February 26, 2015

UnitedStates DepartmentofTransportation DocketManagementSystem 1200 NewJersey Avenue., SE WestBuildingGroundFloor RoomW12-140 Washington, DC 20590 Re: ExemptionRequest ofGridHawkAviation, LLC, Pursuantto Section 333 ofthe Federal Aviation Reform Act of2012, et. al. DearSir orMadam: Pursuantto the FAA Modernization and Reform Act of2012 ("Reform Act") and the procedures outlined in 14 CFR 11, we are requesting that GridHawk Aviation,LLC as the owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so that GridHawk Aviation, LLC, may operate its small unmanned aircraft/lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration, so long as such operations are conducted within and under the conditions outlined herein or as maybe establishedbytheFAA as requiredby §333. As described herein, Justin Schwigenis an experiencedjourneymanlineman and has held such a position for the past 16 years. He holds a Journeyman Lineman's credentials. Additionally, Justin Schwigen is a FAA licensed private pilot and actively flies andmaintains his currencypursuantto the FARs. Justin Schwigen has been actively involved in the process of inspection of hightension power distribution lines, systems, and structures both as a lineman, but also as an airborne inspector and repairman. More specifically, JustinSchwigenhasfor several years engaged in the process of accessing, inspecting, and repairing structures and high-tension power distribution lines from an airborne platform, typically a helicopter. During those years ofwork inthatcapacity, and havingbeen exposed to the associated dangers, Justin Schwigen and his company, GridHawk Aviation, LLC are pioneering inspection and documentation of condition of various electrical distribution systems and structures in both highly populated areas as well as remote areas throughout the United States. GridHawk Aviation, LLC envisions the use of a "SkyRanger", a UAS with a Ground Control System (GCS) to monitor (but not operate or control) the UAS unit's downlink of data and/or video. The Aeryon SkyRanger has weighs with imaging Section333 ExemptionRequestofGridHawkAviation,LLC Page 1 of8

### payload less than 7 pounds. It

### can operate in line of sight (LOS) from the surface to 500 feet AGL for a period of between 35 and 40 minutes with on-board battery packs. (See attached documentations) To date, Justin Schwigen and his company, GridHawk 'Aviation, LLC, have rejected all offers to conduct inspections of power distribution systems and structures through the use of UAS's for the purpose of first ensuringcompliance with the Federal Aviation Regulations. Notwithstanding the decision of Judge Patrick G. Geraghty in the matter ofMichael P. Huerta vs. Raphaelle Pirker, Docket Number CP-217, in which he reasoned that no FAR prohibited the use of small unmanned aircraft or lightweight UAS Grid Hawk Aviation, LLC, submits its Petitionfor Exemptionunder §333. GridHawk Aviation, LLC's exemption request would permit its operation of lightweightunmanned UAS'sremotely controlled in the line ofsite ofthe operator. The operation would take place in those areas surrounding power distribution systems.and , structures which may be near both populated or congested areas as well as extremely · remote areas. Itis contemplated thatGridHawk Aviation will establishmarked areas of operation, cordoned-off locations and corresponding predetermined enhancements in those areas ofoperations. Generally, as we have detailed below, the operations contemplated by GridHawk Aviation, LLC, and Justin Schwigen serve the public interest in many ways. Inspections of power distribution systems and related structures are necessitated by both engineering limitations and regulations. The cost of these inspections are extensive and often involve the use of an individual perched on a platform associated with an airborne helicopter to perform inspections and repairs. There is a corresponding danger to the lineman, the pilot, the aircraft, and those on the ground. While the technology associated with UASs has not yet reached the level where repairs can be conducted to power distribution systems and related .structures, location .and identification ofthe nature and extent of needed repairs can be quickly, safely, and_cost affectively identified by the use of UASs as contemplated by GridHawk Aviation,_LLC, andJustin Schwigen. Granting the Request for Exemption is consistent with the Secretary of Transportation's responsibilities to not only integrate UAS's into the NationalAirspace System, but to "establishrequirements for the safe operation of suchaircraft systems.in the National Airspace System" under §333(c) of the Reform Act. GridHawk Aviation, LLC, and Justin Schwigen will conduct operations in compliance with protocols described herein oras otherwiseestablishedby theFAA. Accordingly, GridHawk Aviation, LLC, respectfully requests the grant of .an exemption allowing it to operate lightweight, remotecontrolled UASs to conductUtility Company electrified powerlines and associated structureinspections.
Section333 ExemptionRequestofGridHawk Aviation, LLC Page 2of8Name and MailingAddress: , GridHawk Aviation, LLC cf o JustinSchwigen 3426 Elik Lane Alton, IL 62002 (618) 372-3579 Email: 

