### 1 March 3, 2016
Mr. Anthony J. Fullam President AirProV , LLC 212 Blue Quail Place Trenton, OH 45067 Phone: 513

- 317

- 5678 E

- mail: anthony@airprov.com
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), AirProV, LLC (referred to hereafter as "AirProV"), the operator of small Unmanned Aircraft Systems ("sUAS"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A. Attached as Appendix B is a summary of this request.
The requested exemption would permit commercial operation of AirProV , sUAS s, which weigh between .55 and 25 lbs for the purpose of aerial photography, aerial cinematography, aerial inspections, and other sUAS flight operations that consist of still photographs and cinematography taken by on

- board cameras. Use of the sUAS for aerial photography, aerial cinematography and aerial inspections, and other sUAS flight operations will reduce the need to utilize conventional manned aircraft, manned lifting devices or manned climbing for th e same purpose and provide high

- quality digital imagery at a fraction of the cost. These savings result in enhanced safety, efficiency and productivity for the affected activities, as well as environmental benefits. AirProV, plans to implement the capabili ties of sUAS to offer services including:

• Aerial photography

• Aerial cinematography

• Aerial inspections

• Other sUAS flight operations
Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivale nt level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.
As described more fully below, the requested exemption would authorize commercial operations of aeria l photography, aerial cinematography, and aerial inspections or other sUAS flight operations using sUAS which

### 2 weigh less than 25 lbs and are small in size (see the attached O&M manuals). The sUASs will be operated under controlled conditions at low altitud e in airspace that is limited in scope, as described more fully herein; it will have automated control features, as described below and in the O&M manuals. AirProV, will maintain full general liability aviation at all times on aircrafts. Furthermore, the s UAS also will be operated by an individual who has passed an FAA approved Private Pilots ground training exam, medical certification and a required manufacturer’s training program for the sUAS. Finally, the airspace in which the sUAS will operate will be C lass G airspace or airspace approved by the FAA in advance.
AirProV respectfully submits that because these small, unmanned aerial vehicles will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional air craft or other manned mean, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. Approval of these exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s (the F AA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”
The name and address of the applicant are:

AirProV, LLC Attn: Anthony J . Fullam Phone: 513

- 317

- 5678 E

- mail: anthony@airprov.com Address: 212 Blue Quail Place, Trenton, OH 45067
The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.1 33(a); 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b).
Appendi x A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

AirPr oV submits that grant of this exemption applicat ion for use of the proposed UAS s in of aerial photography, aerial cinematography , and aerial inspections, and other sUAS flight operations will advance the Congressional

### 3 mandate in Section 333 of the Ref orm Act to accelerate the introduction of UASs into the national airspace system ( " NAS " ) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

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

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

• Operation of the UAS within visual line of sight of the operator.
Reform Act § 333(a)(1). If the Secreta ry determines that such vehicles " may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft i n the national airspace system." Id. §333(c) (emphasis added). 1

The Federal Aviation A ct expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraf t, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airwo rthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of s ections 44702

- 44716 of this title if the Administrator finds the exemption is in the public interest.

1 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the A dministrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the UAS. AirProV welcomes the opportunity to consult with FAA staff in order to address any issues or c oncerns that this proposal may raise that they believe may require modification.
49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).
The grant of the requested exemption is in the public interest based on the clear directio n in Section 333 of the Reform Act; the additional authority 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 and cost savings associated with transitioning to UASs for aerial photography, aerial cinemato graphy, an d aerial inspections and other sUAS flight operations . Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Airwort hiness of the sUAS
A critical element of the exemption application involves evidence of the airworthiness of the sUAS. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requi rement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. Our small UAS's will operate at low speed in a controlled environment, at least five miles from an airport. 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.

### 4 RISK MITIGATION

AirProV , has reviewed FAA exemptions references 1

- 3 Condition and Limitations sections and believes that
proc edures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist developed and employed to ensure that the sUAS airworthiness will be verified before launch. Airworthiness wil l be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time failure prone components.

AirProV requests that in a manner similar to reference 3, he be allowed to operate within 5 miles of an airport provided that;
“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aer onautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.”
Operations within five (5) miles of an airport are not anticipated to be routine, but AirProV is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise

. Operations within Class B airspace are not requested due to lack of mode C transponder.
Mandatory Operating Conditions (see O&M and Safety Lists)
Grant of the exemption to AirProV will be subject to the following mandatory conditions, which are base d upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to be conducted over private or controlled

- acces s property.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

• Above Ground Level (AGL) altitud e to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds.

