James E. Mackler Attorney 615.238.6312 (Direct Phone) 615.248.4668 (Direct Fax) jmackler@bonelaw.com

{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) June 1 6 , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE, West Building Ground Floor, Room W12

- 140, Washington, DC 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b).

PETITION FOR SUMMARY EXEMPTION

Dear S ir or Madam:

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

and 14 C.F.R. Part 11, Middle Tennessee Industrial Development Association , (“ MTIDA ”) an
operator of Small Unmanned Aircraft (UA) hereby applies for an ex emption from the listed
Federal Aviation Regulations ("FARs") to operate an unmanned aircraft system (UAS) to conduct
video, photography, inspection, and data collection of buildings and potential building sites.

MTIDA is eligible for a summary exemption for aerial data collection. 1

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples

in clude imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments

aboard the UA. See exemption #. 11482.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) QUICK REFERENCE SUMMARY:

• Types of aircraft to be flown:

o DJI Phantom 3

o DJI Inspire 1

• Technical manuals are all currently available online at the following URLs:

o Phantom 3 : http://www.dji.com/product/phantom

- 3/download

o Inspire 1: http://www.dji.com/product/inspire

- 1/download

• The operations will be for aeri al data collection to conduct inspections of real estate

. 2

• We already agree to all the restrictions listed in Exemption # 11 784 granted to Precision

Unmanned Aerial, LLC to conduct aerial photograph for land surveying and real estate on

June 9 , 2015. Thos e restrictions are listed below. Based upon the FAA’s recent guidance,
this petition is eligible for summary exemption and should be granted immediately.

MTIDA requests that the publication and comment procedures be waived in accordance

with 14 C.F.R. § 11.87 which states :

§ 11.87 : Are there circumstances in which FAA may decide not to publish a summary of
my petition for exemption?

The FAA may not publish a sum mary of your petition for exemption and request
comments if you present or we find good cause why we should not delay action on your
petition. The factors we consider in deciding not to request comment include:

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously.

(c) Whether our delaying action on your petition would affect you adversely.

2 Exemption 11326 to PPC Electric was for “aerial data collection” intended “ to conduct inspections of energy infrastructure, such as transmission and distribution lines and substations.”{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) (d) Whether you filed your petition in a timely manner.

Corresponding to the above sub

- sections, MTIDA has good cause to request the FAA to
waive the comment period and not delay action on the petition because:

(a) MTIDA would not set any precedent. MTIDA agrees to the SAME exact limitations as
Exemption # 11784

, including the type of aircraft.

(b) The relief requested is identical to that granted, without publication for comment, in
Exemption # 11 784 . The FAA has also issued grants of exception in circumstances
similar in all material respects to those presented in this petition in exemption #
11062 to Astraeus Aerial, 11109 to Clayco, Inc, 11112 to VDOS Global, LLC, and
11213 to Aeryon Labs, Inc.

(c) Delaying the granting of this petition would adversely affect the public, the FAA,

and MTIDA

. The public, as well as t he FAA, would be better served by the FAA
quickly granting this petition and thereby freeing up limited FAA resources and
allowing FAA inspectors to dedicate their time and attention to much higher
priorities. Moreover, MTIDA is adversely affected by the a bove listed regulations.
Finally, the enhanced safety achieved using an unmanned ai rcraft with the
specifications described in this petition and carrying no passengers or crew, rather
than a manned aircraft of significantly greater proportions, carrying c rew in addition
to flammable fuel, gives the FAA good cause to find that the UAS operation that
would be enabled by this exemption is in the public interest.

(d) The petition has been filed in a timely manner.

Petitioner’s contact info:

Bone, McAllester Norton, PLLC Attn: James Mackler Phone: 615

- 238

- 6312 Email: jmackler@bonelaw.com Address: 511 Union Street, Suite 1600, Nashville, Tennessee 37219{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) Middle Tennessee Industrial Development Association (MTIDA) Attn: Robert Bibb, Executive Director Phone: 615

- 269

- 5233 Email: rtbibb@mtida.org Address: 2108 Westwood Avenue , Nashville, Tennessee 37204

Regulations from which the exemption is requested:

• 14 C.F.R. § 61.23(a) and (c)

• 14 C.F.R. § 61.101(e)(4) and (5)

• 14 C.F.R. § 61.113(a)

• 14 C.F.R. § 61.315(a)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.119(c)

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)(1)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(1) & (2)

• 14 C.F.R. § 91.417(a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing
Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law directs
the Secretary of Transportation to consider whether certain unmanned aircraft systems may
operate safely in the national airspace system (NAS) before completion of the rulemaking
required under Section 332 of the FAA Modernization and Reform Act. In making this
determination, the Secretary is required to determine which types of UA 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 UA’s size, weight, speed, and operational capability;