### Iustin@gridhawkaviation.com I. Federal Regulations fromWhich Exemption is Sought: The Petition, pursuant to Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations, seeks exemptionfrom: 14 CFR 21; 14 CFR 45.23(b);14 CFR45.27 (a); 14 CFR 61.113 (a) and (b); 14 CFR 91, et. seq. including: 91.407(a)(1), 91.409(a)(1), 91.417(a)&(b), 91.7(a), 91.9(b)&(c), 91,103(b), 91.109(a), 91.119, 91.121, 91.151, 91.203(a), 91.405(a)(a). Exemptions from the foregoing would allow the operation and use of a UASfor the purpose of inspections of electrical distribution and transmission lines .and associated structures. Without such exemptions the benefits to safety and efficiency byreason oftheuse ofUAS technology will be lost.

II. Nature andExtent ofRelief Sought and ReasonsTherefore: The United States electric grid consists of thousands of miles of distribution.and transmission power lines and related structures, all of which are inextricably interconnected. These thousands of miles of electrified lines and structures require an ongoing inspection and maintenance process and program to ensure uninterrupted service and minimized delays in delivery of the product, electricity. America's dependency on electricityjustifies all efforts necessary to ensure.minimal interruptions or delays in delivery of electricity. But, to date, inspection necessarily involves direct human interface almost always involving either ascending a tall structure orhoveringabove a structure ina helicopter. And, since most transmission lines and associated structures arelocated in remote areas withvery difficult.terrain, relocating teams of workers and all of their necessary gear to the site is often necessary simply to conduct an inspection or find a problem. The cost to Electricity vendors, the risk of interruptions in delivery of electricity, and the danger to workers who must scale structures or be lifted by helicopters, demands a more cost effective, reliable and safe approach to inspections and maintenance of transmission lines andassociated structures.

Section333 Exemption RequestofGridHawk Aviation,.LLC Page 3of8With the advent of UAS technology, inspections and tasks leading up to necessary maintenance have become potentially much more inexpensive, effective and safe. It is important to note that these inspections may serve either the purpose of prevention or the locating and addressing an existing problem that threatens delivery. Routine inspections are often conducted at great expense and risk. UASs will not only conduct these on-site inspections and relay real-time video to the inspector, but the video can be stored for training and verification purposes. The operator and inspector remain safely on the ground, in sight of the UAS. Instead of teams of linemen and loads of equipment or the involvement of a helicopter, two I} individuals, a pilot/operator of the UAS and an inspector/observer is all that is needed toconductthe sameinspection. In terms of cost, the expense of the UAS-based inspections will prove to be a fraction of thecost ofinterfaced-human inspections. Currently, itis estimated_that a helicopter costs the electricity vendor between $1,500.00 and $2,000.00 per hour of operation. In addition, the cost of locating teams and equipment can vary widely, depending on the access that the terrain allows, the distance, etc, but adds significantly to the expense ofthe inspection. It is difficult to estimate with certainty the per-hour cost with interfaced-human illspections, but it is clear that the use of UASs as a substitutewill muchmorecosteffective. Accordingly, thepetitioner seeks exemptionfrom theRegulations noted above so that examination and inspection can be made to various electrified distribution_and transmission lines, structures, and components throughout the continental United States while complyingwithotherFederal Aviation Regulations_ III.The Benefittothe Public Interest as aWhole ifPetition is Granted: As mentioned above, the cost of using UAS technology is only a fraction of_the cost of the current methods of inspections. This reduction in costs would presumably be passed along to the consumer. Since the distribution of electricity is heavily governed throughout the United States, these cost savings would become readily apparentto theregulating authority andpresumably addressed accordingly. The use of UAS technology for the purpose of conducting inspections will produce a higher degree ofreliability in the delivery ofelectricity. This is so largely because inspections, as they would be more cost effective, will be conducted_more regularly. Additionally, eachinspectionwith UAS technology will have thecapacity to download imagery and save the entirety of the inspection in a video format. These can be used for inspection on site or later by personnel in office. There is the added benefit that the efficacy of these inspections in the future will evolve due to thetrainingcapacity that storedvideotaped inspections have.

