1 Integrity	Management

, LLC

Ja m es	G. Grubbs

– Owner

9001	Faulkner	Lane Knoxville,	TN	37922

Phone :	(865) 560

- 3100

Email : jgrubbs@integritymgt.com

August	19 ,	2015

U.S.	Department	of	Transportation	(DOT) Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Exemption	Request

As	follows	please	find	the	Integrity	Management,	LLC		(“Integrity	Management”) request	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	to	allow

com mercial	operation	of the	DJI	Phantom	3 Small	Unmanned	Aircraft	Systems (“UASs” )	for	aerial surveying ,	safety	and	monitoring	of	secured	and	controlled environment	of	Telecommunication/Cell	tower	sites.	This	exemption	request	is exclusively	for	the	use	of	th e	UAS	operated	by	Integrity	Management,	LLC,	a Tennessee	based	company.

Also	attached	to	this	letter	is	the DJI	Phantom	3	UAS	User	Manual and	Safety

Guidelines	and	Disclaimer (“the	Manual” ) ,	which	outlines	the	operating requirements,	limitations,	maintena nce	and	technical	specifications	for	the DJI

Phantom	3 UAS.

Thank	you	for	your	time	and	consideration,	please	contact	me	with	any	questions.

Regards,

James	G. Grubbs Integrity	Management,	LLC2 August	19 ,	2015 U.S.	Department	of	Transportation	Docket Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the Federal	Aviation	Regulations	from	14	CFR	Part	21;	14	CFR	61.113	(a)	&	(b);	91.7	(a); 91.9	(b)	(2);	91.103	(b);	91.10 9;	91.121;	91.151	(a);	91.203	(a) &	(b);	91.405	(a); 91.407	(a)	(1);	91.409	(a)	(1)	&	(a)	(2);	91.417	(a)	&	(b).

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012 (the	Reform	Act)	and	14	C.F.R.	Part	11,	Integrity Management,	LLC	(“Inte grity Management”),	operator	of	the	DJI	Phantom	3 Small	Unmanned	Aircraft	System(s) (“UASs”),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation Regulations	(“FAR”)	to	allow	commercial	operation	of	its	UASs	for	aerial	s urveying of	structures,	equipment	condition,	safety	and	monitoring	of	Telecommunication	/ Cellular	Towers	in	a	secured	and	controlled	environment,	so	long	as	such	operations are	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be

establi shed	by	the	FAA	as	required	by	Section	333.

As	detailed	in	this	document	and	the	attached	UAS	Flight	Manual,	the requested	exemption	would	permit	the	operation	of	UAS	under	controlled conditions	in	airspace	that	is	1)	limited	2)	predetermined	3)	controll ed	as	to	access and	4)	would	provide	safety	enhancements	best	practices	safety	protocols	followed by	Integrity	Management	at	Telecommunication/Cellular	Tower	sites.	Approval	of this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transp ortation’s	(the	FAA	Administrator’s)	responsibilities	to	“...establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace system.”	Section	333(c)	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is:

Integrity	Mana gement,	LLC Ja m es	G. Grubbs

PH:	865

- 510

- 3100

Email: jgrubbs@integritymgt.com Address:	9001	Faulkner	Lane,	Knoxville,	TN	37922

Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	Part	21

14	C.F.R. 61.113	(a)	&	(b)3 14	C.F.R.	91.7	(a) 14	C.F.R.	91.9	(b)	(2) 14	C.F.R.	91.103	(b) 14	C.F.R.	91.119	(c)

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)	(1)	&	(a)	(2) 14	C.F.R.	417	( a)	&	(b)

STATUTORY	AUTHORITY	FOR	EXEMPTIONS

The	Federal	Aviation	Act	expressly	grants	the	FAA	authority	to	issue exemptions.	This	statutory	authority	includes	exempting	civil	aircraft,	as	the	term	is defined	under	40101	of	the	Act,	including	UASs,	from the	requirement	that	all	civil

aircraft	must	have	a	current	airworthiness	certificate.

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a regulation prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections

44702

- 44716	of	this title	if	the	Administrator	finds	the	exemption	in	the	public interest.	49	U.S.C.	44701(f)	See	also	49	USC	44711(a);	49	USC	44704;	14	CFR 91.203(a)(1).

