November 6, 2015

U.S. Department of Transportation Document Management System 1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam:

SUMMARY

MEADORS INC. (“ Petitioner ”), through the instant petition (the “ Petition ”), seeks exemption from the regulations listed below, to ope rate Unmanned Aircraft Systems, pursuant

to Section 333 of the FAA Modernization and Reform Act of 2012 (the “ FMRA ”). This exemption will permit Petitioner to operate a UAS f or the commercial purpose of conducting aerial photography, videography, surveying, and dat a collection in compliance with the conditions outlined below or as established by the Federal Aviation Administration (“ FAA ”).

BACKGROUND

The specific exemptions below are being requested b ecause: (1) existing regulations will burden Petitioner, (2) Petitioner can provide a lev el of safety that is equal or greater than those provided by the existing rules, and (3) the request is in the public interest.

A. Contact Information of Petitioner

The name and address of Petitioner is:

MEADORS INC. c/o James Webb, Director of Estate Management & Mai ntenance P.O. Box 21758 Charleston, South Carolina 29413 (843) 708-7153 jim@meadorsinc.com

B. Description of Petitioner

Petitioner offers architectural design, constructio n, millwork and cabinetry, conservation

and maintenance services. Petitioner will use a UAS to take photographs, video, surveys and collect data relating to its business operations. G enerally, Petitioner will use said video, photographs, surveys, and data to document the prog ress of the projects it is working on for thePage 2

purpose of keeping detailed records and enhancing i ts ability to evaluate the quality and safe completion of the project. Petitioner will also use some of the images and video captured of completed projects to market its services. The use of a UA will enhance Petitioner’s services to its clients and the public by providing a more effi cient, safer method as further described in this

Petition.

C. Summary Process

Petitioner makes this request under the “summary gr ant” process that the FAA announced in April 2015. 1 This request is similar to a number of recent grant s of exemption, including: Exemption No. 12995 to Dragonfly Live, L LC (FAA-2015-2788) and Exemption No. 12965 to Lee Lewis Construction, Inc. (FAA-2015 -2737).

D. Specific Regulations From Which Exemption is Sought 2

Regulations from which the exemption is requested:

• 14 C.F.R. part 21, Subpart H

• 14 C.F.R. § 45.23 (b)

• 14 C.F.R. §§ 61.101(e)(4) and (5)

• 14 C.F.R. §§ 61.113 (a) & (b)

• 14 C.F.R. § 61.23(a)

• 14 C.F.R. § 61.315(a)

• 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. § 91.109

• 14 C.F.R. § 91.119

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151 (a)

• 14 C.F.R. §§ 91.203 (a) & (b)

• 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)

E. Pilot In Command Overview

Any Pilot In Command (“ PIC ”) will be required to hold an airline transport, c ommercial, private, recreational or sport pilot certificate, a nd a current FAA airmen medical certificate or a U.S. driver’s license issued by a state, the Distri ct of Columbia, Puerto Rico, a territory, a

1 See FAA Summary Grants Speed UAS Exemptions, https:// www.faa.gov/news/updates/?newsId=82485.

2 The specific reasons the requested exemptions shoul d be granted are addressed later in this Petition.Page 3

possession or the Federal government. The PIC will also be required to meet certain flight-hour and currency requirements and demonstrate the abili ty to safely operate the UAS in a manner consistent with the operation specifications, inclu ding evasive and emergency maneuvers, as well as maintaining appropriate distances from peop le, vessels, vehicles and structures.

AUTHORITY FOR EXEMPTIONS

This exemption application is expressly submitted t o fulfill Congress’ goal in passing Section 333(a) through (c) of the FMRA. The FMRA di rects the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (the “ NAS ”) before completion of the rulemaking required und er Section 332 of the FMRA. In making this determination, the Secretary i s required to determine which types of

UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS's size, weight, speed, and operational ca pability; • Operation of the UAS in close proximity to airpor ts and populated areas; and • Operation of the UAS within visual line of sight of the operator.

(See FMRA, Section 333(a).)