Section 333 Exemption Request ofGridHawkAviation, LLC Page4 of8

### As well, safety will be enhanced and the costs associated with safety will be reduced. With the introduction of human factor into a dangerous environment, such as when human inspections take place with transmission lines and associated structures, the cost of maintaining a level of safety naturally increases. Remove the human interaction with the structure itself, and the risk of harm naturally reduces. With use of UAS technology, and the lack of need for interfaced-human inspection, the dangers to those involved will be reduced and, accordingly, there will be a correspondingreductionincost ofdelivery oftheproduct. Americans are highly dependent on the uninterrupted supply of electricity. Today, electrical distribution systems constitute targets-for terrorists and with that threat comes the threat to lives. (http://www.bloomberg.com/news/articles/2012- 11-14/thousands-seen-dying-if-terrorists-attack-vulnerable-u-s-grid). A widespread or regional interruption in the delivery of electricity, even if for a short period, will result in immeasurable monetary loss as well. It

### is anticipated that with the increase in the frequency and the thoroughness of the inspections, the efforts of terrorists to damage or destroy central distribution systems can possibly be at the very least, hindered, and very possibly completely thwarted, anddisaster averted. Reduction in costs, increase in reliability, and improvement of safety will enhance the benefit to the public and ensure the delivery of electricity to the consumer. IV.The Grant ofthe Requested ExemptionWill NotAdversely Mfect Safety: 

### As indicted, the current method of inspection necessarily involves the human interfacing with the electrical transmission lines and associated structures. These inspections involve a high risk of injury or even death to those working around_the site of the inspection. Those who are in danger include those on board the helicopter, if that method is used, as well as the linemen who climb the structures and the supporting crew below. Difficult and hazardous terrain often increases the risk ofinjury and death. From these concerns alone, there is an obvious increase in the safety to those involved inthe inspection. At the same time, there is a potential increase in safety to the members of the general public in that more frequent and thorough inspections can be conducted. With more frequent and thorough inspections, there comes a reduction in theprobability ofdangerouscircumstances to presentthemselves. A. UAS PlatformandSafety Features Gridhawk envisions the use of a UAS, the Aeryon SkyRanger platform ("SkyRanger").
Section333 Exemption Request ofGridHawkAviation,.LLC Page 5of8

### The SkyRanger provides two semi-autonomous flight modes using a**point~and** 

### click map and videointerface. The user clicks ona map to directtheSkyRanger to fly to pointofthe mapwhere the operatoris pointing, orprogramflight plans maybe entered for a series of way points or grid based area. Additional navigation age including landing zones and flight areas may be designated to ensure the SkyRanger operates only within user specified flight parameters. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a variety of sensors including sonar, barometric pressure, temperature, wind speed, and others to ensure high stability and reliability even in challenging weather conditions. At all times during flight operations, the operator has the command authority to intervene a programflight and take immediate control. Attached hereto as Exhibit A is brochure materialregarding anticipated UAS technologytobe utilized. TheSkyRangerfeatures thefollowing additional automated safety functions:

• Automated pre-flight systemperformancechecks. • User pre-flightchecklist. • Automated condition or fault detection, warnings, and predefined responses to a number of flight and system conditions including winds, power status, temperature, andlost-link communications. • Predefined responses include behavior such as attempting to reestablish radio communication, return to home position and hover, return to home positionand land, orlandincurrentposition. • In the case oflostGPS, a manual userflight mode is enabled which.allows the operator to provide manual navigation inputs to assist in the landing ofthe vehicle. The SkyRanger specifications are asfollows: Payload

