August 10, 2015

Exemption No. 12388 Regulatory Docket No. FAA

– 20 15

– 1769

Mr. Scott D. Clark

913 W est Van Buren St reet Chicago, IL 60607

Dear Mr. Clark :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the condition s and limitations of the exemption, including the date it ends.

By letter dated May 6, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption

. You requested to operate an unmanned ai rcraft system (UAS) to conduct

a erial photography, cinematography, and videography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the p etitioner is a DJI Phantom 3

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,2

Subpart H

— Airwort hiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Scott D. Clark is granted an exe mption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Scott D. Clark is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 5 5 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of si ght (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must uti lize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be ab le to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensu re that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred t o as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outli ned in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documen ts. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The4

operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replace ment of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to e ach flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufa cturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Ric o, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to op erate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, ve hicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs5

(traini ng, proficiency, and experience

- building) and determi ning the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training se ssions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautica l chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enfo rcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS sign al, th e UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization ( ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the term s of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

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

P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs invol ved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request ;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operati on.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption , the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresScott	D.	Clark May	6 th ,	2015

913	W	Van	Buren	St.	Unit	3E Chicago,	IL	60607 Cell	(828)	691	1472

Email: scott@scottclark.co

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	of	2012** 

Attachments: 1) Phantom 3 Professional	User	Manual	1.0 2) Phantom 3 Professional	Quick	Start	Guide 3) Phantom	3	Intelligent	Battery	Safety	Guidelines 4) Phantom	3	Safety	Guideline	Disclaimer

References: 1) FAA	Exemption No.	11138,	Regulatory	Docket	No.	FAA20140481 in	the matter	of	the	petition	of	DOUGLAS	TRUDEAU 2) FAA	Exemption	No.	11136,	Regulatory	Docket	No.	FAA

**–** 2014

**–** 0508	in the matter	of	the	petition	of	ADVANCED	AVIATION	SOLUTIONS	LLC 3) FAA	Exemption	No.	11080	Regulatory Docket	No.	FAA20140355 in	the matter	of	the	petition	of	FLYING	CAM	INC 4) FAA	Exemption	No.	11437 Regulatory	Docket	No.	FAA

- 2015

- 0221 in	the matter	of	the	petition	of MARCUS	D.	MELHUS

Dear	Sir	or	Madam,

In	accordance	with	the	FAA **’** s	Guideline s	for	Submitting	a	Petition	for Exemption	under section	333	of	the	FAA	Moderniz ation	and	Reform	Act	of	2012,	I

Scott	D.	Clark ,	referred	to hereafter	as	the	petitioner,	request	exemption	from	the following	sections	of	Title	14,	Code	of Federal	Regulations **§ §** 

**61.113(a) ;	61.113(b);	91.119(c);	91.121;	91.151(a);	91.405(a);	91.407(a)(1);** 

**91.409 (a)(1)**  **;	91.409(a)(2);	91.417(a)	&	(b);**

In	order	to	operate	small	unmanned	aircraft	syste ms	(UAS)	commercially	in airspace regulated	by	the	Federal	Aviation Administration	(FAA)	for	the	purposes	of aerial	photography, cinematography,	videography,	and	other	flight	operations	that could	be	performed	safely	and more	cost	effectively	with	the	use	of	small	UAS	at	low altitude	within	the	U.S.	national	airspace syste m	as	compared	to	a	manned	aircraft.Operations	will	be	performed	only	at	the	request	of and	with	the	authorization	and

permission	of	clients	or	their	authorized	agents	in	order	to facilitate	commerce	and

raise	awareness	of	the	beneficial	uses	of	small	unma nned	air	systems.

So	long	as	such	operations	are	conducted	within	and	under	the	conditions	outlined

herein or	as	may	be	established	by	the	FAA as	required	by	Section	333.	The

conditions	identified	and proposed	by	the	petitioner	are	drawn	from	references	1

- 3.

**The	FARs** The	petitioner	seeks	exemption	from	the	above	mentioned	FARs	for	the	following

reasons **;**

**61.113(a)	&	(b) ;**  The	petitioner	requests	relief	in	order	to	facilitate	the	utilization	of	an experienced	UAS operator	with	the	addition	of	a trained	o bserver.	All	pre

- flight inspection,	maintenance	and	flight logs	will	be	saved	and	made	available	to	the	FAA and	Secretary	of	Transportation	(SoT)	for review;	with	the	purpose	of	safely integrating	civil	UAS	operation	in	the	National	Airspace System.