Section	333(b)	of	the	Reform	Act	assists	the	Secretary	in	determining whether	UAS	may	operate	in	the	Na tion	Airspace	System	(NAS)	without	creating	a hazard	to	the	user,	the	public,	or	a	threat	to	national	security.	In	making	this determination,	the	Secretary	must	consider:

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

• Whether	the	UAS	operates	w ithin	the	visual	line	of	sight	of	the	PIC;

• Whether	the	UAS	operates	outside	of	highly	populated	areas	and	away	from close	proximity	to	airports.

Reform	Act	333(a).	If	the	Secretary	determines	that	a	UAS	“may	operate	safely	in	the national	airspace	system, the	Secretary	shall	establish	requirements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	333	(c).

Integrity	Management’ s	UASs	are	multi

- rotor	vehicles,	weighing	less	than	15

lbs. including	payload.	They	operate	under	norm al	conditions	at	a	speed	of	no	more than	50	mph	and	have	the	capability	to	hover,	and	move	in	the	vertical	and horizontal	plane	simultaneously.	The	UASs	will	operate	only	in	the	visual	line	of sight	(VLOS)	of	the	PIC	at	all	times.	Operations	will	take	plac e	only	within	the controlled	environments	around	Cellular	towers.	These	operations	will	insure	that4 the	UASs	will	“not	create	a	hazard	to	users	of	the	national	airspace	system	of	the public.”	Reform	Act	Section	333	(b).

Provided	the	small	size	of	the	UAS s	involved	and	the	controlled	environment within	which	they	will	operate,	our	application	is	equivalent	to	the	level	of	safety	in which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	commercial operations	of	UASs	to	commence	immediately.

In	a ddition,	due	to	the	small	size/weight	of	the	UASs,	the	low	altitudes	and controlled	areas	in	which	our	UASs	will	operate,	approval	of	the	application presents	no	national	security	issues.

Given	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	au thority contained	in	the	Federal	Aviation	Act,	as	amended;	the	strong	equivalent	level	of safety	surrounding	the	proposed	operations,	and	the	significant	public	benefit, including	enhanced	safety,	the	grant	of	the	requested	exemptions	is	in	the	public

inte rest.	Accordingly,	Integrity	Management	respectfully	requests	that	the	FAA grant	the	requested	exemption	without	delay.

PUBLIC	INTEREST

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in passing	Section	333(a)	through	(c)	of the	Reform	Act.	This	law	directs	the	Secretary of	Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may operate	safely	in	the	NAS	before	completion	of	the	rule	making	required	under Section	332	of	the	Reform	Act.	By	granting	an	exemption the	FAA	will	fulfill Congress’s	intent	of	allowing	UASs	to	operate	with	significant	safety	precautions	in

low	risk	environments.

The	telecommunications	industry	provides	the	gateway	for	emergency communication	and	response	capabilities.	As	well,	tower	c limbers	have	one	of	the most	dangerous	jobs	in	America	with	multiple	deaths	per	year.	A	UAS	can	gather valuable	information	to	help	increase	safety	and	productivity	while	limiting	the need	for	tower	climbers.	Falls	are	the	leading	source	of	workplace	fatal ity	and injury,	and	reducing	falls	through	UAS	use	for	site	surveying	could	save	worker’s lives	while	providing	the	necessary	information	to	make	sure	communications	are operating	properly.

EQUIVALENT	LEVEL	OF	SAFETY

Integrity	Management	proposes	that	t he	exemption	requested	herein	apply to	civil	aircraft	that	have	the	characteristics	and	that	operate	with	the	limitations listed	herein.	These	limitations	provide	for	at	least	an	equivalent	or	even	higher level	of	safety	to	operations	under	the	current	reg ulatory	structure	because	the proposed	operations	represent	a	safety	enhancement	to	the	already	safe	protocols5 followed	in	Telecommunications/Cell	tower	sites	and	imaging	and	surveying operations

.

Integrity	Management	will	be	bound	by	the	following	when	c onducting	its	UAS operations	under	an	FAA	issued	exemption:

• The	UA	will	weigh	less	than	15	pounds.

• Flights	will	not	exceed	the	indicated	air	speed	of	50	mph	(43.3	knots).

• Flights	will	be	operated	at	or	below	an	altitude never	exceeding	400	feet	AGL.

• The UA	will	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	and potential	observers	at	all	times.

• The	PIC	will	follow	the	operations	and	maintenance	procedures	outlined	in the	UAS	Flight	Manual	at	all	times.

• Prior	to	each	flight	the	PIC	will	inspect the	UAS	to	ensure	it	is	in	a	safe, operational	condition	per	the	UAS	Flight	Manual.

