January 15, 2016 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Petition ofFiberCon, Inc. for anExemption Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 Director: Flight Standards Service: Pursuantto Section 3 3 3 ofthe FAAModernization and ReformAct of2012 ("ReformAct") and 14 C.F.R. Part 11, FiberCon, Inc. (FiberCon) hereby applies for an exemption from the Federal Aviation Regulations ("F ARs") identifiedbelowto allow commercial operation ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial photography, videography, cinematography, mapping, and infrastructure inspection for the motionpicture, television, real estate, communications, utilities and web industries. This petition for exemption is made based on information outlined inthis Petition for Exemption, as well as the accompanying FiberCon documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. Flight Manual 1 (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") FiberCon submits these supporting materials as confidential documents pursuantto 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary informationthat FiberConhas not and will not share with otherrequesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom oflnformationAct, 5 U.S.C. § 552 et. seq. 

### NOTE: ALLATTACHMENTS SET FORTH IN SUPPORT OFTHIS LETTER OF PETITIONARE CONFIDENTIALAND SHALLNOT BE RELEASED TO THE PUBLIC WITHOUT WRITTENAUTHORIZATION FROM THE PETITIONER. For your convenience, this Petition is organized as follows:

1

. The term "Manufacturer's Manual" also includes all relevant manufacturerpublications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation January 15, 2016 Page2

I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Photography, Videography, Cinematography, Mapping, and Infrastructure Inspection III. Relevant StatutoryAuthority IV. FiberCon's Proposed UAS Operations Meetthe Requirements of Section 333 ofthe ReformAct A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions SetForth inthe Operations Manuals V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(l) B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. § 91.7(a): CivilAircraftAirworthiness G. 14 C.F.R. § 91.9(b)(2): CivilAircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration H. 14 C.F.R. § 91.103: PreflightAction I. 14 C.F.R. § 91.109(a): Flight Instruction J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes K. 14 C.F.R. § 91.121: Altimeter Settings L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight inVFR Conditions VI. Drug andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. Conclusion

### U.S Department ofTransportation January 15, 2016 Page 3 

### I. DESCRIPTION OF PETITIONER FiberCon is based in Dallas, TX and provides aerial photography, videography, cinematography, mapping, and infrastructure inspection for the motionpicture, television, real estate, communications, utilities and web industries. The Company's Principal and ChiefPilotJarrod Goudeau has been flying UAV Quadcopters as a hobby for more than fourteen years without incident, logging thousands ofhours flying. Additionally, Mr. Goudeau was trained in small UAV building, repair and setup along with UAV acrobat flight and FAI technical precision flight. Mr. Goudeau will obtain a UAV operator license when the FAA makes the certification available. FiberCon, Inc. will use a UAV operator who holds a private pilot license in accordance with current FAAregulation until Mr. Goudeau can obtain a FAA UAV operator's license. Upon the grant ofthe 333 Exemptionthe Company's business will specialize in aerial photography, videography, cinematography, mapping and infrastructure inspection for the film, television, real estate, communications, utilities and web industries. FiberCon's staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in additionto any other needed on site assistance. All ofthe equipment ownedby FiberCon is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. FiberCon's goal is to advise the perspective client that FiberCon is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. FiberCon seeks an exemption to allow for aerial photography, videography, cinematography, mapping and infrastructure inspection and other related mediaproducts. The contact information for Petitioner is as follows: Jarrod Goudeau FiberCon, Inc. 3109 Knox Street, Ste. 511 Dallas, TX 75205 Phone: 214-233-6557: Email:jarrod@titlewise.com 

### II. DESCRIPTION OF PROPOSED OPERATION FiberCon seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Phantom 3 Pro (referred to FC-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on private property or approved location where FiberCon has received verifiable permission to operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations ofthis Petition for Exemption and FiberCon's Operations Manuals. As detailed in FiberCon's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, FiberCon's Operations Manuals incorporate redundant safeguards toU.S Department ofTransportation January 15, 2016 Page4

assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. A. Aerial Videography, Photography and Cinematography FiberCon seeks to use small FC-UAS for the purpose ofconducting aerial photography, videography, cinematography, mapping, and infrastructure inspection for the motion picture, television, real estate, communications, utilities and web industries. FiberConhas purposefully tailored its operations to meet the requirements establishedbythe FAA inprior grants of exemption authorizing commercial use ofUAS in the real estate industry, including:

