I

January 14, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Landmark Safety, LLC for Exemption Pursuant to

Section 333 of the FAA Modernization and Reform Act of 2012

Applicant I nforma t ion:

The na m e of the applicant: Landmark Safety, LLC

The pri m ary contact for this a pplication:

Ryan Privat

Landmark Safety, LLC

4400 Ambassador Caffery

A

- 310

Lafayette, LA 70508

D ear Gentlemen:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”)

and 14 C.F.R. Part 11, Landmark Safety, LLC (“ Landmark Safety ”) hereby applies for an

exemption from Federal Aviation Regulations identified below, to allow commercial

operations of small, unmanned aerial vehicles by and through small, unmanned aerial systems

(“sUAS”) for the purposes of aerial inspections, loss control and prevention audits, data

collection

, aerial photography & videography , commercial videos and other work related to

aerial photography for commerce and training purposes in the NAS. Landmark Safety, LLC

does not intend to use for closed set filming. Flight operations will utilize the off t he shelf DJI

family of unmanned aircraft (Inspire 1 and Inspire 1 Pro) . Conduct of UA operations will be

with respect to FMRA Section 333(c) and the UAS “Blanket COA”.

This exemption is requested in subject to and in conformance with those operations and

protocols outlined in this Petition, the sUAS Operator’s Handbook, which includes component parts

manufacturers’ operations and/or instructions manuals (“Operator’s Handbook”) and any other

requirements established by the FAA pursuant to the FMRA.I. Description of Landmark Safety

Landmark Safety, LLC is a health safety and environmental consulting and training

firm incorporated in the state of Louisiana on or about March 1

, 2008 that specializes in

health safety and environmental consulting

, inspection of facilities, equipment and work

sites and training in the oil & gas, construction, and insurance industry.

II. Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain

unmanned aircraft systems may operate safely in the National Airspace ("NAS") before

completion of the formal UAS rulemaking, based on the following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

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".

T he FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards when the Administrator decides a requested exemption

is in the public interest. See 49 U.S.C. § 44701(f) (permitting exemptions from §§

44701(a), (b) and §§ 44702

– 44716, et seq .). A party requesting an exemption must explain

the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not

adve rs el y affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

III. Qualifications for Approval Under Section 333 of the

FM RA

The proposed operations in this petition for exemption qualify for expedited approval

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant

factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled

as to access; and that (4) provides an increased level of safety beyond that existing when

fixed or rotor wing aircraft are used to accomplish the same purpose.

Landmark Safety’s sUAS are rotorcraft, weighing 55 or fewer pounds

. They operate,

under normal conditions, at low speed and have the capability to hover, and move in the

vertical and horizontal plane. Landmark Safety’s sUASs will operate in line of sight and will

only operate within daylight hours

.Given the small size of the sUASs involved and the restricted environment within which

they will operate, this petition exemption falls within an equivalent level of safety, in which

Congress desired the FAA to permit commercial UAS operations by exemption pending

completion of formal rulemaking. Also, due to the size of the sUASs a nd the restricted area in

which the sUASs will operate, approval of the application presents no national security issue.

Considering the clear direction in Section 333 of the Reform Act, the authority

contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding

the propos e d operations, and the significant public and Landmark Safety benefit, the grant of

the requested exemptions is also in the public interest.

IV. Proposed Operations

To assist the FAA in its safety assessment of Landmark Safety’s proposed sUAS

operations, below is a summary of operational limitations and conditions, which will ensure an equivalent or higher level of safety to operations conducted under current regulatory

guidelines:

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the Operator.

3. Maximum total flight time for each operational flight will be limited to the

amount of time the sUAS can be flown and still maintain a reserve battery

power of no less than 20 %.

4. Flights will be operated at an altitude of no more than 500 feet above ground

level ("AGL").

5. Flights will be operated at a safe lateral distance from, and not directly above,

any inhabited structures, buildings, vehicles, vessels, or people not associated

with the operation or who have not signed a waiver in advance of the

operation.

