imaging payload, sensors, and applicable equipment.

Equipment operation manuals for each sUAV are included in these documents under Appendix A for your reference and are considered confidential information for each respective company’s UAS.Commitment to Safety

As a privileged holder of a Commercial Pilot’s license with instrument rating, I have a healthy respect for proce dure and safety. I conduct an extensive pre

- flight checklist and inspection of aircraft systems. I obtain all necessary permissions prior to operation and do not operate within 5 miles of an airport unless prior

contact to Air Traffic Control or the airport ma nager has been established. I conduct safety briefings prior to every flight, designate a person to call 911 in the event of an emergency, determine whether anyone on site is CPR certified,

indicat e the flight p lan, and mak e sure everyone is aware of poten tial hazards. I pilot my UAS through remote control by line of sight and with a spotter while filming. Most flights include a n additional dedicated camera operator. My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then lands if communication with the remote control is lost. I land my UAS prior to the manufacturers recommended minimum level of battery power

. I actively analyze flight data and other sources of information to constantly update and enhance safety pr otocol, and I have procedures in place to abort flights in the event of safety breaches or potential danger.

My Preflight Checklist is as follows:

• Identify geographic or human obstacles that challenge a safe flight. • Conduct safety briefing.

• Ignition switch (s) off. • Propellers removed. • Inspect wings/propellers /fuselage /control surfaces for damage

. • Battery levels for aircraft, controller , ground station and mobile device full

. • Verify recording media is installed.

• Power on controller, g round station, mobile device and aircraft.

• Verify m obile device

, application and aircraft are connected. • Calibrate IMU, gimbal, and compass. • Verify c ontrol surfaces/motor direction(s) are correct, free and clear. • Power down aircraft, mobile device

, and controller. • Mount propellers correctly and firmly. • Clear aircraft vicinity.

• Power on controller, mobile device and aircraft.

• Advance throttle and begin mission

.

Aircraft And Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent

, or even higher level of safety

, to operations under the current regu latory structure as the proposed operations represent a safety enhancement to current operations conducted withconventional aircraft or humans climbing structures . These conditions are drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 111 09, 11112,

and 11213 and as recent as 11857. These limitations and conditions to which Corey L. Hart agr ees to be bound when conducting commercial operations under

an FAA issued exemption include:

1) Operations authorized by this grant of exemption are limit ed to the aircraft

desc ribed in the Operator’s manuals found in Appendix A. O perations of

any other aircraft will require a new petition or a petition to amend this grant. 2) The UA may not be flown at an indicated airspeed exceedi ng 5 0 mph (10 mph during inspections). 3) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must be in feet AGL. 4) The UA must be operated within visual line of sight (VLOS) of the Aircraft Operator at all times. This requires the Aircraft Operator to be able to use human vision unaided by any device other than corrective lenses. 5) The Exemption Holder’s Manuals must be amended to include all

conditio ns and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the Exemption Holder ’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed, otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or

revise its Manu als. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator

upon request. The Exemption Holder must also present updated and revised documents if it petitions for an extension or a mendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition for amendment to its exemption. 6) Prior to each flight, the A ircraft Operator must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been perfo rmed, and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 7) Any UAS that has undergone mainte nance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight andaircraft record entry must be added to the Exemption Holder’s Operator’s

manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals. 9) The Exemption H older must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized technician returning the UAS to service. 10) The authorized technicians must receive and document training referenced in the Exemption Holder’s Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer System and Safety Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between inspections. 13) Prior to commencing operations, the Aircraft Operator shall have logged at least 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type and 5 hours in the make and

model. 14) If the UAS loses commun ications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property and land or be recovered in accordance with the Exemption

Holder’s Manuals. 15) The Aircraft Operator must abort the flight in t he event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption Holder’s Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind and forec ast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Groun d Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.20) The UA must remain clear and yield the right of way to all other manned operations a nd activities at all times (including, but not limited to, ultra

- light vehicles, parachute activities, parasailing activities, hang gliders, etc.). 21) The UA may not be operated by the Aircraft Operator from any moving

device or vehicle. 22) UAS operations may not be conducted during night, as defined in 14 CFR

1.1. 23) All operations must be conducted under visual meteorological conditions (VMC). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibilit y is less than 3 statute miles from the Operator. 24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airpo rt’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required by the Operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 25) The UA may not be operated over congested or densely populated areas unless the conditions set for in #26 are satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronauti cal Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d)(1). 26) Flight op erations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a) Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The

Air craft Operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations must cease immediately and/or; b) The aircraf t is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of the risk of operating closer to those objects and; c) Operations near the Aircraft Operator do not present an undue hazard to the Operator per § 91.119(a). 27) All operations shall be conducted over private or controlled access 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. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to t he FAA’s UAS Integration Office (AFS

- 80)within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

14 C.F.R. Part 21, Subpart H , 14 C.F.R. §91.203(a) (1):

Airworthiness Certificates

Subpart H, entitled Airworthiness Certifica tes, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated wit h the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H

meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f))

and Section 333 of t he Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certifi cate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In a ll cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing o r rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS s to be operated hereunder are less than 55 lbs. fully loaded, carri y neither a pilot nor passenger, carries no explosive materials or flam mable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance

with lo cal public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, applic ation of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a s ubstantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words
"limited," "restricted ," "light

- sport," "experimental," or "provisional," as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may

be needed as the sUAS will have no entrance to the cabin, cockpit or pilot stationon which the word “Experim ental” can be placed. Given the size of the sUAS,

two

- inch lettering will be impossible. The word “ Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the sUAS as “Experimental.”