• AstraeusAerial (ExemptionNo. 11062) • Aerial MOB, LLC (ExemptionNo. 11066) • Pictorvision, Inc. (ExemptionNo. 11067) • HeliVideo Productions, LLC (ExemptionNo. 11065) • Snaproll Media, LLC (ExemptionNo. 11063) • RC Pro Productions Consulting, LLC d/b/aVortexAerial (ExemptionNo. 11064) • Flying-Cam, LLC (ExemptionNo. 11080) • Aerocine, LLC (ExemptionNo. 11150) • Team 5, LLC (ExemptionNo. 11158) • Alan D. Purwin (ExemptionNo. 11161) • HelinetAviation Services, LLC (ExemptionNo. 11160) • Picture Factory, Inc. (Exemption No. 11178) • Airshark (ExemptionNo. 11651) • Trudeau, Realtor® (ExemptionNo. 11138) • Alon Sicherman (ExemptionNo. 11728) All UAS photography, videography, cinematography, mapping and infrastructure inspection operations will occur on private property or approved location in a controlled area away from spectators and persons not involved in the recording process. In addition, the filming will be conductedbetween dawn and dusk to ensure maximum safety for the public and those involved in the manipulation and operation ofthe UAS; VFR conditions, at altitudes below400' above ground level ("AGL"). As set forth below, FiberCon's operations provide an equivalent level ofsafety which is superior to performing the same work using conventional fixed-wing aircraft or helicopters. Small UAS recording operations is also saferthan traditional manned aircraft performing the same function. Videographer, photographers and inspectors also frequently need to climb roof tops, trees, ladders or otherwise perform elevated work, which exposes them to the risk of dangerous falls, electrocution or other work related injuries. In addition, depending on the nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk of exposure to hazardous conditions. The use ofFC-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most othertypes of recording operations.U.S Department ofTransportation January 15, 2016 Page 5 Moreover, conventional operations using rotorcraft and fixed-wing aircraft in lowlevel operations presentrisks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel which inherentlypresents significant fire hazards as well as exposure to other chemical contaminates. Itis importantto note the use of small UAS inthis area will not onlybe safer and more cost effective to the perspective user or purchaser ofthe service, butthe quality and expanse ofacquired information will be far more robust given the low cost associated with its acquisition and otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory datawith greaterprecision and duration at a very low cost. Small UAS will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible orhighly dangerous using conventional aircraft or other inspection methods. III. RELEVANT STATUTORYAUTHORITY This Petition for Exemption is submittedpursuantto Section 333(a) through (c) ofthe FAAModernization and ReformAct of2012 ("ReformAct"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 33 3 ofthe ReformAct, the FAAAdministrator is to permit unmanned aircraft systems to operate in the NationalAirspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAAAdministratorhas general authority to grant exemptions from the agency's safetyregulations and minimum standards whentheAdministrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(±) (defining the authority ofthe Administrator); 49 U.S.C. § 44701(±) (permitting exemptions from§§ 44701(a), (b) and §§ 44702-44716, et seq.). Aparty requesting an exemptionmust explain the reasons whythe exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or howit wouldprovide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). IV. FIBERCON'S PROPOSED FC-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The small FC-UAS operations proposed by FiberCon as noted above inthis Petition for Exemption qualify for expedited approval pursuantto Section 333 ofthe ReformAct as each of the statutory criteria and relevant factors are satisfied. A. Approval is Warranted Based on the VAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conductedusing the UASs due to their size weight, speed, and operational capability.U.S Department ofTransportation January 15, 2016 Page 6 The FC-UAS utilized by FiberConhas been approved for use in prior Section 333 Grants ofExemption from the FAA. 2

• The FC-UAS weighs less than 55 pounds, including payload

• The FC-UAS will not be flown at a ground speed in excess of50 knots. The exemptionholder may use either groundspeed or calibrated airspeed to determine compliance withthe 50 knot speed restriction

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encodedbarometric altimeter, radio altimeter, or any combinationthereof. This information will be transmitted to the pilot viatelemetric data feed.