Lastly, if the Secretary determines that such vehic les “may operate safely in the national airspace system, the Secretary shall establish requ irements for the safe operation of such aircraft in the national airspace system.” (See FMRA, Sectio n 333(c).)

The Federal Aviation Act expressly grants the FAA t he authority to issue exemptions. This statutory authority by its terms includes exem pting civil aircraft – including UASs – from the requirement that civil aircraft must have a cur rent airworthiness certificate.

Petitioner interprets this provision to place the d uty on the Administrator not only to process applicants for exemptions under section 333 , but to also craft conditions for the safe operation of the sUAS, if it should be determined t hat the conditions set forth herein do not fulfill the statutory requirements for approval.

Given the small size of the UASs involved, and the restricted environment within which they will operate, Petitioner falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA s hould, by exemption, allow commercial operations of UASs to commence immediately. Also du e to the size of the UASs and the restricted areas in which the relevant UASs will op erate, approval of the application presents no national security issue.

Given (1) the clear direction in Section 333 of the FMRA; (2) the authority contained in the Federal Aviation Act; (3) the strong equivalent level of safety surrounding the proposed operations; and (4) the significant public benefit, including enhanced safety, reduction in environmental impacts (reduced emissions and chemic al spills), and (5) previous exemptions granted allowing UASs for aerial photography, video graphy, surveying and data collection, thePage 4

grant of the requested exemptions in this Petition is in the public interest and supported by the FMRA. Accordingly, the applicant respectfully reque sts that the FAA grant the exemptions as

set forth in this Petition. AIRCRAFT DESCRIPTION, PERFORMANCE, AND MAINTENANCE

Petitioner will operate a DJI Phantom 3 Advance, DJ I Phantom Professional and DJI Inspire 1 (collectively, the “ sUASs ”), which are multirotor aircraft weighing less tha n 7 pounds.

The DJI Phantom 3 Advance and Phantom 3 Professiona l (collectively, the “ Phantoms ”) weigh approximately 2.82 pounds, while the DJI Inspire 1 (the “ Inspire ”) weighs approximately 6.47 pounds. The Phantoms have the ability to operate un der normal conditions at a speed of no more than 16 m/s (approximately 31 knots), while the Ins pire has the ability to operate under normal conditions at a speed of no more than 22 m/s (appro ximately 43 knots). The Phantoms and Inspire have the capability to hover and move in th e vertical and horizontal plane simultaneously. The sUASs will operate only in the PIC’s or Visual Observer’s (“ VO ”) visual line of sight at all times, and includes automatic safety features as described in the User Manuals. The sUASs are equipped with a flight recorder that automatically records flight telemetry, aircraft status information and other parameters.

The sUASs are also equipped with GPS, a Vision Positioning System, and a Return-toHome feature. Return-to-Home is an effective safety measure and has three forms: (1) Smart RTH, (2) Low Battery RTH, and (3) Failsafe RTH.

1. Smart RTH

allows the PIC to initiate said mode calling the s UAS back to the recorded home point. This could be used if the PIC, for whatever reason, deems that the operation cannot continue, or for any other reason the PIC would require the sUAS to return to the home point without the use of the rem ote controller.

2. Low Battery RTH

notifies the PIC when the battery is at depleted l evels and further operation of the sUAS may affect the abilit y to safely complete the operation. If no action is taken by the PIC within 10-seconds, th e sUAS will automatically return to the home point.

3. Failsafe RTH

automatically initiates after signal with the remo te controller is lost for more than three seconds, at which time the sUAS will automatically return to the home point.

Maintenance will be performed regularly as detailed in this Petition, the User Manuals, Safety Guidelines and as required by any grant of e xemption by the FAA. Moreover, all maintenance will be recorded in the Maintenance Log attached and/or submitted with this

Petition.