. Empty weight Maximumwind Operationalradiusrange Dimensions Fuel Maximumaltitude Maximumendurance up to 1.3 pounds 5.3 pounds 40MPH up to 1.6nautical miles 40 inches diameter deployed lithiumpolymerbatteries 1,500feet 50 minutes

B. Operator-PilotQualifications, Experience, Currency andSafety

Section 333 Exemption RequestofGrid.HawkAviation. LLC Page 6of8•' 

### .

GridHawk will utilize only Private or Commercial Rated pilots who are current and hold at least a Class III FAA Medical Certificate. Furthermore, GridHawk will require at least 20 hours offlight time and 200 cycles prior to conducting operations pursuant to the grant of an exemption. Pilot currency demands consistent with existingFARrequirements will also be employed toensure thatpilots maintain_their effectiveness. For all exempted flight operations, one qualified individual will be designated_as Pilot in Command (PIC) and second individual will be designated visual observer (VO). The PIC shall act as team leader and shall be responsible for safety of flight and operations. The VO shall be responsible for the Ground Control Station (GCS) assembly and will maintainvisual identification of the UAS while scanning for_and pointing out flight hazards, such as other aircraft, obstacles, boundaries of the predesignated safe operations areas and persons. 

### C. Airspace and Related Safety The UAS will only be 

### used to conduct flight operations under day & 

### VFR conditions. It is contemplated that the UAS will launched from a location within or very near and below the right of way for the transmission line and associated structures, unless more immediate hazard concerns dictate otherwise. Creation of the safe operation areas and the actual operations will take into iji.CCount the possibility of equipment failure such that it will not present an undue hazard to persons orproperty. On 

### rare occasion, current inspections may be conducted in densely populated areas or areas extending over heavily traveled thoroughfares. It is contemplated thatno UAS-based inspection will take place inareas where an unexpected accident would endanger members of the public. Alternative methods of inspection as well as density of the population or volume of traffic will be considered and any doubt for safety be resolved against UAS operations. It 

### is anticipated that, in such_areas, UAS-based inspections will be minimal and only be conducted in accordance with existingFederalAviation regulations. With regard to airspace concerns, it is not anticipated that there will be frequent entry into the existing airspace system as most operations will be in remote_areas and within 400 feet of the surface. In those cases where an airspace is from

__the surface to a given altitude AGL, consultation with and notification of the local.air traffic control system will be undertaken, and the publication, if 

### appropriate, of notice to airmen through the normal channels will be posted. Operations shallbe conducted in that airspace only after permission is obtained and only during.the effective time of the NOTAMs. Again, given the remoteness of most flight operations, the frequency of operations involving anything other than Class G Section 333 Exemption Request ofGridHawkAvialion, LLC Page 7of8

### airspace will be very low. And, it should be emphasized here that, since the exemption sought is to operate very near and at the same elevation as existing transmission lines and associated structures, the operation ofGridHawk's UAS will not significantly expand or enlarge risks to other airborne aircraft beyond the_risks already presentedbythe transmission lines and structures themselves. All operators being FAA licensed pilots will be aware of and knowledgeable aboutany overlyingorinvolved airspace as well as right ofway rules. V. Summaryfor Publicationinthe Federal Register: 

### GridHawk Aviation, LLC, seeks an exemption pursuant to Section 333 to conduct UAS-based inspections of power distribution and transmission lines,_and associated structures, within the continental United States. The Petition seeks exemptionfrom: 14 CFR 21; 14 CFR 45.23(b);14 CFR 45.27 (a); 14 CFR 61.113 (a) and (b); 14 CFR 91, et. seq. including: 91.407(a)(1), 91.409(a)(1), 91.417(a)&(b), 91.7(a), 91.9(b)&(c), 91,103(b), 91.109(a), 91.119, 91.121, 91.151, 91.203(a), 91.405(a)(a).