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operat e a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist

for airworthiness of the UA. Given the size of the aircraft and th e requirements

that the Operator has agreed to as it relates to airworthiness, as contained in the
manual, an equivalent level of safety will be achieved by insuring compliance

with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and

11110.

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

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 esta blishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route

or altitudes prescribed for helicopters by the FAA. As this exemption is for a

sUAS that is a helicopter and the exemption requests authority to operate ataltitudes up to 400 AGL, an exemption may be needed to allow such operations. The equivalent level of safety will be achieved given the size , weight, and speed

of the UAS as well as the location where it is operated. No flight will be taken

without the permission of the property owner, facility owner, and/or local officials.

Because of the advance notice to the property owner and participants, all

affected individuals will be aware of the planned flight operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft weighing far

more than the maximum 55 lbs. and the lack of flammable fuel, any risk

associated w ith these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

- UAS o perations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067,

11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulat ion requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAV, in manual or eme rgency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of sa fety. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and

11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a fligh t in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed: 1) During the day, to fly after that for at least 30 minut es or; 2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’ proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight is

reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed MartinCorporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or

officia l representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limi ted operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b):

Main tenance Inspections

These regulations require that an aircraft Operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sectio ns will not apply to the Petitioner. Maintenance will be accomplished by the Operator

, or manufacturer

, pursuant to the flight manual

and operating handbook as referenced in the attached confidential manuals in Appendix A. An equivalent level of safety wil l be achieved because these small UASs are very limited in size and will carry a small payload and operate only in

defined areas for limited periods of time.

If mechanical issues arise, the UAS can land immediately and will be operating from no higher tha n 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 a nd 11110.

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:Petitioner seeks an exemption from the following rules: 14 C.F.R. Part 21, Subpart H ; 14 C.F.R. § 91.203(a) (1) ; 45.23 (b) ; 91.7(a) ; 91.9 (b) (2) ; 91.103 ; 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small, unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial su rveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production surface mining, closed set filming disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Inspection will be of inanimate objects in

areas where the owners will have consented to the inspections or otherwise have agreed to allow the UAS and the Operator to be in the area where operations will take place.

The size of the UAS, its speed and restricted area of operation do not raise national security issues.

Summary

Approval of exemptions allowing commercial operations of sUAV’s for the petitioner to operate an unmanned aircraft system (UAS) will enhance safety by reducing risk. Conventional aircraft operations expose operators and civilians to higher risk s than those created by use of sUAV’S. The operation of battery powered sUAVs, is friendlier to the environment than the use of aircraft burning

Jet A or 100LL. S UAV s carry no passengers or crew, eliminating exposure to the risks associated with manned aircraft flight s.

The operation of small UASs, weighing less th an 55 lbs., conducted under the

strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweightaircraft operate at slow speeds, close to the ground, and in areas that are under

control . A s a result, operations are far safer than those conducted with turbine helicopters operating in close proximity to the ground.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

, size, weight, speed, operating capabilities, proximity to a irports and populated areas

and operation within visual line of sight and national security, provide more than adequate justification for the grant of the requested exemptio ns allowing commercial operati on of Petitioner’s UAS for the p urposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as

recent as 11857.

Sincerely, Corey L. Hart

2428 South 48 th Street Omaha, NE 68106A PPENDIX A

– TECHNICAL MANUALS AND SPECIFICATIONS

3DRobotics Aero https://3drobotics.com/wp

- content/uploads/2014/10/AeroM

- Operation

- Manual

v1.pdf

3DRobotics Solo https://3drobotics.com/wp

- content/uploads/2015/09/v6_09_22_15.pdf

3DRobotics X8 https://3drobotics.com/wp

- content/uploads/2015/04/X8

- Operation

- Manual

- vC.pdf

DJI Inspire 1 http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

DJI Matrice 100 http://download.dji

innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf

DJI Phantom 2 http://download.dji

innovations.com/downl oads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en. pdf

DJI Phantom 3 http://download.dji

innovations.com/downloads/phantom_3/en/Phan tom_3_Professional_User_Man ual_v1.4_en_0915.pdf

DJI Spreading Wings S800 http://download.dji

- innovations.com/downloads/s800/S800_User_Manual_en.pdf

DJI Spreading W ings S900 http://download.dji

innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

DJI Spreading Wings S1000 http://download.dji

innovations.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf

Freefly Alta http://d27w8s76bjlz9v.cloudfront.net/wp

content/uploads/2015/07/28175748/ALTA_Manual_RevB.pdfFreefly Cinestar

- 8 http://d27w8s76bjlz9v.cloudfront.net/wp

content/uploads/2014/07/cinestar8Manual

- v4.pdf

Intuitive Aerial Aerigon IAH3 http://www.intuitiveaerial.com/specs/

SABRE HL48 Skyhorse http://www.sabresurvey.com/uav.html

SenseFly eBee https://www.sensefl y.com/fileadmin/user_upload/sensefly/documents/manuals/Ex tended_User_Manual_eBee_and_eBee_Ag_v16.pdf

Yuneec Q500 Typhoon http://www.yuneec.com/download/manuals /typhoon_q500_instruction_manual_v 2.1.pdf