A further and more in-depth description of the sUAS s and related performance, operating procedures and maintenance can be found in the User Manuals and Safety Guidelines attached

and/or submitted with this Petition. 3

3 The User Manual PDF file for the Inspire was too l arge to submit via the online docket. A copy can be found at: https://dl.djicdn.com/downloads/inspire_1/en/Inspir e%20_1_User_Manual__V1.8.pdf

.Page 5 RULES FROM WHICH EXEMPTION IS SOUGHT AND

REASONS EXEMPTIONS SHOULD BE GRANTED

A. 14 C.F.R. Part 21, Subpart H: Airworthiness certifi cates

Subpart H establishes the procedural requirements f or the issuance of airworthiness certificates. Given the size and limited operating area associated with the sUAS to be utilized by Petitioner, an exemption from 14 C.F.R. Part 21, Su bpart H, meets the requirements of an equivalent level of safety under Part 11 and Sectio n 333 of the FMRA. 49 U.S.C. § 44701(f) and

Section 333 of the FMRA both authorize the FAA to e xempt aircraft from the requirement for an airworthiness certificate, upon consideration of th e size, weight, speed, operational capability and proximity to airports and populated areas of th e particular UASs.

The sUASs to be used by Petitioner will not carry p ersons or property, will not carry combustible fuel, weigh less than 7 pounds, and wil l only fly under strict operational requirements set forth in this Petition and by any exemption granted by the FAA.

An analysis of these criteria by the FAA has routin ely found that UASs operated without an airworthiness certificate, in the restricted env ironment and under the conditions proposed, will be at least as safe, or safer, than a conventional manned aircraft operating with an airworthiness

certificate.

B. 14 C.F.R. § 45.23(b): Marking of the aircraft

Section 45.23(b) requires that: “light-sport catego ry aircraft or experimental or provisionally certified aircraft . . . display on t hat 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,’ ‘experiment al,’ or ‘provisional,’ as applicable.”

The sUASs have no entrance, cabin, cockpit or pilot station on which the word “Experimental” can be placed. Moreover, given the s ize of the sUASs, the two inch lettering will be impossible. Petitioner proposes to achieve an eq uivalent level of safety by including the word “EXPERIMENTAL” in the largest practicable lettering on the sUASs, where the PIC, VO and any other person in the vicinity of the aircraft wh ile preparing for launch will be able to see such designation. The sUASs will be identified by serial number, registered, and have N-Number markings in lettering as large as practicable.

C. 14 C.F.R. §§ 61.101(e)(4) & (5): Recreational pilot privileges and limitations

Sections 61.101(e)(4) & (5) prohibit persons with a recreational pilot certificate from acting as a PIC of an aircraft for compensation or hire and in furtherance of a business. An exemption is therefore required. The FAA has routin ely found that PICs holding a minimum of a sport or recreational pilot certificate and a valid U.S. driver’s license are eligible to operate UASs for a commercial purpose.Page 6

An equivalent level of safety will be achieved by r equiring that the PIC meet minimum flight-hour and currency requirements, demonstrate the ability to safely operate the sUASs in a manner consistent with the User Manuals, Safety Gui delines, and any grant of exemption, including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles, and structures where necessary.

D. 14 C.F.R. §§ 61.113(a) & (b): Private pilot privile ges and limitations: Pilot in

command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. The proposed operations can achieve an equivalent level of safety because the sUASs will not carry a pilot or passengers, and PICs will be required to m eet certain flight-hour and currency requirements and demonstrate the ability to safely operate the sUASs in a manner consistent with the User Manuals, Safety Guidelines, and operation specifications, including evasive and emergency maneuvers, as well as maintaining appropr iate distances from people, vessels,

vehicles and structures.

E. 14 C.F.R. § 61.23(a): Operations requiring a medica l certificate: Requirements and

duration

Section 61.23(a) requires PICs of any flight for c ompensation or hire to hold a comprehensive FAA issued medical certificate. In gr anting exemptions, the FAA has routinely found that a person holding a U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession or the Feder al government, operating UASs will not adversely affect safety. Similarly, the grant of an exemption to Petitioner will not adversely affect safety because all PICs will have – at a min imum – a U.S. driver’s license, will exercise a level of care as described throughout this Petition , and will abide by any and all other conditions provided in any exemption granted by the FAA.

F. 14 C.F.R. §§ 61.315(a) and (c): What are the privil eges and limits of my sport pilot

license?