VI.List ofSupportingExhibits: 

### A. Brochure regarding anticipated UAS technology to be utilized consisting of theSkyRanger Aeyron UAS and supportingequipment. B. Graphic-UnitedStatesElectric Grid (2009) C. 

### GridHawkOperationlimitations Respectfully submitted, GridHa Aviation, L C

By:

# ---R-------"---¥--~])~ Justin Schwigen, Owne 3426 Elik Lane Alton, IL 62002 (618) 372-3579 Email: Iustin@gridhawkaviation.com

Section 333 Exemption RequestofGridHawk Aviation, LLC Page8of8Field-tested and battle-proven. Aeryon small UAS set the standard for immediate aerial intelligence gathtring by ANYONE, ANYWHERE, at ANYTIME:

+ Intuitive wuchscreen interrace and advanced ieatures.

minimal usertrainirog +Single operator transport and deployment. no launch

or recovery equipment +Reliable flight periormance even in the most demanding weather conditions, 1Nhen other systems cannot fly The Aeryon SkyRangerrM introduces a new airframe and integrated system design to the Aeryon sUAS platform. based on thousands of hours of flight time and successful customer exercises and missions around the world. Designed to military and government specifications. SkyRangerTM extends industry-leading performance and system capabilities.

Intuitive interface and autonomous capabilities - no joysticks required

+ Point-and-dick touchscreen

navigation and camera control + Dynamic flight plans including

Follow-Merx protection and AUloGrid'" mapping modes

Advanced optics and networking -smart imagery and seamless integration

+ Stabilized. simultaneously-streaming

dual EO/IR high resolution cameras

EO: 1 080p2k HD H.26f video. 15MP still images

- IR: 66-0xl!SO H.264 video and s;iU images.

white-hot and black-hot modes + Low-latency all-digital network256bii AES encrypted streaming video to muliiple devices. embedded geotags and metadata + Beyond line-of-sight range

1.9 mi 13 km) integrated capability. extensible beyond 3. i mi 15 km) 

### EXHIBIT

A Rugged, reliable and capable -dependable in extreme environments

+ Up to 50-minute endurance with payload.

continuous operation model + High wind tolerance

-

1.0 mph {65 kph] susiained. 55 mph (90 kphl gusts + Ruggedized and weather-sealed + Environmental temperature range

-22'F to 122'F 1-Jo•c to 50'Cl Pre-assembled backpack deployment- airborne in seconds

+Folding design protects payload

& includes battery for powered standby +Payload. battery, arms. and legs are

easily replaced in the field without toolsThe Aeryon sUAS platform brings secure. real-time and simultaneous tactical situational awareness to ground forces and remote command

.Advc:nced autonomous capabilities and simple touchscreen controls require minimal training for soldier. squad, or platoon-level deployment.
Unlike fixed-wing systems

. the Aeryon SkyRangerrM is a Vertical Take

-Off and Landing IVTOLI sUAS- ideal for providing continuous eyes-on-target for situational awareness. ope•ations in confined environments. and low-risk launch and retrieval without peripheral equipment. SkyRangerrM is ideally suited for both land and maritime military use including covert ISR. convoy and compound security. and ship boarding operations

. Immediate deployment. small size. quiet operation and specialized i maging payloads make SkyRanger'- the ideal platfoom for a wide range of missions in any conditions. including:

+ Tactical situational awareness & targeting + Perimeter &convoy security + Covert Intelligence. Surveillance

and Reconnaissance IISR) + Anti-pi;-acy. tactical ship boarding + De-mining + Emergency & disaster response + HAZMAT /CBRNE management

For information about Aeryon sUAS solutions, contact yourAeryon Sales Representative: Call+i -519-1:89-6726 ext: 320 or email salesfGaeryon