• Any	UA	that	has	undergone	maintenance	will	undergo	a	functional	test	flight.

• All	operators	will	be	required	to	demonstrate	the	ability	to	safely	operate	the

UAS	in	a	manner consistent	with	what	is	outlined	in	the	UAS	Flight	Manual, including	evasive	and	emergency	maneuvers	and	maintaining	appropriate distances	from	people,	vessels,	vehicles	and	structures.

• UAS	operations	will	not	be	conducted	during	the	night,	as	defined	in 14	CFR 1.1.	All	operations	will	be	conducted	under	visual	meteorological	conditions (VMC).	Flights	under	special	visual	flight	rules	(SVFR)	will	not	be	conducted.

• 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.

• If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA	will	return	to

a	pre

- determined	location	within	the	private	or	controlled

- access	property
and	land	or	be	recovered	in	acc ordance	with	the	UAS	Flight	Manual.

• The	PIC	will	abort	the	flight	in	the	event	of	unpredicted	obstacles	or emergencies	in	accordance	with	the	UAS	Flight	Manual.

• The	PIC	is	prohibited	from	beginning	a	UAS	flight	unless	(considering	wind

and	forecast	weather conditions	and	assuming	normal	cruising	speed)	there is	enough	power	to	fly	to	the	first	point	of	intended	landing	prior	to	utilizing battery	reserve	power.

• Before	conducting	operations,	the	radio	frequency	spectrum	used	for operation	and	control	of	the	U A	must	comply	with	the	Federal Communications	Commission	(FCC)	or	other	appropriate	government oversight	agency	requirements.

• The	documents	required	under	14	CFR	91.9	and	91.203	will	be	available	to the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time the	UA	is	operating. These	documents	will	be	made	available	to	the	Administrator	or	any	law enforcement	official	upon	request.

• The	UA	will	remain	clear	and	yield	the	right	of	way	to	all	other	manned aviation	operations	and	activities	at	all	times.6 • The	UA will	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.

• The	UA	will	not	be	operated	over	congested	or	densely	populated	areas. These	areas	include	but	are	not	limited	to	the	yellow	areas	depicted	on World	Aeronautical	Charts	(WAS),	Sectional	Aer onautical	Charts	(sectionals), or	Terminal	Area	Charts	(TAC).

• All	operations	shall	be	conducted	over	private	or	controlled

- access	property with	permission	from	the	land	owner/controller	or	authorized representative.

• Any	incident,	accident,	or	flight	opera tion	that	transgresses	the lateral	or vertical	boundaries	of	the	operational	area	will	be	reported	to	the	FAA’s	UAS Integration	Office	(AFS

- 80)	within	24	hours.	Accidents	will	be	reported	to	the National	Transportation	Safety	Board	(NTSB)	per	instructions contained	on

the	NTSB	website: www.ntsb.gov

.

DESCRIPTION	OF	SPECIFIC	REGULATIONS

Regarding	the	Unmanned	Aircraft	System	(UAS)

14	C

. F

. R

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

Subpart	H, entitled	Airworthiness	Certificates,	establishes	the	procedural requirements	for	the	issuance	of	airworthiness	certificates	as	required	by	FAR 91.203	(a) (1).	Given	the	size	and	limited	operating	area	associated	with	the	aircraft to	be	utilized	by	Integrit y	Management,	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	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.	Our	small	UAS	will	be	operated	at	low	speed	in	a	controlled environment,	at	least	five	miles	from	an	airport	and	more	tha n	three	miles	from	any city	or	densely	populated	area.	An	analysis	of	these	criteria	demonstrates	that	the UAS	operated	without	an	airworthiness	certificate,	in	the	restricted	environment and	under	the	conditions	proposed	will	be	at	least	as	safe,	or	safer ,	than	a conventional	aircraft	(fixed	wing	or	helicopter)	operating	with	an	airworthiness certificate	without	the	restrictions	and	conditions	proposed.

The	UAS	to	be	operated	hereunder	is	less	that	15lb.	fully	loaded,	carries	neither	a pilot	nor passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and operates	exclusively	within	a	secured	area	as	set	out	in	the	Manual.	Like	other	civil aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and	monitored by	the	operato r,	pursuant	to	the	Manual’s	requirements,	and	under	the requirements	and	in	compliance	with	local	public	safety	requirements ,	to	provide security	for	the	area	of	operation	as	is	currently	done	on	active	Telecommunication/

Cell	tower	sites.7 These	safety enhancements,	which	already	apply	to	civil	aircraft	operated	in connection	with	Telecommunication/Cell	towers,	provide	a	greater	degree	of	safety to	the	public	and	property	owners	than	conventional	operations	conducted	with

airworthiness	certificates	issue d	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	UAS,	due	to	its	size,	speed	of	operation,	location	of operation,	lack	of	explosive	materials	or flammable	liquid	fuels.