6. The sUAS Pilot will be an FAA licensed airman with at least a sport or

recreational pilot's certificate and have an additional VLOS operator during

operations.

7. The sUAS Pilot with Pilot in Command responsibilities for the flight will be

the designated Operator ("Operator").

8. The sUAS will operate only within confined areas

9. A briefing will be conducted in regard to the planned sUAS operations pri or

t o each day's missions. It will be mandatory that all personnel who will be

performing duties within the boundaries of the safety perimeter be present for

this briefing.

10. The Operator will have been trained in operations of sUAS generally and

received up

- to

- date information on the particular sUAS to be operated

.11. Written and/or oral permission from the relevant property holders will be

obtained.

12. All required permissions and permits will be obtained from territorial, state,

county or city jurisdictions, including local law enforcement, fire or other

appropriate governmental agencies.

13. If the sUAS loses transmission signal, the sUAS will have the capability

to return to a pre

- determined location and land.

14. Contingency plans will be in place to safely terminate flight if there is a

loss of transmitter communications or a loss of GPS signal.

15. The sUAS will have the capability to abort a flight in case of

unpredicted obstacles or emergencies.

V. Regulations From Which Exemption is Requested

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, including sUASs, from its safety regulations and minimum

standards when the Administrator decides a requested exemption is in the public interest.

Landmark Safety seeks an exemption from several interrelated provisions of 14 C.F.R.

Parts 21, 45 and 91 for purposes of conducting Aerial inspections, data collection,

photography and videography using sUASs . Listed below are (1) the specific sections of

14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards

that Landmark Safety has established which will ensure a level of safety better than or

equal to the rules from which exemption is sought.

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R.

§ 91.203(a)(1)

Landmark Safety seeks an exemption from 14 C.F.R. Part 21, Subpart H, which

establishes the procedural requirements for the issuance of airworthiness certificates as

required by 14 C.F.R.

§ 91.203(a)(1). Given the size and limited operating area associated with the

sUAS to be utilized by Landmark Safety

, 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 and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to

airports and populated areas of the particular UAS.

In all 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 as, or safer than, a conventionalrotorcraft operating with an airworthiness certificate without restrictions and

conditions of the proposed sUAS operations.

Equivalent Level of Safety

The sUAS to be operated hereunder, DJI Innovations family of unmanned

aircrafts (Inspire 1 and Inspire 1 Pro) , weighs less than 55 pounds with payload, carries

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels,

and operates exclusively within a secured and sterile area. Unlike other civil aircraft, the

proposed operations will be controlled and monitored by the Operator pursuant to the

Flight Operations Manual’s requirements.

These safety enhancements, which already apply to civil aircraft operated in

connection with existing inspection operations, provide a greater degree of safety to the

Landmark Safety’s employees, members of the public, and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R.

Part 21, Subpart H. Lastly, application 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,

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial

external load.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness

certification of normal category rotorcraft. To the extent Landmark Safety’s sUAS

would otherwise require certification under Part 27, Landmark Safety seeks an exemption from Part 27's airworthiness standards for the same reasons identified in

the exemption request from 14 C.F.R. Part 21, Subpart H.

B 14 CFR § 61.113: Private Pilot Privileges And Limitations

Landmark Safety seeks an additional exemption from 14 CFR § 61.113, which

restricts private pilot certificate holders from flying aircraft for compensation or hire,

and which would also have the effect of requiring a second

- class medical certificate.

Equivalent Level of Safety

In Grant of Exemption No. 11062), the FAA determined that an Operator with a private pilot certificate operating the UAS would not adversely affect operations in the

NAS or present a hazard to persons or property on the ground. Additionally, as previously determined by the Secretary of Transportation, the requirement to have an

airman certificate ameliorates security concerns over civil UAS operations conducted in

accordance with Section 333. The Aerial inspections conducted by Landmark Safety

occur in areas where access to the public is strictly limited and controlled. Under

virtually all circum s tance s, all of the property or structures are owned and operated by

the same entity. As a result, the operation has no substantial impact on any third persons

not involved in the inspection.