.com www.aeryon.com I toaeryonlabs TECHNICAL SPECIFICATIONS: ENDURANCE: • Up to 50-minute flight time !with payload) WIND TOLERANCE: • 40 moh [65 kohl sustained • 55 mph (90 kph) gusts ENVIRONMENTAL TEMPERATURE RANGE: • -22•F to- i 22?Fl-3o·c to SO'Cl BEYOND LINE-OF-SIGHT RANGE: • 1.9 mi 13 km) integrated capability • Extensible beyond 3.1 mi 15 kml ALTITUDE: • 1500 ft. 1450 ml A.GL, i 5000 it.**~50 0**  m )MSL LAUNCH & RECOVERY METHOD:

· • Verticsl Take-Oif and Landing ! VTOLl DIMENSIONS: • Deployed :£0 in.li02 em!diameter, 9.3 in. 12L em) heioht • Folded : 20 in. 1 50 em)**gth~** 10 in. 125 cml width WEIGHT [WITHOUT PAYLOAD): • 5

.3 lbs (2.L kg) ADDITIONAL PAYLOADS: • 3-axis stabi li

zed hi ah resolution E Ocamera • Custom payload development NAVIGATION LEOS: • Red/Green and Re

. j/NIR RADIO FREQUENCIES: • 900 mhz, 2.4 GHz, custom CONTROL AND DATA LINK: • Low

-latency all-digitalnetwork SECURITY: • Secure network pairing.

AES256bit encryption ·Visualizing The U.S. Electric Grid : NPR

THE GRID

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EXISnr•G Uf(ES 345-199 f:V

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PROPOSED UliES •, New 765 kV

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Source: American Electric Power, American Wind EnergyAssociation, CentertorAmerican Progress, DepartmentofEnergy, Edison Electric Institute, Energy Information Administration, Electric PowerResearch Institute, Federal Energy Regulatory Commission, National Renewable Energy Laboratory, U.S. Environmental Protection Agency, Western Resource Advocates Credit: Producer: Andrew Prince; Designer: Alyson Hurt; Editors:Avie Schneiderand Vikki Valentine; Supervising Editors: Anne Gudenkautand Quinn O'Toole; Additional Research: Jenny Gold; Database and GISAnalysis: Robert Benincasa


## NPR Series EXHIBIT Power Hungry: Reinventing The U.S. Electric Grid May 1. 2009 B

http://www.npr.orgl2009/04/24/110997398/visualizing-the-u-s-e!ectric-grid 2/6115 9:36PM

Page 2 of 3**~~··----·-·**

# ____________________..._.__

OPERATION LIMITATIONS AND RESTRICTIONS FOR GRIDHAvVKAVIATION, LLC

VER.1.00 February 2015 

### EXHIBIT


### c1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents which has four rotors and four motors in a quadcopter configuration and weighing less than 7 pounds including imaging payload: The 