14	C

. F

. R

. 91.405	(a);	407	(a)(1);	409	(a)(1)	&	(a)(2);	417	(a)	&	(b): Maintenance	Inspections

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

Give n that these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness certificate,	these	sections	will	not	apply	to	Integrity	Management.	Maintenance	will be	accomplished	by	the	operator	pursuant	to	the	UAS	Flight	Manual.	An	equivalent level	of	safety	w ill	be	achieved	because	these	small	UASs	are	very	limited	in	size	and will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	limited	periods	of time.	If	mechanical	issues	arise	the	UAS	can	land	immediately	and	will	be	operating from	no	higher than	400	feet	AGL.	As	provided	in	the	Manual,	the	operator	will ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	the manufacturer	and	operator	is	most	f amiliar	with	the	aircraft	and	best	suited	to maintain	the	aircraft	in	an	airworthy	condition	to	provide	the	equivalent	level	of safety.

Regarding	the	Pilot	In	Command	( PIC)	of	the	UAS

14	C

. F

. R

. 61.113 (a)	&	(b):	Private	pilot	privile ges	and	limitations: Pilot	in

command

Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non

- commercial	operations.	Because the	UAS	will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve the	equivalent	level	of	safety	of	current	operations	by	following	the	r equirements

listed	in	the	Manual.

Unlike	a	conventional	aircraft	that	carries	the	pilot	and	passengers,	the	UAS	is remotely	controlled	with	no	living	thing	or	cargo	on	board.	The	area	of	operation	is controlled	and	restricted,	and	all	flights	are	planned and	coordinated	in	advance. The	risks	associated	with	the	operation	of	the	UAS	are	so	diminished	from	the	level of	risk	associated	with	commercial	operations	contemplated	by	Part	61	when8 drafted,	that	allowing	operations	of	the	UA S	as	requested	above	via	a PIC	exceeds the	present	level	of	safety	achieved	by	14	C.F.R.	61.113	(a)	&	(b).

Regarding	the	Operating	parameters	of	the	UAS

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

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is in airworthy	condition.	As	there	will	be	no	airworthiness	certificate	issued	for	the aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for determining	airworthiness.	Given	the	size	of	the	aircraft	and	the	requirements

conta ined	in	the	Manual	for	maintenance	and	use	of	safety	checklists	prior	to	each flight	an	equivalent	level	of	safety	will	be	provided.

14	C.F.R.	91.9	(b)(2):	Civil	Aircraft	Flight	Manual,	marking,	and	placard requirements

The	UAS,	given	its	size	and	config uration	has	no	ability	or	place	to	carry	such	a	UAS Flight	Manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.

The	equivalent	level	of	safety	will	be maintained	by	keeping	the	UAS	Flight	Manual at	the	ground	control	point	where	the	pilot	flying	the	UAS	will	have	immediate

access	to	it.

Based	on	the	FAA	Memorandum	“Interpretation	regarding	whether	certain	required documents	may	be	kept	at	an	UA’s	contro l	station,”	dated	August	8,	2014	the requested	relief	from	91.9(b)(2)	may	not	be	necessary.

In	addition,	the	FAA	has	issued	the	following	exemptions	to	this	regulation: Exemption	Nos.	8607,	8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602, 32827,	and 10700.

14	C.F.R.	91.203	(a)	&	(b):	Carrying	civil	aircraft	certification	and	registration

This	regulation	provides	in	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	c urrent	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.9 The	UAS	fully	loaded	weighs	no	more	than	15	lb.	and	is	operated	without	an onboard	pilot.	Therefore	there	is	no	ability	or	place	to	carry	certification	and registration	documents	or	to	display	them	on	the	UA.

An equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the ground	flight	control	point	where	the	pilot	flying	the	UAS	will	have	immediate access	to	them,	to	the	extent	they	are	applicable	to	the	UAS.	The	FAA	has	issued numerous	exemptio ns	to	this	regulation.	A	representative	sample	of	other exceptions	includes	Exemption	Nos	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,

and	10700.