Section 61.315(a) and (c) restrict sport pilots fr om acting as the PIC of any flight for compensation or hire, or in furtherance of any busi ness. The FAA, however, has provided that PICs holding a sport or recreational pilot certific ate and a valid U.S. driver’s license are eligible to operate UASs for a commercial purpose. All of Pe titioner’s PICs will be required to have – at a minimum – a U.S. driver’s license, meet minimum f light-hour and currency requirements, demonstrate the ability to safely operate the sUAS in a manner consistent with the User Manuals, Safety Guidelines, and any grant of exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distances from people, vess els, and structures where necessary.

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

Section § 91.7(a) requires that no person may opera te a civil aircraft unless it is in airworthy condition. Since there will be no airwort hiness certificate issued for the aircraft shouldPage 7

this request for exemption be granted, the PIC will ensure that the sUASs are in airworthy condition based upon its compliance with the User M anuals, Safety Guidelines and review of the Maintenance Log prior to every flight. The PIC will conduct a pre-flight inspection to determine that the sUAS being used is in condition for safe f light. During the pre-flight inspection the PIC will take into account any inoperable components, i tems, or equipment. If the PIC discovers a condition affecting the safe operation of the sUAS, the aircraft will not be operated until the necessary maintenance is performed and the sUAS is in safe flying condition.

Given the size of the aircraft and the requirements contained in the User Manuals and Safety Guidelines for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be achieved.

H. 14 C.F.R. § 91.9(b)(2): Civil aircraft flight manua l, marking and placard requirements

Due to the small size and configuration of the sUAS s, and the fact that there is no pilot, crew, or passengers onboard, it is not possible to place or carry such a flight manual on the aircraft. The equivalent level of safety will be ma intained by keeping the User Manuals, Safety Guidelines and any other operating documents at the Ground Control Station where the PIC, VO or any other person involved with the operation wil l have immediate access to said documents.

I. 14 C.F.R. § 91.103: Preflight action

Section 91.103 requires each PIC, prior to beginnin g a flight, to become familiar with all available information concerning that flight, inclu ding, runway lengths at airports of intended use, and the following takeoff and landing distance information. This is not applicable to the operations proposed since no airports, or runways w ill be necessary.

To provide an equivalent level of safety, each indi vidual operation will have a flight plan that will be thoroughly reviewed with the PIC and V O. The PIC and VO will review current and future weather forecasts for the vicinity that the operation is to take place, flight battery requirements, aircraft performance data, and any ot her relevant information to the operation. The PIC and VO will also review all site-specific condi tions in preflight procedures and ensure that no obstacles or obstructions to the operation exist , or how such obstacles can be avoided without compromising the safe completion of the operation. No operation will take place unless the PIC determines the same can be completed safely. Lastly , the PIC and VO will ensure all required or suggested pre-flight actions are followed in the Us er Manuals, Safety Guidelines and any grant of exemption.

J. 14 C.F.R. § 91.109: Flight instructions; Simulated instrument flight and certain flight tests

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.Page 8

All subparagraphs of this section address civil man ned aircraft in conjunction with training and flight tests. In addition to the sUASs being unmanned and having no combustible fuel, by design, the sUASs do not have fully functi onal dual controls. Flight control is accomplished through the use of a remote controller that communicates with the aircraft via

radio communications.

The equivalent level of safety is provided by the f act that neither a pilot nor passengers will be carried in the aircraft, the size and speed of the aircraft, and the ability to control the sUAS via radio signals from the controller. Moreove r, any flight instruction taking place would be done at a minimum of 500 feet from other people. Flight instruction will only be conducted during dedicated training sessions, at which time t he sUAS will only be operated an appropriate distance from all non-essential persons to the flig ht instruction.

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

Section 91.119 establishes safe altitudes for opera tion of 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.

The exemption requested herein is for sUASs that fl y in a similar manner to a helicopter, with vertical takeoff and vertical landing. The sUA Ss will never operate at an altitude higher than 400 feet above ground level (“ AGL ”) and all operations will occur during daylight ho urs under visual meteorological conditions (“ VMC ”) only. The sUASs will also remain in the visual line of sight of the PIC and/or VO at all times.