• 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.
Operator Requirements

AirProV respectfully proposes that operator requirements should take into account the characteristics of the part icular sUAS. Certain UASs, such as the DJI S1000+, DJI S900, D JI S800 EVO, DJI Inspire 1, DJI Phantom 3 Professional and DJI 4 are characterized by a high degree of control and various built

- in technical capabilities that limit the potential for operat ion outside of the operating conditions set forth above. Please see details in the attached O&M manuals for each in Appendix C

. Additional automated safety functions and safety enhancing features of the sUAS's include the following:

### 5 • Auto

- pilot detection of lost GPS or of insufficient satellites initiates an immediate return to aircraft take

off location ("home")

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

• If the auto

- pilot detects a lost

- link to the GCS for longer than 30 seconds, landing procedure begins.
Given these safety features, A irProV proposes that operators of the sUAS should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:

• have successfully complete d, at a minimum, FAA private pilot ground school instruction and passed the FAA Private Pilot written examination or FAA

- recognized equivalents;

• have completed the manufacturer’s training or a minimum of 40 hours training pr ogram for operation of the sUAS s

.
AirProV notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Feder al Aviation Administration, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airme n’s certificates. 49 USC §44701 (f).

### 6 In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations of a sUASs conducting precision aerial inspections or surveys.

A pproval of the exemption allowing commercial operations of the sUAS for precision inspection and survey work will enhance safety by reducing risk. Conventional aerial photography, aerial cinemato graphy and aerial inspection operations, using helicopter or piston

- powered aircraft present r isks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the location. Other conventional manned climbing or mann ed lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards, and inhalation hazards associated with the structures being inspected. In contrast, a sUAS weighing less than 25 lbs. and powered by batteries eliminates a portio n of that risk given the reduced mass and lack of combustible fuel carried on board a manned aircraft and the lack of risks associated with manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights, manned lifts or climbing hazards.
Additionally, no national security issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the sUAS poses no threat to national security.
The operation of the sUAS, weighing less than 25 lbs., for aerial photography, aerial cinemato graphy, and aerial inspections i n accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting A irProV from the requirements of Part 21.

The sUAS s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports, operation within visual line of sight, and national security

— and its showing of an equivalent level of safety as it may relate to the re quirement for FAA training, provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the sUAS in the commercial aerial photography, aerial cinemato graphy, and aerial inspections business.

AirProV i s requesting this exemption for the purpose of aerial photography, aerial cinemato graphy, aerial inspections and other flight operations that may arise. The reason for such a general based exemption request is to integrate a horizontal business model in or der to capitalize on vast opportunities in the future without delay in additional exemption requests.

Very truly yours,
Anthony J. Fullam President AirProV, LLC

### 7 Enclosures:
Appendix A: Exemption Request and Equivalent Level of Safety Showings Under Applicable Rules Subject to Exemption

A p p e n d i x B : S u m m a r y o f T r i m b l e S e c t i o n 3 3 3 E x e m p t i o n R e q u e s t
Appendix C : Operation and Maintenance Manuals:

• DJI S1000+

• DJI S900

• DJI S800 EVO

• DJI Inspire 1

• DJI Phanto m 3 Professional

• D J I P h a n t o m 4

### 8 A P P E N D I X A

EXEMPTION REQUEST AND EQUI VALENT LEVEL OF SAFETY SHOWINGS UNDER APPLI CABLE RULES SUBJECT TO EXEMPTION

AirProV requests an exemption from the following regulations as well as any additional regulations that may technically app ly to the operation of the sUAS s :
14 C.F.R. § 45.23(b): Marking of the Aircraft
The regulation provides:
When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

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

- sport ",

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

The sUAS s has no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The word " Experimental " will be placed on the forward fuselage in compliance with § 45.29(f). The equ ivalent level of safety will be achieved by having the sUAS marked on its forward fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV will see the identification of the sUAS as "Experimental". The FAA has issued th e following exemptions to this regulation to Aerial Pros, Exemption No. 10700, and to others, including Exemption Nos. 8738, 10167 and 10167A.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 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 AirProV , an exemption from Par t 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the
requ irement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports of the particular UAS. Our small sUAS s will be operated at low speed in a controlled environment, at least five miles from an airport. An analysis of these crit eria demonstrates that the sUAS s operated without an airworthiness certificate, in the restricted environment and under the conditions proposed wil l be at least as safe, or safer than a conventional aircraft (fixe d wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be o perated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials o r flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, 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 construction sites.
These safety enhancements, which already apply to civil aircraft operated in connection with construc tion sites, power plant sites and the like provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these s ame criteria demonstrates that there is no credible threat to national security posed

### 9 by the s UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no g reater than two lbs.
14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.
Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike a conven tional aircraft that carries a pilot, passengers, and cargo, the sUAS in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command o f an aircraft for compensation or hire. AirProV respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. AirProV's sUAS has a high degree of control and various built

- in technical capabilities th at strictly limit the potential for operation outside of the operating conditions set forth in the exemption application.
The sUAS has navigation and control system comprised of a Ground Control Station (GCS) and auto

- pilot system. All flights utilize prec ision GPS guidance. In the case of unplanned events, the operator inputs evasive maneuvers from the control unit, and the control unit executes that maneuver. Operator interventions include diversion to the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut off and land (Flight Termination System).
Given these safety features, AirProV proposes that operators of the sUAS should not be requir ed to hold a commercial or private pilot certification. Instead, operators should be required to:

• have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

- recognized equival ents;

• have completed manufacturer's training program or a minimum 40 hours training program for operation of the s UAS.