In	addition,	based	on	the	FAA	Memorandum	“Interpretation	regarding	whether certain	required	documents	may	be kept	at	an	UA’s	control	station,”	dated	August	8, 2014	the	requested	relief	from	91.203	(a)	&	(b)	may	not	be	necessary.

14	C.F.R.	91.103(b):	Preflight	Action

This	regulation	requires	each	pilot	in	command	take	certain	actions	before	flight	to

ensure	the safety	of	flight.	An	exemption	is	needed	from	this	requirement	as	the pilot	will	take	separate	preflight	actions,	including	checking	for	weather	conditions, checking	flight	battery	requirements,	checking	takeoff	and	landing	distances,	and	all

other	actions in	the	Preflight	Checklist	of	the	Manual.	These	actions	will	provide	an equivalent	level	of	safety.

14	C.F.R.	91.109:	Flight	Instruction

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.

By	design,	UASs	and	remotely	piloted	aircraft	do	not	have	fully	functional	dual controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that

communicat es	with	the	aircraft	via	radio	communications.	As	a	result, t raining	will be	conducted	during	dedicated	sessions following	the	guidelines	in	the	Manual.

The	FAA	has	previously	approved	exemptions	for	aircraft	without	fully	functional

dual	controls.	See	Ex emption	Nos.	5778K	&	9862A.	The	equivalent	level	of	safety provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the aircraft,	the	ability	to	control	the	UAS	via	radio	signals	from	the	controller,	and	by the	size	and	speed	of	the	airc raft.

14	C.F.R.	91.119 (c) :	Minimum	Safe	Altitudes

Section	9 1.119(c) prescribes	that,	except	when	necessary	for	takeoff	or	landing,	no person	may	operate	an	aircraft	below	the	following	altitudes:	(c) Over	other	than congested	areas .	An	altitude	of	500 feet	above	the	surface,	except	over	open	water	or10 sparsely	populated	areas.	In	those	cases,	the	aircraft	may	not	be	operated	closer than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.

This	exemption	is	for	a	multi

- rotor	craft	that	flies	similarly to	a	helicopter,	with	a vertical	takeoff	and	vertical	landing,	which	will	typically	operate	at	altitudes	from	0 feet	to	400	feet	AGL,	so	an	exemption	may	be	need	to	allow	such	operations.	The UAS	will	never	operate	at	altitude	higher	than	400	AGL	and	will be	in	a	restricted area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	to operations	without	their	pre

- obtained	consent.

The	equivalent	level	of	safety	can	be	achieved	where	all	UAS	Flight	operations	will

be	conducted	at	least	50 0	feet	from	all	nonparticipating	persons	(persons	other	than the	PIC	or	VO),	vessels,	vehicles,	and	structures	unless:

a. Barriers,	fencing	or	structures	are	present	that	sufficiently	protect nonparticipating	persons	from	debris	in	the	event	of	an	accident. The operator	will	ensure	that	nonparticipating	persons	remain	under	such protection.	If	a	situation	arises	where	nonparticipating	persons	leave	such protection	and	are	within	500	feet	of	the	UA,	flight	operations	will	cease immediately	and/or;

b. The aircraft is	operated	near	vessels,	vehicles	or	structures	where	the	land owner/controller	has	granted	permission	and	the	PIC	has	made	a	safety assessment	of	the	risk	of	operating	closer	to	those	objects	and:

c. Operations	near	the	PIC	do	not	present	an	undue	hazard	t o	the	PIC	,	per 91.119(1).

In	addition,	the	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and speed	of	the	UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken without	the	permission	of	the authorized	representat ive .	Compared	to	flight operations	with	aircraft	or	rotorcraft	weighing	far	more	than	the	maximum	15	lb. proposed	herein	and	carrying	flammable	fuel,	any	risk	associated	with	our operations	is	far	less	than	those	presently	presented	with	helicopters	and	ot her conventional	aircraft	operating	at	or	below	500	AGL	in	the	telecommunications industry.

14	C.F.R.	91.121:	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising altitude	by	reference	to	an	altimeter	that	is set	“...to	the	elevation	of	the	departure airport	or	an	appropriate	setting	available	before	departure.”	As	the	UAS	may	not have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may

be	needed.

The	UA	will	automatically	provide	onbo ard	GPS	altitude	information	to	the	UAS	PIC via	a	radio	communications	telemetry	data	link,	which	downlinks	from	the	aircraft11 to	the	PIC	and	is	displayed	on	the	Ground	Station	Controller	for	active	monitoring	of the	flight	information.