**91.119(c)** As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU),	operations

conducted	closer than	500	feet	to	the	ground	may	require	that	the	UA	be	operated

closer	than	500	feet	to	essential persons,	or	objects	that	would	not	be	possible

without	additional	re lief.	The	petitioner	requests modification,	waiver	or	exemption and	clarification	concerning	the	terms **“** congested	areas **”** and **“** densely	populated **”**

. The	petitioner	requests	waiver	for	this	condition	to	allow	reasonable	and responsible	operations	in	areas	of subdivisions	and	neighborhoods	if	required. The	petitioner	will	primarily	operate	the	UAS	between	ground	level	and	200	feet.

The UAS	will	be	operated	over	designated	properties	with	the	owner **’** s	consent	and while	maintaining a	safe	distance	from	persons.	T he	petitioner	will	compile	flight data	from	the	logs.	This	data	may assist	the	FAA	in	development	of	regulations	for commercial	operations	in	low

- risk,	controlled environments.

**91.121** As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU)	is	inapplicable	since

the UAS	does	not	have	an	altimeter	and	instead utilizes	electronic	GPS	with	a

barometric	sensor	for altitude	information. **91.151(a)** As	discussed	in	Exemption	11136	(ADVANCED	AVIATION	SOLUTIONS	LLC) prior relief	has	been	granted	for	manned	aircraft	to	ope rate	at	less	than	the prescribed	minimums, including	Exemption	Nos.	2689,	5745,	and	10650.	In addition,	similar	UAS	specific	relief	has been	granted	in	Exemption	Nos.	8811, 10808,	and	10673	for	daytime,	VFR	conditions.	The	UAS provides	battery	power remaining	in	percent	to	the	PIC.	The	UA	batteries	provide approximately 25	minutes of	powered	flight.	Information	provided	in	the	operating	documents	discusses procedures	regarding	remaining	battery	power	management.	Those	documentscontain	a condition	in	which	the	PIC	will	initiate	a	landing	procedure	when	battery

remaining	reaches	a specified	level.	Given	the	limitations	on	proposed	operations and	the	location	of	those	proposed operations,	The	FAA	found	that	a	reduced minimum	power reserve	for	flight	in	daytime	VFR conditions	was	reasonable.

As	discussed	in	Exemption	11437	(MARCUS	D.	MELHUS)	prior	relief	has	been granted	for	unmanned	aircraft	is	in	the	public	interest	and	under	the	authority	in	49

U.S .C.	106(f),	40113,	and	44701,	M R .	MELHUS	was	granted	an	exemption	from	14

CFR **§§** 61.23(a)	and	(c),	61.101(e)(4)	and	(5),	61.113(a),	61.315(a),	91.7(a), 91.119(c),	91.121,	91.151(a)(1),	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and 91.417(a)	and	(b),	to	the	extent	necessary	to	allow MR.	MELHUS	to	operate	a	UAS	to perform	aerial	data	collection	up	to	200	feet	above	ground	level.

**91.405(a) ;	91.407(a)(1);	91.409	(a)(1)	&	(2);	91.417(a)	&	(b)**  As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU),	The	petitioner

proposes	to inspect	and	ens ure	that	the	UAS	is	in	a	condition	for	safe	flight	in accordance	with	the	operating documents.	The	FAA	found	that	adherence	to	the petitioner **’** s	operating	documents	and	the conditions	and	limitations	specified, describing	the	requirements	for	maintenance, inspection,

and	record keeping,	were	sufficient	to	ensure	that	safety	would	not	be	adversely

affected.

**The	UAS** The	DJI	Phantom	3 is	the	newly	released predecessor of	the	highly	successful DJI	Phantom	2	vision	plus	which	was	a highly	successful	consumer grade	small

rotorcraft	in the	quadcopter	configuration

. The	Phantom	3	has	an advertised	wei ght

of	less than	46 Ounces (1280 g)	designed primarily	to	carry	aloft	a	high	definition camera.	It	has	an	advertised	maximum	speed	of	less than 31 knots	( 16 m/s)	and	a

maximum	climb	rate	of	l ess	than	1000	feet	per	minute	(5 m/s).	It	is powered	by	four electric	motors	with	a	distance	between	motors	of	less	than	14	inches	(350mm).