• The FC-UAS will have systemredundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnectionto the remote control or ground control station is lost, failsafe systems will permitthe UAS to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control ofthe FC-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the FC-UAS is 2.4 and 5.8 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending on payload. The difference in weight betweenthe FCUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event ofan unintended accident or incident. In addition, the riskto the onboard pilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in FiberCon's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected FC-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assistthe FAA in making a safety assessment ofFiberCon's proposed operations, belowis a summary ofoperational limitations and conditions that FiberCon will adhere to, and which will ensure an equivalent or higher level ofsafety to operations conducted under currentregulatory guidelines: 1. The FC-UAS weighs less than 55 pounds, with payload.

2 See e.g., Grant ofExemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant ofExemption to VDOS Global, LLC (Exemption No. 11112); Grant ofExemption to LowCountryRC, Corp. (Exemption No. 11184); Grant ofExemption to Alan Purwin (ExemptionNo. 11161); Grant ofExemptionto HelinetAviation Services (ExemptionNo. 11160); Grant ofExemptionto Total Safety U.S., Inc. (ExemptionNo. 11156)

..

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2. All operations shall be conducted over private or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight prior to operation. 3. All UAS operated under the Grant ofExemption will be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe FC-UAS, and one ormore Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a 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 ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in whichthe PIC is rated on his or herpilot certificate. 6. The FC-UAS shall be operated withinVLOS ofthe PIC and Observer at all times. The PIC must use human vision unaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption shall be added to the FiberCon's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations in the Grant ofExemption and FiberCon's Operations Manuals, the conditions and limitations in the Grant ofExemption shall take precedence and must be followed. Otherwise, FiberCon shall follow the procedures outlined intheir Operations Manuals. 10. FiberCon may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administrator upon request. FiberCon will also present an updated and revised Operations Manuals ifit petitions for extension or amendmentto its Grant ofExemption. Ifan update or revision would affectthe basis upon which the FAA grants the exemption, FiberCon will seek an amendment to its Grant ofExemption. FiberCon will contact the FAA'sUAS Integration Office (AFS-80) ifquestions arise regarding updates or revisions to the operating documents.U.S Department ofTransportation January 15, 2016 Page 8 11. FiberCon Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the FC-UAS is operating. 12. The PIC is prohibited from beginning a FC-UAS flight unless (considering wind and forecast weather conditions) there is enough powerto fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximumtotal flight time for each operational flight using the FC-UAS will be limited to 40 minutes orthe amount oftime the UAS can be flown and still maintain a reserve batterypower ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feetAGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. Inthe event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point onthe structure, and no more than 50 feet horizontally from the structure. 15. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAand/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present an undue hazard, and;

c. Operations nearerto the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 16. The FC-UAS may notbe 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. 17. The FC-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the FiberCon COA. The letter ofagreement with the airport management will be made available to the Administrator upon request. 18. Prior to each flight the PIC shall inspectthe FC-UAS to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents as well as equipment updates. The PIC shall not operate any FC-UAS ifthe inspectionreveals a condition that affects the safeU.S Department ofTransportation January 15, 2016 Page 9 operation ofthe FC-UAS until the necessary maintenance has beenperformed and the FC-UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflight inspection. All maintenance and alternations mustbe properly documented inthe UAS's records as required by FiberCon's Operations Manuals. 19. FiberCon will timely carry out its maintenance, inspections, and record keeping requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe FC-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning the FC-UAS to service. 20. Any FC-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) musttimely undergo a functional test flight in accordance with FiberCon's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and FC-UAS record entry shall be included inthe FiberCon's Operations Manuals. 21. The FC-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and productupdates. 22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on FiberCon's Operations Manuals. 23. FiberCon will obtain anAir Traffic Organization ("ATO") issued Certificate of Waiver orAuthorization, otherwise known as a COA, priorto conducting any operations under this Grant ofExemption. ANOT AM will be issued as required by the COA. All operations will be conducted in accordance with airspace requirements in the ATO issued COAincluding class ofairspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe FC-UAS loses communication with the PIC, it will have the capability to safely return to a pre-determined location withinthe operational area and land safely. 26. Contingencyplans will be in place to safely terminate flight ifthere is a loss of communicationbetweenthe PIC and the Observer. 27. The FC-UAS will have the capability to safely abort flight in the case ofunpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued withinthe United States