An	equivalent	level of	safety	will	be	achieved	by	the	operator,	pursuant	to	the Manual	and	Safety	Checklist,	confirming	the	altitude	of	the	launch	site	shown	on	the GPS	altitude	indicator	before	flight.

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

Section	91.151	(a)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR conditions.	Our	UAS	is	limited	to	operations	in	sterile	and	controlled	environments as	outlined	in	the	Manual,	and	has	a	limited	range	and	flight	time	which	require	an exemption	fr om	14	CFR	91.151(a).

The	battery	powering	the	UAS	provides	up	to	approximately	35	minutes	of	powered flight.	To	meet	the	30	minute	reserve	requirement	in	14	CFR	91. 151,	UAS	flights

would	be	limit ed	to	5	minutes	in	length. Given	the	limitations	on	the	UAS’ s	proposed flight	area	and	the	location	of	its	proposed	operations	within	a	predetermined	area, a	longer	time	frame	for	flight	in	daylight	VFR	conditions	is	reasonable.

Integrity	Management	believes	that	an	exemption	from	14	CFR	91.151(a)	falls

within	the scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed Martin	Corporation	to	operate	without	compliance	with	FAR	91.151(a)).	Operating the	small	UAS,	in	a	secure	controlled	area	with	less	than	30	minutes	of	reserve	fuel, does	not	engender	the	t ype	of	risks	that	Section	91.151(a)	was	intended	to	alleviate given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	UAS	flights	to	5 minutes	would	greatly	reduce	the	utility	for	which	the	exemption	will	be	granted.

An	equivalent	level	of	safet y	can	be	achieved	by	limiting	flights	t o 30	minutes,	or enough	battery	reserve	to	ensure	that	that	UAS	lands at	the	ground	station	with	at least	20%	of	battery	power	whichever	happens	first.	The	Integrity	Management	UAS onboard	power	management	system	cont inuously	monitors	flight	time	and	amount of	battery	power.	It	transmits	this	information	to	the	PIC	at	the	ground	station	in

real

- time.	Similar	exemptions	have	been	granted	to	other	operations,	including Exemptions	2689F,	5745,	10673,	and	10808.

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:

Applicant	seeks	an	exemption	from	the	following	rules:	14	C.F.R. 21,	subpart	H;	14

C.F.R.	61.113 (a)	&	(b);	91.7	(a);	91.9	(b)	(2);	91.103	(b);	91.109;	91.119	(c);	91.121; 91.151	(a);	91.203	(a)	&	(b);	91.405	(a);	91.407	(a)	(1);	91.409	(a)	(1)	&	(a)	(2)	and 91.417	(a)	&	(b)	to	operate	commercially	a	small	unmanned	vehicle	(15lb.	or	less)	in its	opera tions.12 Approval	of	exemptions	allowing	commercial	operations	of	UASs	enhances	safety while	reducing	risk.	Manned	aircraft	monitoring	and	surveying	creates	a	greater risk	because	the	craft	are	much	larger,	have	combustible	fuel,	and	carry	an	onboard

human pilot.	In	contrast,	a	UAS	weighing	few er than	10	lb.	and	powered	by	batteries eliminates	virtually	all	of	that	risk	given	the	reduced	weight	and	lack	of	combustible fuel	carried	on	board.	The	UAS	will	carry	no	passengers	or	crew	and,	therefore,	will

not	ex pose	them	to	the	risks	associated	with	manned	aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	15	lb.,	conducted	in	the	strict conditions	outlined	above	and	in	the	manual,	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	allo wing	commercial operations.	Thes e	lightweight	aircraft	operate	at	slow	speeds,	close	to	the	ground, and	in	a	sterile	environment	and,	as	a	result, are	far	safer	than	conventional operations	conducted	with	turbine	helicopters	operating	in	close	proximity	to	the ground	and	people.

Privacy

All	fli ghts	will	occur	over	private	or	con trolled	access	property	with	the	property owner’s	prior	consent	and	kno wledge.	Images	taken	will	be	of	individuals	who	have also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where aerial	photography	will	take	place.

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

– provide	more	than adequate	justification	for	the	grant	of	the	requested exemptions	allowing commercial	opera tion	of	applicant’s	UASs	in	the	telecommunications	industry pursuant	to	the	Manual	appended	hereto.

Sincerely,

Ja m es	G. Grubbs

Owner Integrity	Management,	LLC