The equivalent level of safety will be achieved giv en the size, weight and speed of the sUASs, as well as the confined location where the s UASs will be operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personn el, all affected individuals will be aware of the planned flight operations. Moreover, compared t o the flight operations of aircraft or rotorcraft weighing far more than the less than max 7 pounds of the sUASs that are the subject of this Petition, and the lack of combustible fuel, an y risk associated with these operations is far less than similarly situated conventional aircraft. The PIC and VO will also survey the area of operation for any potential obstacles or dangers an d notify all involved of the potential obstacles

and how same will be avoided. If the PIC deems the operation cannot be completed safely due to any obstacles, the operation will be canceled or ab orted.

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

Section 91.121 requires each person operating the a ircraft to maintain cruising altitude by reference to certain altimeter settings proscribed therein.

DJI Phantom 3 and Inspire 1 UAs do not have a typic al barometric altimeter onboard, however, altitude information will be provided to t he PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the
sUASs to the Ground Control Station for active moni toring of the altitude and flight path. ThisPage 9

altitude information, combined with each of Petitio ner’s PIC’s skilled operation of the sUASs within the visual line of sight, at or below 400 fe et AGL, will ensure a level of safety equivalent to Section 91.121.

M. 14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) prohibits an individual from begi nning “a flight in an airplane under VFR conditions unless (considering wind and forecas t 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 minutes; or (2) At night, to fly for at least 45 minutes.”

The battery powering the Phantoms provides approxim ately 23 minutes of powered flight, while the battery powering the Inspire prov ides approximately 18 minutes of powered flight. This would render the sUASs unable to meet the 30 minute reserve requirement. Given the confined location of the sUASs within a predete rmined operating area and its ability to land immediately, an exemption is reasonable.

An equivalent level of safety can be achieved by th e PIC not beginning any operation unless (considering wind and forecast weather condi tions) there is enough available power for the UA to conduct the intended operation and to ope rate after for at least five minutes or with the reserve power recommended by the manufacturer, if g reater. In addition, the sUASs have a Low Battery Return-to-Home mode as described above.

N. 14 C.F.R. §§ 91.203(a) & (b): Civil aircraft: Certi fications required

Sections 91.203(a) & (b) require that no person ope rate a civil aircraft unless it has within it an appropriate current airworthiness certificate and an effective U.S. registration certificate. The airworthiness certificate must also be displaye d at the cabin or cockpit entrance so it is eligible to passengers and crew. An exemption is re quested because no airworthiness certificate will be required if the requested exemption is gran ted and, furthermore, the sUASs have no cabin, cockpit or pilot station and are operated wi thout an onboard pilot, crew or passengers. Therefore, there is no ability to place or carry ce rtification and registration documents or to display them in the sUASs.

An equivalent level of safety will be achieved by k eeping these documents at the Ground Control Station where the PIC, VO or any other rele vant person will have immediate access to

them.

O. 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(1) & (2); 417(a) &(b): Maintenance inspections

Section 91.405(a) requires that an aircraft operato r or owner “shall have that aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph (c) of this section, have dis crepancies repaired as prescribed in part 43 of this chapter . . . .” Section 91.407 similarly make s reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenancePage 10

work that has been accomplished by certificated mec hanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to s ervice.

An equivalent level of safety will be achieved beca use the sUASs are small in size, will operate solely in controlled and predetermined area s, and are not large, complex mechanical devices. Petitioner will perform all maintenance an d inspections in accordance with the manufacturer’s User Manuals and any required manufa cturer safety or service bulletins. In addition, the PIC will conduct a pre-flight inspect ion of the sUASs 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 sUASs and no flights will occur unless and until all flight crit ical components of the sUAS have been found to be in a condition for safe operation. All maintenan ce will be recorded in the Maintenance Log

attached and/or submitted with this Petition. A fun ctional flight test will be conducted following the replacement of any flight-critical components. Moreover, the operator is the person most

familiar with the aircraft and therefore is best su ited to maintain it in airworthy condition.