Because Landmark Safety will operate in a sterile area, the sUAS will be flown

based on visual line

- of

- sight at altitudes below 500' AGL. Accordingly, Landmark

Safety request that this exemption be granted.C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

Landmark Safety seeks an exemption from the aircraft marking and

identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and

45.27(a).

14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard

requirements, provides that: No person may operate a U.S.

- registered civil

aircraft unless that aircraft is identified in accordance with Part 45 of this

chapter.

Equivalent Level of Safety

Landmark Safety, LLC w ill e ns ure co m pliance with § 45.29( f ) to m eet t he i ntent

of the regulation by displaying the r egistration number in the largest practicable lettering.

The FAA has previously issued the following exemptions to the aircraft marking

requirements of § 45.23(b): Exemption Nos. 10700, 10167 and 10167A.

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

Landmark Safety seeks an exemption from the flight manual requirements of 14

C.F.R. § 91.9(b)(2), which states:

(b) 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.

Given its physical dimensions, configuration and load capacity, the sUAS has no ability to carry such a flight manual on the aircraft, not only because there is no pilot on

board, but because there is simply no room or capacity to carry such an item on the

aircraft.

Equivalent Level of Safety

The safety related purpose of this flight manual requirement can be equally

satisfied by maintaining the sUAS flight manual at the ground control point where the

Operator will have immediate access to it. Accordingly, Landmark Safety requests an exemption from 91.9(b)(2)'s flight manual requirements, on the condition that the sUAS

flight manual be available at the control point during each operation.

The FAA has issued the following exemptions to this regulation: Exemption Nos.

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and

10700.E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Landmark Safety seeks an exemption from 14 C.F.R. § 91.7(a), which requires that

a civil aircraft be in airworthy condition to be operated. Inasmuch there will be no

airworthiness certificate issued for the sUAS, should this exemption be granted, no FAA

regulatory standard will exist for determining airworthiness.

Equivalent Level of Safety

The DJI Innovations family of unmanned aircrafts (Inspire 1 and Inspire 1 Pro)

has a stellar safety record, demonstrating that the sUAS is airworthy. Further, given the

size of the sUAS and the requirements contained in the Flight Operation Manual for

maintenance and pre

- flight safety check lists, an equivalent level of safety will be

provided.

The FAA has issued the following exemptions to this regulation: Exemption Nos.

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and

10700.

F. 14 C.F.R. § 91.103: Preflight Action

Landmark Safety seeks an exemption from 14 C.F.R. § 91.103, which requires a

PIC to become familiar with specific information before each flight, including

information contained in the FAA

- approved flight manual on board the aircraft. While

the Operator will be familiar with all information necessary to safely conduct the flight,

an exemption is requested to the extent that an FAA

- approved flight manual is required

on board the aircraft.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Operator’s

Handbook. The Operator will take all required preflight actions

- including reviewing

weather, flight battery requirements, landing and takeoff distance, and aircraft

performance data

- before initiation of flight. The Operator’s Handbook will be kept

at the ground station with the operator at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction

Landmark Safety seeks an exemption from 14 C.F.R. § 91.109(a), which

provides that n o 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." sUASs and remotely piloted aircraft, by their design, do not have functional

dual controls. Instead, flight control is accomplished through the use of a box that

communicates with the aircraft via radio communications.Equivalent Level of Safety

Given the size and speed of the sUAS, an equivalent level of safe training can

still be performed without dual controls because no pilot or passengers are aboard the

sUAS, and all persons will be a safe distance away in the event that the sUAS

experiences any difficulties during flight instruction.