A irProV notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations.
Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the sUAS without a private pi lot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein

. The risks associated with the operation of the sUAS (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the lev el of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the s UAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).
14 C.F.R. § 91.7(a): Civil aircraft airworthiness.
This regulation requires that no person may operate a c ivil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the sUAS without an airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size of the aircraft and the requirements that have presumably already been met for the sUAS (for instance, the sUAS’s Operations and Maintenance Manual and

### 10 Safety Manual and Checklist), an equivalent level of safety will be achieved by insuring c ompliance with the manuals prior to ea ch flight.
14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.
The regulation provides:

No person may operate a U.S.

- registered civil aircraft... For which an Airplane or Rotorcraft Flight Manual is not required by §21.5
(2) of this chapt er, 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 the size and configuration of the sUAS, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level of safety will be achieved by keeping the flight manual (see, e.g ., User Guide, Exhibit 4) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 101 67, 10167A, 10602, 32827, and 10700.
14 C.F.R. 91.103: 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 se parate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual and Safety Checklists. These actions will prov ide an equivalent level of safety.
14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction
These regulations provide 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.
The sUAS is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communic ations. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will be assured. 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. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establish es safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 5 00 feet above the surface, except over open water or sparsely populated areas. In those cases, the ai rcraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

### 11 As set forth herein, the sUAS will never operate at higher than 400 feet AGL. Because aerial photography, aerial cinematog raphy , and aerial inspections must be ac complished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.
14 C.F.R § 91.121 Altimeter Settings

AirProV requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for altim eter use below 18,000 feet mean sea level (“MSL”) in maintaining the cruising altitude or flight level of the aircraft. A irProV operation of the sUAS will not exceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight suc h as a manned aircraft will typically fly. The ground station has live feedback and GPS information about the sUAS, including but not limited to the height of the sUAS, its forward velocity, and compass heading. The operator will be able to observe and con trol the maximum height of the sUAS. Additionally, the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety provided by Section 91.121 will be met.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

T his regulation prohibits an individual from beginning " 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 s peed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly afte r that for at least 45 minutes."
The sUAS batteries provide approximately 15

- 30 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS ’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

A irProV believes tha t an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel d oes not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or carg o also enhances its safety. Additionally, limiting sUAS flights would gr eatly reduce their utility. In the unlikely event that the sUAS should run out of battery charge, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

AirProV believes that an equ ivalent level of safety can be achieved by maintaining 10 minutes of reserve battery, which, allows approximately 30 minutes of flight time, but AirProV limits all flights to no greater than 20 minutes, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.
14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration
This regulation provides as follows:
(a) . . . no person may operate a civil aircraft unless it has . . . an app ropriate 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 co ckpit entrance so that it is legible to passengers or crew.

### 12 The sUAS s fully loaded weighs no more than 25 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation . A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections
Section 91.405(a) requires that an aircraft ope rator or owner " shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . ." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certai n maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the sUAS s will be accomplished by the owner/operator pursuant to the ma nuals. An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached Maintenance Man ual and the Safety Checklist, the trained operator of sUAS will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person mos t familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.

### 13 APPENDIX B

SUMMARY OF TRIMBLE SECTION 333 EXEMPTION REQUEST

AirProV hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the DJI S1000+, DJI S900, DJI I nspire 1, DJI Phantom 3 Professional and DJI Phantom 4 sUAS s for aerial photography, aerial cinematography , and aerial inspections. An exemption is r equested from the following regulations:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b).

### 14 A P P E N D I X C

OPERATION AND MAINTENANCE MANUALS & SAFTEY GUIDELINES

• DJI S1000+ User Manual v1.2

o http://www.dji.com/product/spreading

- wings

- s1000

- plus/download

• DJI S900 User Manual v1.2

o http://www.dji.com/product/spreading

- wings

- s900/download

• DJI S800 Evo User Manual v1.10

o http://www.dji.com/product/spreading

- wings

- s800

- evo/download

• DJI Inspire 1 User Manual (EN) v1.2

o http://www.dji.com/product/inspire

- 1/download

• DJI Phantom 3 Professional User Manual (EN) v1.0

o http://www.dji.com/product/phantom

- 3/download

• DJI Phantom 4

o http://www.dji.com/product/phantom

- 4 /downloadA i r P r o V , L L C 2 1 2 B l u e Q u a i l P l a c e T r e n t o n , O H 4 5 0 6 7