PUBLIC INTEREST

Granting this Petition will further the public inte rest by allowing Petitioner to safely, efficiently, and economically conduct the operation s described in this Petition under certain conditions imposed under any grant of exemption. Mo reover, the FAA has already approved exemptions allowing commercial operations of UASs f or aerial photography, videography, surveying and data collection, finding that such co mmercial operations are in the public interest.

Granting this Petition is in the public interest be cause: (1) the risk to the public is less than when using a manned aircraft for aerial photog raphy, videography, surveying, and data collection, (2) congestion to the NAS will be reduc ed, (3) UASs are efficient and safe, and (4) it will benefit the economy.

A. The Risk to the Public Is Less Than When Using Mann ed Aircraft

Manned aircraft, performing these same essential fu nctions, create a greater risk to the public because said craft are much larger, have com bustible fuel, and carry a human pilot or other crew. In contrast, a UA weighing less than a maximum of 7 pounds, powered by batteries, and utilizing flight systems such as GPS, VPS, and Return-To-Home, eliminate virtually all of that risk given the reduced weight and lack of comb ustible fuel carried onboard. The sUASs will carry no passengers or crew and, therefore, will no t expose them to the risks associated with manned aircraft flights. The sUASs do not require a n airport or runway to take-off and land, and

therefore – unlike a manned aircraft – will not nee d to travel potentially long distances over populated areas to arrive at the operation location

.

B. Congestion of the NAS Will Be Reduced

By reducing the amount of manned aircraft needed to perform aerial photography, videography, surveying, and data collection, conges tion of the NAS will be reduced. This will reduce noise and air pollution, as well as increasi ng the safety of persons and property in the airPage 11

and on the ground. Furthermore, congestion around a irports caused by departing and arriving aircrafts will be reduced, as well as air traffic c ontrol having to handle fewer aircraft that require assistance during takeoff, landing and other instan ces where aircraft require ground control

assistance.

C. UASs Are Efficient and Safe

By using battery power and electric motors, the sUA Ss produce no air pollution, and are a much more environmentally conscious alternative t o the aircraft traditionally used for aerial photography, videography, surveying and data collec tion, which can burn approximately 20-30 gallons of leaded aviation fuel per hour. The sUASs also create far less noise pollution as they are propelled by battery powered, electric motors r ather than internal combustion engines.

Most importantly, the sUASs pose far less potential for collateral damage to life and property in the air and on the ground compared to a manned aircraft weighing approximately 6,500 pounds with much greater wingspans, length an d combustible fuel capacity.

D. Use of the UAS Will Benefit the Economy

Use of UASs will allow United States based companie s to remain competitive and contribute to growth of the U.S. economy. In additi on, due to the rising cost of fuel and the Environmental Protection Agency’s regulatory action s seeking to phase out leaded aviation fuel, U.S. owned and operated companies must adopt new an d alternative methods to remain competitive and cost efficient. UASs have a much lo wer operational cost than manned aircraft, which allows companies to conduct a service more co st effectively, and in many instances a service that the company would not otherwise be abl e to offer. UASs will allow companies to provide a better, more efficient service to clients , which will free up resources to be used in other aspects of a business. The resulting impact of all of this will be greater stability and resources, which will benefit the local, state and the nationa l economy overall.

PRIVACY

All flights will occur over private property or con trolled-access property with the property owner’s consent and knowledge. Therefore, any issues with privacy are minimal or, if certain operations pose privacy concerns, Petitione r will take special precautions to ensure that the privacy of individuals and businesses are not v iolated. Any commercial operations proposed by Petitioner are similar, if not identical, to man ned flights whereby aerial photography, videography, surveying and data collection have bee n done for decades. The confined area of operation ensures that – unlike manned operations – the sUASs will not have to travel from an airport or other takeoff point to the area of opera tion, and therefore will not flyover property or individuals not involved with the operation.