.U.S Department ofTransportation January 15, 2016 Page 10 29. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraftpilot and at least 10 hours logged as a UAS pilotwith a similarFC-UAS type platform. This requirement canbe achievedby flights conducted and logged as a hobbyist. 30. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum ofhours pursuantto 54 CFR § 61.51(b) as UAS pilot operating the make and model ofFC-UAS to be utilized for operations under the exemption andthree take-offs andthree landing inthe preceding 90 days. 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The FC-UAS shall remain clear and yield the right ofwayto all othermanned operations and activities at all times (including, butnot limitedto, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. FC-UAS Operations under Instrument Flight Rules, at night, orbeyondVLOS are prohibited. 34. The UAS will notbe operated from an elevatedplatform unless designed and engineered specifically for suchpurposes andbe in compliance withthe general restrictions imposedbythe applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevatedplatform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe FC-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The FederalAviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 oftheAct, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest.3 FiberCon seeks an exemption from several interrelatedprovisions ofTitle 14 ofthe Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconductingthe requested operations using FC-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and

3 49 U.S.C. § 4470l(f) (authorizing the grant ofexemptions from requirements ofregulations prescribed pursuantto Sections 44701(a) and (b) and Sections 44702- 44716).U.S Department ofTransportation January 15, 2016 Page 11 safeguards that Petitionerhas established which will ensure a level ofsafety better than or equal to the rules from which exemption is sought. 4 UNMANNEDAIRCRAFTSYSTEM A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) The FAAhas stated that no exemption is needed from this section ifa finding is made under the ReformActthat the UAS selected provides an equivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and inpoint offact exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there are some characteristics ofthe chosen UAS that fail to meet the requirements ofthe ReformAct, an exemption is requested. 

### EquivalentLevelof Safety FiberCon's use ofthe FC-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description ofproposed operations in Section IV(A), the FC-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of50 knots. The FC-UAS is also equipped with safety features which will allow Petitionerto operate the FC-UAS safely after experiencing certain in-flight contingencies or failures as noted below.6 7

4 14 C.F.R § 11.81(e), whichrequires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, orhow the exemption would provide a level ofsafety at least equal to that provided by the rule from which you seek exemption.

5 See Grant ofExemptionNo. 11062 toAstraeusAerial (FAA-2014-0352 atpgs. 13-14, 22).

6 See e.g., Grant ofExemptionNo. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation."

7 See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The FC-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The FC-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones ormaximum flight ranges and altitudes so the system cannot enter areas deemed unsafe orunnecessaryto fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the FC-UAS to detect a system fault while inthe air and automatically fly backto its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set windthresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commandingthe system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as windthresholds are notU.S Department ofTransportation January 15, 2016 Page 12 Additionally, the FC-UAS carries neitherpilots norpassengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively withinthe parameters stated inFiberCon's Operations Manuals. Operations conducted underthis exemption will be closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. FiberCon will also provide the FAAwith advance notice ofall operations viaNOTAMs as required bythe applicable COA. In all cases, operation ofthe FCUAS under the proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate. Lastly, the FC-UAS do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the FC-UAS. 8 In addition, no sense-and-avoid technology is necessary for the FC-UAS because they will be operated at all times inVFR conditions and withinVLOS ofthe PIC and Operator. 9 B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal categoryrotorcraft. To the extent that FiberCon's small FC-UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements FiberCon seeks an exemption from the aircraft marking and identificationrequirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), CivilAircraft 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 ofthis chapter.

• 14 C.F.R. § 45.23(b), Markings oftheAircraft, states: 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 onthat aircraft near each entrance to the cabin, cockpit, or
exceeded. Also a flight termination link- to prevent a 'fly away' or other potentially dangerous situation- is available to the operator."

8 See Grant ofExemption No. II062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S Department ofTransportation January 15, 2016 Page 13 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.