It	utilizes	an	internal	inertial	measuring	unit	(IMU)	with	integrated

barometric	sensor augmented with	global	positioning	system	(GPS /GLONASS )	to maintain	its	geospatial	orientation	and	position.	It	is controlled	primarily	through an	FCC	certified	radio	control	(RC)	unit.	Real	time	video	and telemetry	information is	transmitted	back	to	a	grou nd	control	station	allowing	the	operator	and/or PIC	to monitor	battery	level,	GPS	signal	strength,	altitude	(AGL),	distance	from	PIC,	camera imagery,	and	control	camera	angle.	It	has	failsafe	modes	of	operation	for	either	loss

of	RC	or GPS	signal.	Altitude can	be	limited	by	the	on board	flight	controller	and

maximum	altitude	can be	preprogrammed	by	the	PIC.	Battery	life	limits	flight	times to	approximately 23 minutes. The onboard	flight	controller	will	warn	the	pilot	via telemetry	and	external	lighting	cues before reaching	a	low	battery state.	An automatic	termination	of	flight	and	landing	will	be	initiated when	the	battery reaches	a	predetermined	low	state.	It	is	anticipated	that	flights	will	usually	last less

than	12	minutes.	More	information	is	available in	attachment	1.**Risk	M itigation**  The	petitioner	has	reviewed	FAA	exemptions	reference **’** s	1

- 3	Conditions	and

Limitations section	and	believes	that	the	procedures	specified	therein	are

reasonable	and	will	be	utilized	in order	to	manage	and	mitigate	risk	and ensure public	safety.	A	preflight	checklist	will	be developed	and	employed	to	ensure	that

the	UA	airworthiness	will	be	verified	before	launch. Airworthiness	will	be maintained	by	performance	of	routine	inspections	before	each	flight, maintaining flight	an d	maintenance	logs	to	record	time	on	failure	prone	components.	These

documents	will	be	made	available	to	the	FAA	and	SoT	to	assist	in	future implementation	of safety	standards	and	regulations.	The	petitioner	will	only	operate the	UAS	over	designated proper ties	with	the	owner **’** s	consent.	Flight	plans	will	be predetermined	to	limit	the	UASs	flight time	and	limit	safety	concerns.	The	petitioner will	take	into	account	distance	from	persons	and potential	flight	obstacles	prior	to operating	the	UAS.	UAS	operation will	always	be	within VLOS	of	the	PIC	and	the

observer.

**Public	I nterest**  Use	of	the	UAS	in	lieu	of	a	manned	aircraft	would	enhance	safety	and	reduce

the environmental	impact	as	compared	to	similar	operations	conducted	with

manned	aircraft	of greater	propor tions,	carrying	a	crew	and	flammable	fuel. Additionally,	use	of	the	UAS	in	order	to facilitate	commerce	could	lead	to	economic growth.	Operations	for	this	petition	will	enable service	for	property	owners	or	their designees	seeking	an	enhanced	perspective	f or characteristics,	amenities,	and benefits	of	their	desired	photographic	subjects	that	cannot	be displayed	through ground	level	videography/photography.	Aerial	photography	is	a	valuable marketing tool	that	can	lead	to	increased	commerce	and	enhance	person al	photography.	Aerial surveying	and	inspections	can	increase	work	site	efficiency,	improve	volumetric

estimations	and reduce	risks.	The	petitioner	will	provide	clients	with	photographic data	for	these	purposes	on	a **‘** for	hire **’** basis	acting	as	an	independen t	contractor.	A visual	observer	will	be	utilized.	Flight	data including	UA	flight	time,	Control	Unit operation	time, incident,	accident,	and	details concerning any	deviations	from normal	operations	will	be	available	to	FAA	for	use	in	collecting	data regard ing	the use	of	UAS	as	part	of	this	application.	This	data	may	be	submitted	to	FAA	via traditional	means	or	other	means	as	required.

**Conclusion** The	petitioner	is	requesting	this	exemption	for	the	purposes	of **“** aerial photography, cinematography,	videograph y ,	inspections	and	other	flight operations **”** .	The	reason	for	such	a general	and broad	based	request	is	that	the petitioner	wishes	to	utilize	a	business	strategy	of horizontal	integration	and maximize	economies	of	scope	in	order	to	capitalize	on	opportunities as	they	may arise	in	the	future	without	the	long	turnaround	time	associated	with	additional exemptions.	The	petitioner's	business	model	is	based	on	the	idea	of	offering	ad	hoc

small	UAS services	to	individuals	or	companies	who	wish	to	employ	these	service s as	a	safe,	effective,	and legal	option	to	enhance	their	business	or	hobby.	Thepetitioner	has	refrained	from	engaging	in commercial	use	of	the	UAS.	The	primary

purpose	of	seeking	this	exemption	is	to	obtain	the capability	to	offer	those	services

while	re maining	in	compliance.	The	petitioner	has more	than	40	hours experience	in

the fixed	single	aircraft	operation

.

Respectfully	submitted

Scott	D	Clark