The FAA has approved exemptions for flight training without fully functional

dual controls for a number of aircraft and for flight instruction in experimental aircraft.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Landmark Safety requests an exemption from the minimum safe altitude

requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe

altitudes under which aircraft may not operate, including 500 feet above the surface

and away from any person, vessel, vehicle, or structure in non

- congested areas. See

14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less

than those minimum altitudes when it can be operated "without hazard to persons or

property on the surface," provided that "each person operating the helicopter complies

with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended inspections, the sUAS is normally operated below 500

feet AGL. Additionally, due the nature of the proposed operations, the sUAS will

maintain a safe lateral distance from inhabited structures, buildings, vehicles, and

vessels, and from people not associated with the operation.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more and given the

lack of flammable fuel, any risk associated with these operations is far less than those

that presently exist with conventional aircraft. An equivalent level of safety will be

achieved given the size, weight, and speed of the UAS, a s well as the location where

it is operated. T he sUAS will be operated in a restricted and sterile area, where

buildings and people will not be exposed to operations without their pre

- obtained

consent. Because of the advance notice to the property owners and participants, all

affected individuals will be well aware of the planned flight operations as set forth in

the Flight Operation Manual.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere

with other aircraft that are subject to the minimum safe altitude regulations. Finally, the

successful safety record of the DJI Innovations family of unmanned aircraft (Inspire 1

and Inspire 1 Pro) demonstrates that the sUAS can be safely us e d at these lower

altitudes and closer operating environments.

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a

person operating an aircraft to maintain cruising altitude or flight level by reference to

an altimeter that is set to the elevation of the departure airport or barometric pressure.

An exemption is required because the sUAS does not have a barometric altimeter, but

rathe r a GPS altitude read out.Equivalent Level of Safety

An equivalent level of safety will be achieved by the operator confirm ing the

altitude of the launch site shown on the GPS altitude indicator before flight. Moreover,

the Operator will use the GPS altitude indicator to constantly monitor the sUAS's height,

thus ensuring operation at safe altitudes. J. 14 C.F.R. § 91.151(a): Fuel Requirements

for Flight in VFR Conditions

Landmark Safety requests an exemption from 14 C.F.R. § 91.151(a)'s fuel

requirements for flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight 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 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the battery powering the DJI Innovations family of unmanned aircrafts

provides approximately 18 minutes of powered flight. To meet the 30 minutes

reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not be conducted.

Given the limitations on the sUAS's proposed flight area and the location of its

proposed operations within a predetermined area, a safety margin based on a reserve

amount of battery life is needed. Landmark Safety will not be conducting any sUAS

flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be

conducted on

- site without significant transit time by the sUAS. All flights will be

planned to be terminated with no less than 20 % reserve battery power still available.

This restriction would be more than adequate to return the sUAS safely to the ground

and its planned landing zone from anywhere in its limited operating area even in the

event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of

reserve fuel does not include the type of risks that Section 91.151(a) was intended to

alleviate give n the size and speed of the small UAS, and the proximity of the flight

operation to the landing zone.

This request for exemption falls within the scope of prior exemptions, including

Exemption Nos. 10673, 2689F, 5745, 10673, and 10808.

K. 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

Landmark Safety seeks an exemption from civil aircraft certification and

registration requirements of 14 C.F.R. § 91.203(a) and (b). The regulation states in

pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless

it has within it the following:(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under

§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

Landmark Safety is seeking an exemption from the ai rw orthine ss certificate

requirements, an exemption to this regulation is necessary because: (1) the sUAS's

configuration, load capacity and size does not allow it to carry certification and

registration documents; (2) the sUAS does not have a cabin or cockpit entrance at which

documents could be displayed; and (3) there are no passengers or crew for whom the

certificates need to be displayed.

Equivalent Level of Safety

To the extent these regulations are applicable to the proposed sUAS operations,

an equivalent level of safety will be achieved by keeping these documents at the ground

control point where the Operator will have immediate access to them.