• 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by § 45.23. In a previous Grant ofExemption, the FAAdeterminedthat exemption from these requirements was warrantedprovidedthatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 

### EquivalentLevelof Safety All FC-UAS flown by FiberConwill bearN-numbermarkings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C." D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): MaintenanceInspections FiberCon seeks an exemption from the maintenance inspectionrequirements contained in 14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption from these regulations is needed because Part 43 andthese sections onlyapply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption will nothave. (Emphasis added) 

### EquivalentLevelof Safety An equivalent level ofsafety will be achieved or exceeded because maintenance and inspections will be timelyperformed in accordance withthe Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by FiberCon's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe FC-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe FCUAS and no flights will occurunless, anduntil, all flight critical components ofthe FC-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by FiberCon's Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe FC-UAS aircraft records ofthe flight.

10. FAA Docket No. FAA-2014-0352.

11. See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation January 15, 2016 Page 14 FiberCon's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, FiberCon's Operations Manuals also include procedures to document and maintain a record ofthe FC-UAS's maintenance, preventative maintenance, alterations, status of replacement/overhaul componentparts, and the total time in service ofthe FC-UAS used under this Grant ofExemption. As a whole, the maintenance and inspection procedures required in FiberCon's Operations Manuals ensure that an equivalent or higher level ofsafety will be achieved. PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations FiberCon seeks exemption from 14 CFR § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. Inthis case, while the FC-UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption to AstraeusAerial, the FAAdetermined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant withrequiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. EquivalentLevelof Safety The restrictions FiberConhas placed on its FC-UAS operations meet or exceed the restrictions similarly imposed onAstraeusAerial. FiberCon will operate onprivate property or approved location away from persons and property not involved inthe operation. FiberCon will also obtain anATO issued COApriorto conducting any operations underthis Grant ofExemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COAincluding class ofairspace, altitude level and potential transponder requirements. A NOTAM will also be issued as required bythe applicable COA. In addition to these flight restrictions, FiberCon will further ensure safe operationby requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also inthe unique aspects ofFC-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only inFC-UAS operations generally but have logged flight time inthe specific make and model used for the operations before they are permittedto participate in commercial flights on behalfofFiberCon. The pilot qualification,

12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352).U.S Department ofTransportation January 15, 2016 Page 15 training, and currency requirements in the Operations Manuals ensure that FiberConpilots are competent and proficient inthe FC-UAS they are operating. FiberCon's training and qualification requirements are consistent withthose contained inprior FAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. OPERATINGPARAMETERS OFTHE UAS F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UAS, FiberCon seeks an exemption from 14 C.F.R. § 91.7(a), whichrequires that a civil aircraft be in airworthy condition to be operated. The FAAhas stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitionerrequests that the requirements for§ 91.7(a) be treated in accordance with SectionV (A), supra. G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft FlightManual in theAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) For which anAirplane or Rotorcraft Flight Manual is required by§ 21.5 ofthis chapter, unless there is available inthe aircraft a current approvedAirplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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) ofthis 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. Given the small size and configuration ofthe FC-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboard the FC-UAS because there is simply no room and the FC-UAS has no cabin or cockpit. As a way to comply withthe code FiberCon will maintainthe documents withthe PIC and make them available for inspection.

13 See Id. at 13-14,22.U.S Department ofTransportation January 15, 2016 Page 16 

### EquivalentLevelof Safety In an FAAOffice ofChiefCounsel's Opinion datedAugust 8, 2014, and preparedby Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthepilot oftheunmanned aircraft has access to the UAS flight manual, registration certificate, and otherrequired documents from the ground control station from whichhe or she is operating the aircraft. 14 As this FAAOffice ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achievedby ensuring that the pilothas access to the documents atthe ground control station from whichhe or she is piloting the UAS. H. 14 C.F.R. 

### § 91.103: PreflightAction FiberCon seeks an exemption from 14 C.F.R. § 91.103, whichrequires a PIC to become familiar with specific information before each flight, including information contained in the FAAapproved FlightManual onboardthe aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extentthat anFAAapproved Flight Manual is required. 

### EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the FiberCon's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance with the FiberCon's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flightprocedures. The PIC will also be required to reviewweather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency landing areas-before initiation offlight. FiberCon's Operations Manuals and the Manufacturer's Manual will be kept atthe ground control station and will be accessible to the PIC at all times while operating the UAS. I. 14 C.F.R. 