### SkyRanger currently manufactured by Aeryon. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this·exemption are limited to the inspection electrical distribution and transmission lines, and associated structures. 3. The UA may notbe flown ata ground speed exceeding 25 mph. 4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL), or 50 feet above any structure being inspected, as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC mustbe in feet AGL. 5. All operations to occur in Class G airspace unless othenvise authorized by local ground control/air control, ARTCC or other authority over the involved airspace. 6. Operations to avoid congested or populated areas, which are depicted in yellow on official VFR navigational Sectional Charts, unless it is determined that operation will be pose no unreasonable risk of harm or danger to those nonparticipating individuals and/or personal orreal property. 7. All operations shall be within the right-of-way or easement if any, of the utility except as may be necessary for the purpose of transition from the base of operation to the structure to be inspected and for ingress and egress purposes only, in whichcase permission of the affected landowner shall first be obtained. 8. All operations conducted in the vicinity of an airport are toremain more than 2.5 nautical miles from the center line azimuth of the corresponding runway center line measured from the runway threshold. 9. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human obsenration unaided by any device other than corrective lenses, as specified on the PICs FAA-issued medical certificate. 10. All operations must utilize a visual observer (VO) and within VLOS ofthe VO at all times. This requires the VO to be able to use human vision unaided by any device other than corrective lenses. The VO may be used to satisfy the VLOSrequirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 11. The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is notpermitted to operate the camera or otherinstruments. 12. The operating documents and this grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exits between the conditions and limitations in this exemption and the procedures outlines in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mustfollow the procedures as outlined in its operatingdocuments. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised,documents ifit petitionsfor extension or amendmentto this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petitionfor amendment to its grantofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates orrevisions to the operating documents. 13. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in condition fore safe flight. The Ground Control**Statio~** must be included in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraftrecords. 14. Any UAS that has undergone maintenance or alteration that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight mustmake an entry ofthe flight in the UAS aircraftrecords. 15. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operatingdocuments.16. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 17. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance. with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 18. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 19. The authorized personmust make anentry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 20. The PIC must possess at least a private pilot certificate and at least a current third-class medical certificate. In accordance with 14 CFR 61.23, a pilot holding a commercial certificate mustposses atleast a second-class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated onhis orher pilotcertificate. 21. Prior to operations conducted for the purpose of inspection, the PIC must have completed the operator's training as prescribed in the operating documents. During that training, the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), the minimum hours prescribe in the operating documents as UAS pilot operating the make and model of the UAS to be utilized for operations under the exemption. Training, proficiency, and experiencebuilding flights can be conducted under this grant of exemption to qualify the operator's PIC(s), VO(s) and other essential personnel as defined in the operating documents. However, said training operations may experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR § 91.119. 22. Prior to operations conducted for the purpose of inspection, the PIC must have completed the operator's currency requirements as prescribed in the operating documents. The PIC must have completed at least three take-offs and three landings in the preceding 90 days as UAS pilot operating the make and model of the UAS to be utilized for operations under the exemption to maintain currency. Take-off and landing currency flights can be conducted under this grant of exemption. \A/hen establishing or regaining currency, said currency flights may only be conducted during dedicated training/currency sessions. Duringtraining, proficiency, experience-building flights, and dedicated currency flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR § 91.119. 23. Prior to operations conducted for the purpose of inspection, the PIC, VO, and other essential personnel as defined in the operating documents, must have met all qualification, training, and currency requirements, as outlined in the· operating documents. A record of completion of these requirements must be documents and made available to the Administratoruponrequest. 24. The operator may not permit the PIC to operate the UAS for the purpose of inspection unless the PIC has demonstrated and logged in a manner consistent with 14 CFR § 61.51(b), the ability to safely operate the UAS in a manner consistent with hoe the UAS vvill be operated under this exemption, including evasive and emergency maneuvers and maintain appropriate distances from people, vessels, vehicles, and structures. 25. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 26. The UA may not operate within 5 nautical miles of the airport reference point as denoted on a currentFAA-published aeronautical chart. 27. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC 28. Ifthe UAS loses communications or loses its GPS signat the UA mustreturn to a pre-determined location within the planned operating area and land or be recovered in accordance with the operatingdocuments. 29. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operatingdocuments. 30. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% batter power remaining. 31. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice 

# ··----to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation

.. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level andpotential transponderrequirements. 32. All aircraft operated in accordance with this 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 mustbe aslarge as practicable. 33. 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. 34. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 35. The UA must remain clear and yield the right of way to all manned operations and activities at all times. 36. The UAS may notbe operatedby the PIC from any moving device or vehicle. 37. The UA may notbe operated over congested or densely populated areas. 38. Flight operations must be conducted no less than 500 feet from all nonparticipatingpersons, vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons are no longer under such protection and are within 500 feet of the UA, flight operations mustcease immediately, and/or; b. The aircraft is operated near vessels, vehicles, or structures where the owner/COI)troller of such vessels, vehicles, or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present anunduehazard, and; 

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c. Operations nearer to the PIC, VO, Sensor Operator, other essential personnel as defined in the operating documents, do notpresent anundue hazard to those persons per§ 91.119(a). · 39. All operations shall be conducted with permission from the state or local government agency, organization, or owner, with authority for operating the bridge under inspection. Permissionfrom the authority will beobtained for each flight tobeconducted. 40. 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 the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) · perinstructions contained onthe NTSB Web site: \Vvvvv.ntsb.gov.**-------------------------------------~N[)-----------------------------------------------------------**