The FAA has issued numerous exemptions to this regulation, including: Exemption

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

L. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2); 91.417(a) and

(b): Maintenance Inspections

Landmark Safety seeks an exemption from the maintenance inspection

requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1),

91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection

standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating

that each owner or operator of an aircraft "[s]hall have the aircraft inspected as

prescribed in subpart E of this part and shall between required inspections ...have

discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these

regulations is needed because Part 43 and these sections only apply to aircraft with an

airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and

inspections will be performed in accordance with the Operator’s Handbook

. As provided

in the Operation Manual, the operator will ensure that the sUAS is in working order prior

to initiating flight, perform required maintenance, and keep a log of any maintenance

performed. The operator is the person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that

flight operations will only take place in restricted areas for limited periods of time

during daylight hours, creates less risk than that associated with conventional rotorcraft

performing the same operation.VI. Public Interest

Granting Landmark Safety 's exemption request furthers the public interest. National

policy set by Congress favors early integration of UAS into the national airspace in

controlled, safe working environments such as those propose in this petition. In addition,

maintaining industrial safety has been a priority of state and local governments for decades.

By their nature, structural inspection sites present unique difficulties for persons

attempting to inspect and maintain the structure. The components can be tall and have limited

access. Sending a human observer or using helicopters to inspect such elevated structures

carry certain risks. These risks can be avoided by using a small UAS under controlled

conditions to photograph and document the state of the equipment. This helps to facilitate

repairs and

identify issues before they become problems. Current options for inspecting structures and

conducting aerial site surveys and data collecting is limited to using human personnel.

Inspectors will either use a normal rotor wing manned

- aircraft or crane baskets to raise human

observers to an elevated position. The use of an sUAS reduces the risk to human life by

removing them from dangerous aspects of the inspection process.

In addition, granting the exception will help advance the knowledge base for

conducting commercial UAS operations. This additional data will help the FAA set future

rules regarding UAS flight operations, maintenance, and crew qualifications. The public also

has an interest in reducing the hazards and emissions associated with alternate use of

helicopters to conduct similar inspection operations. The UAS in question is very light weight

and does not carry any flammable fuel, further reducing the risk from any potential accident.

VII. Privacy

All flights will occur over property with the property owner's prior consent

and knowledge.

VIII. Federal Registry Summary

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:

Landmark Safety, LLC seeks an exemption from the following rules:

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. 61.113; 14 CFR

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR

91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1);

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b).

Approval of these exemptions allowing commercial operations of small and

lightweight unmanned aircraft ("sUAS") to conduct facility and site inspections will enhance

safety by reducing risk to Landmark Safety ’s employees, the general public and property

owners.

The DJI Innovations family (Inspire 1 and Inspire 1 Pro) of sUAS, weighing less than 5 5

pounds, with payload, and powered by batteries, eliminates virtually all of that risk given the

reduced mass and lack of com bus tible f uel carried on board. The sUAS is transported to the

designated area set up. It is not flown from an external location to the work

- site. The sUASwill carry no passengers or crew and, therefore, will not expose them to the risks associated

with manned aircraft flights.

The operation of this small s UAS will provide an equivalent level of safety, supporting

the grant of the exemptions requested herein, including exempting the applicant from the

requirements of Part 21 and allowing commercial operations. These lightweight sUASs operate

at slow speeds, close to the ground, and in a controlled environment. As a result, they are far

safer than conventional aerial survey and inspection operations conducted with fixed wing

aircraft or helicopters.

IX. Conclusion

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

— size,

weight, speed, operating capabilities, proximity to airports and populated areas and operation

within visual line of sight and national security

— provides more than adequate justification for

the grant of the requested exemptions to permit Landmark Safety, LLC t o operate sUASs in

support of its facility and site inspections , photography and videography in accordance with

the Operator’s Handbook

.

Granting the requested exemption will benefit the public interest as a whole in many

ways, including (1) significantly improving safety and reducing risk by alleviating human

exposure to danger, (2) improving the inspection process and decreasing operating costs, and

(3) providing an environmentally conscientious way of conducting site surveys and structural

inspections.