### § 91.109(a): FlightInstruction FiberCon seeks an exemption from 14 C.F.R. § 91.109(a), whichprovides inpertinentpartthat "[n]o personmay operate a civil aircraft (except a manned free balloon) that is being used for flight instructionunless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, bytheir design, do nothave functional dual controls. Instead, flight control is accomplished throughthe use ofa device that communicates with the aircraft viaradio communications.Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

14 Memorandum from Mark Bury, FAAAssistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAAFlight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.U.S Department ofTransportation January 15, 2016 Page 17 EquivalentLevelof Safety Given the size and speed ofthe UASs that FiberCon intends to use, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required bythe FiberCon's Operations Manuals, all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight instruction. Moreover, as required bythe FiberCon's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safetyprocedures provided for in FiberCon's Operations Manuals ensure thatthe proposedUAS operations provide an equivalent orhigher level ofsafety thanthat provided bythe flight instructionregulations. J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes FiberConrequests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 15 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 helicopterto operate at less thanthose minimum altitudes when it canbe operated "without hazard to persons orproperty onthe surface," providedthat "eachperson operating the helicopter complies with any routes or altitudes specificallyprescribed for helicopters bythe FAA." An exemption is required because the proposed FC-UAS operation will normally needto occur below400 feet AGL. In circumstances where the FC-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the FC-UAS will notbe operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) mayneedto be less than 500 feet away from the FC-UAS. EquivalentLevelof Safety Comparedto flight operations withrotorcraft weighing far more thanthe maximum weights proposedherein, and giventhe lack offlammable fuel with the above noted UASs, any risk associated withthese operations is far less thanthose whichpresently exist with conventional aircraft. An equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe FC-UAS, as well as the controlled location where the operations will occur. In orderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, orwhen inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth inthe Operations Manuals, the FC-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the FC-UAS and any

15 Relieffrom § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons orproperty on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemptionNo. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15).U.S Department ofTransportation January 15, 2016 Page 18 possible debris resulting from its failure. As required bythe Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe FC-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and, operations near the PIC or Observer will not present an undue hazard per§ 91.119(a). Adherence to these restrictions in FiberCon's Operations Manuals will ensure operations canbe conducted without compromising public safety. 16 

### K. 14 C.F.R. 

### § 91.121: Altimeter Settings FiberCon seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter, butrather a GPS altitude read out. 

### EquivalentLevelof Safety The FAAhas stated that an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (1) the UASs will be operatedbelow400 feet AGL or below17

, (2) withinVLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation pointis established for the PIC to confirm accuracy ofthe onboard GPS. 18 The FC-UAS that FiberCon intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by FiberCon's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants ofExemption, the FC-UAS FiberCon intends to use, and the safety mitigationprocedures contained inthe Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemption to the requirements of§ 191.121 is therefore appropriate. 

### L. 14 C.F.R. 

### § 91.151(a): FuelRequirements for Flightin VFR Conditions

16 See e.g., Grant ofExemptionNo. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are present that can sufficiently protect nonparticipating persons from the U A or debris in the event ofan accident, then the UA may operate closerthan 500 feet to persons afforded such protection. The operatormust also ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closerthan 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closerto those objects and determines that it does not present an undue hazard."

17 Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than I00 feet above the highest point on the structure.

18 See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation January 15, 2016 Page 19 FiberConrequests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight inVFR conditions. Section 91.151 states: (a) No personmaybegin a flight in an airplane underVFRconditions 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) Atnight, to fly after that for at least45 minutes. Here, the technological limitations onUAS batterypowermeans that no meaningful flight operations canbe conducted while still maintaining a 30-minutebatteryreserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, it is not FiberCon's intentionto fly the FC-UAS at night. EquivalentLevelof Safety In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved byprohibiting the PIC from beginning a FC-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intendedpoint oflanding and, assuming normal cruising speed, to fly afterthat for at least 10 minutes. Inreaching this conclusion, the FAAconsidered that the UAS batteries for the FC-UAS provide approximately 50 minutes ofpowered flight (with payload) and provided battery level and battery time remaining inminutes and seconds to the PIC. 19 The FAA also considered the fact the FC-UAS operating manual states: "start every flight with a fully chargedbattery inthe aerial vehicle", and that inthe event that the FC-UAS shouldrun low onpower, the PIC will be alerted and can safely land the- FC-UAS as soon as possible. Like the VDOS Grant ofExemption, FiberCon's use ofthe FC-UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and in fact exceeded. Similarly, inthe Grant ofExemptionto AlanPurwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions couldbe achieved byprohibiting the PIC from beginning a flight with the UAunless (considering wind and forecast weather conditions), there was enoughpowerto safely fly at normal cruising speed to the intended landing point and land the UAwith 25% batterypower remaining. FiberCon will adhere to this limitationfor its FC-UAS flights. The FC-UAS includes a lowbattery warning system and the amount ofbatteryreserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the FC-UAS to a ground-based-on-screen display. 20 As required by FiberCon's Operations Manuals, the PIC will promptly fly the FC-UAS backto the home launch location orpredetermined abort location where it may safely land, while still maintaining a minimum of25%

19. Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20. The FC-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation relative to the UASU.S Department ofTransportation January 15, 2016 Page 20

reserve batterypower. FiberCon submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined withthe requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and withinVLOS ofthe PIC and Observer(s), ensure that the proposed operation will provide an equivalent or higher level ofsafety to the public to that providedbythe regulations from which exemption is sought. VI. DRUGAND ALCOHOL PROGRAM FiberCon will have policies inplace to ensure that no person mayparticipate in FC-UAS flight operations ifthey are underthe influence ofalcohol or any drug. VII. PUBLIC INTEREST The public interest will be served by granting FiberCon's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed inthis Petition. Granting this Petition for Exemptionhelps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act-the FAAAdministrator's assessment ofwhether certain UAS may operate safely in the NAS before completion ofthe statutorilyrequired rulemaking. The proposed FC-UAS operations in this Petitionfor Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermission was granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be inthe local vicinity. Traditional methods ofproviding surveillance and mapping services location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neithertrained nor equipped to perform, which exposes them to unnecessary risk ofserious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used inthe endproduct. The use ofsmall UAS can eliminate these hazards and ultimately create a much safer method ofperforming these types ofinspections creating a safer environment for the public as well as FiberCon employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crewin addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, inthe unlikely event of an accident, FiberCon's small battery powered FC-UAS presents significantly less danger to persons on the ground when compared to operations by conventional manned aircraft.21 As

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals orproperty in the event ofan incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation."U.S Department ofTransportation January 15, 2016 Page 21 Petitioner's FC-UAS are batterypowered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraftperforming in the same functions proposed herein. Air quality will naturally be improved withthe reduction offuel powered vehicles. Lastly, as recognizedbythe FAAinprior Section 33 3 Grants ofExemptionto filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft.22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additionaljobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, giventhe lower cost, owner/operators and others inthe relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. VIII. PRIVACY All FC-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate or controlled-access property withpermission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. IX. FEDERAL REGISTER SUMMARY Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication inthe FEDERALREGISTER, should itbe determined thatpublication is needed: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal Regulations: Part 21, SubpartH; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety byreducing riskto the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods. X. CONCLUSION FiberCon's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operation withinVLOS and national security. The proposed FC-UAS operations

22 See e.g., Grant ofExemptionNo. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation January 15, 2016 Page 22 will benefitthe public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemptionprovides the FAAwithmore than adequatejustificationfor granting the requested exemptions allowing FiberConto use small FC-UAS in the recorded production ofits product. We thank you for your prompt consideration ofourrequested exemptions. Respectfully Submitted,

J

arrod Goudeau FiberCon, Inc. 3109 Knox Street, Ste. 511 Dallas, TX 75205 Phone: 214-233-6557: Email:jarrod@titlewise.com (The following attached items containproprietary and commercial information exempt from disclosure underthe Freedom ofInformationAct, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuantto 14 C.F.R. § 11.35(b)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals PETITIONERREQUESTS THAT GOOD CAUSE EXISTS TO EXEMPTANYPART OF THIS PETITION FROM BEINGPUBLISHED IN THE FEDERAL REGISTERPUBLIC FORUM BECAUSE THE REQUESTED EXEMPTIONWOULD NOT SETA PRECEDENT,ANDANYDELAYINACTING ON THIS PETITIONWOULD BE DETRIMENTALTO THE PETITIONER.