All images, video, and data collected will be used solely to advance the efficiency and quality of services for which Petitioner was hired by its clients, and will not be published or shared with anyone other than in the furtherance of said services and with the consent of any person depicted therein.Page 12 EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that the exemptions requested a pply to civil aircraft that have the characteristics and that operate within the limitat ions listed herein. These limitations provide for at least an equivalent or even higher level of safe ty than operations under the current regulatory structure, because the proposed operations represen t a safety enhancement to the already safe protocols followed by aerial photography, videograp hy, surveying and data collection operations conducted with helicopters and other conventional m anned aircraft. The limitations will ensure that any risk to the NAS and persons/property on th e ground are minimized.

In addition to any measures described above in this Petition, Petitioner will be bound by the following limitations when conducting its UAS o perations under any FAA issued exemption:

1. The UA will weigh less than 55 pounds including pay load.

2. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In any event, the Phantoms have a maximum speed of 16 m/s (approximately 31 knots), while the Inspire has a maximum speed of 22 m/s (approxim ately 43 knots). Moreover, the UA will not be operated at airspeeds greater than the maximum o perating airspeed recommended by the

manufacturer.

3. The UA will be operated at an altitude of no more t han 400 feet AGL.

4. The UA will be operated within the visual line of s ight of the PIC at all times, unaided by any device other than corrective lenses. The PIC will be designated before the flight and will not transfer such designation for the dura tion of the flight.

5. All operations will use a VO. In some circumstances , the VO may be used to satisfy the VLOS requirement as long as the PIC mai ntains VLOS capability. The PIC will be responsible for ensuring that the VO can perform th e duties required of the VO.

6. The PIC and VO will be able to communicate verbally at all times. Electronic or text messaging will not be permitted.

7. All operating documents needed to operate the UA an d conduct specific operations in accordance with any grant of exemptio n will be accessible during UA operations.

8. All UAs that undergo maintenance or any alteration affecting the UA’s operation or flight characteristics will undergo a functional test flight prior to conducting any operations. Functional test flights will be conducted by a PIC with a VO and will be done at least 500 feet from other people. Special care will be taken by th e PIC to survey the surrounding area of the functional test flight to ensure that no undue haza rd is posed to persons or property.

9. Petitioner will maintain and inspect the UA to ensu re safe operating condition.

10. The PIC will conduct a pre-flight inspection to det ermine that the UA is inPage 13

condition for safe flight. During the pre-flight in spection the PIC will take into account any inoperable components, items, or equipment. If the PIC discovers a condition affecting the safe operation of the UA, the aircraft will not be opera ted until the necessary maintenance is performed and the UA is in safe flying condition. T he PIC will also take any pre-flight steps recommended in the User Manuals and/or Safety Guide lines.

11. Petitioner will follow the UA’s manufacturer’s main tenance, overhaul, replacement, inspection, and life limit requirement s for the UA and its components. The UA will also comply with any and all manufacturer safety bu lletins.

12. The UA will be operated by a PIC with an airline tr ansport, commercial, private, recreational or sport pilot certificate. The PIC wi ll also hold a current FAA airmen medical

certificate or valid U.S. driver’s license issued b y a state, the District of Columbia, Puerto Rico, a territory, a possession of the Federal government.

13. Petitioner will require any PIC to demonstrate the ability to safely operate the UA in a manner consistent with the proposed operations under this Petition and any grant of exemption by the FAA, including evasive and emergen cy maneuvers, and maintaining appropriate distances from persons, vessels, vehicl es and structures.

14. No operations of the UA will occur during night and will only be conducted under

VMC.

15. No operation will take place within 5 nautical mile s of an airport reference point (“ ARP ”) or for airports not denoted with an ARP, the cen ter of the airport symbol, unless a letter of agreement with that airport’s management is obta ined or otherwise permitted by a COA issued

to Petitioner.

16. The UA will not be operated less than 500 feet belo w or less than 2,000 feet horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

17. In the event the UA loses communications or GPS sig nal, the UA will return to a pre-determined location within the private or contr olled-access property.

18. The PIC will abort the flight in the event of any u npredicted obstacles or emergencies.

19. The PIC will not begin any operation unless (consid ering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after for at least five mi nutes or with the reserve power recommended by the manufacturer if greater.

20. All UAs will be identified by serial number, regist ered, and have N-Number markings in letters as large as practicable.

21. All operating documents ensuring the safe operation and flight of the UA will be