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

• Operation of the UA within visual line of sight of the ope rator (VLOS). 3

3 FAA Modernization and Reform Act of 2012 at § 333(a).{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) If the Secretary determines that such vehicles "may operate safely in the national airspace
system, the Secretary shall establish requirements for the safe operation of such aircraft in the
national airspace system." Id. § 333(c) (emphasis added). 4

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.
This statutory authority by its terms includes exempting civil aircraft, as the term is defined

under § 40101 of the Act that includes UAS’s, from the requirement that all civil aircraft must

have a current airworthiness certificate.

“The Administrator may grant an exemption from a requirement of a regulation
prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of t his title if
the Administrator finds the exemption in the public interest.” 49 U.S.C. § 44701(f). See also 49

U.S.C. § 44711(b).

OPERATING DOCUMENTS

MTIDA will operate only within the limitations below and the performance parameters

set forth in the aircra ft manuals. MTIDA will provide the following proprietary technical

documents under separate cover:

• Flight Operations and Procedures Manual (FOPM).

• Aircraft Fligh t Manual (AFM) for the DJI Insp ire 1.

• Aircraft Flight Manual (AFM) for the DJI Phantom 3.

• Qualification Manual for the Pilot In Command.

• Qualification Manual for the Visual Observer.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein applies to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These limitations

4 Applicant interprets this provision to place the duty on the Administrator to not only process applications for

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that t he conditions set forth herein do not fulfill the statutory requirements for approval.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) provide for at least an equivalent or even higher level of safety to operations under the current
regulatory structure.

These limitations and conditions are identical to Exemption # 11784

. MTI DA agrees to
be bound when conducting commercial UA operations. The list of limitations and conditions
include the following:

1. Operations authorized by this grant of exe m ption are li m ited to the DJI aircraft listed
above when weighing less than 55 pounds including payload. Proposed operations of any

other a i r c ra f t will requi r e a new petition or a p e tition to a m end this e x e m ption.

2. Operations f or the purpose of closed

- set m otion picture and television filming are

not per m itt e d.

3. The UA m a y not be operated at a s p eed excee d ing 87 knots (100 m iles per hour). T h e

exe m ption holder m ay use either groundspeed or calibrated airspeed to deter m ine

co m pliance with the 87 knot speed restrict i on. In no case will the UA be operated at
airspeeds greater than t h e m ax i m u m UA operating airspeed recommended by the aircraft

m anufacturer.

4. The UA m u st be operated at an altitude of no m o re than 400 f eet above ground level

(AGL). Altitude m ust be reported in feet AGL.

5. The UA m u st be operated within visual line of sight (VLOS) of t h e PIC at all ti m es. This

req u ir e s the PIC to be able to u s e hu m an vision unaided by any device other than

correcti v e lenses, as specified on the PIC’s FAA

- issued air m an m edical certifi c ate o r U.S.

driver ’ s li c ense.

6. All oper a ti o ns m ust utilize a vis u al o bserver (VO). The UA must be op e rated within the

visual line of sight (VLOS) of the PIC and VO at all ti m es. The VO m ay be used to
satisfy the VLOS require m ent as long as the P IC always maintains VLOS capability.

The VO and PIC m ust be able to c o mmunicate verbally at all ti m es; ele c tronic
messaging o r texting is not per m itted d uring f lig h t operations. The PIC m ust be
designated before the flight and cannot transfer his or her designation for the duration of

the flight. T he PIC m ust ensure t h at the VO can perform the duties required of the VO.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 7. This exe m ption and all docu m ents needed to operate the UAS and conduct its
operations in accorda n ce with the conditions a n d li m itations stated in t h is grant of

exe m ption, are hereinafter referred to as the operating docu m ents. 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 outlined 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 documents. 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. The 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 FAA’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., replacement of a flight critical co mponent, 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 mus t 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 each 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 co m ponents, ite m s, or equip m ent. If the inspection reveals
a condition that affects the safe operation of the UAS, the aircraft is prohibited from{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 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 manufacturer’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 Columbia, Puerto Rico, a territo ry, a possession, or the Federal government. The
PIC must also meet the flight review 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 operate unless t he 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, vehicles and str uctures. 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 VOs
(training, proficiency, and experience

- building) and determining 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 sessions. During
training, 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 o perations 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.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 16. The UA m a y not operate within 5 nautical m iles of an airport refere n ce p oint (ARP) a s

denoted in the current F AA Airport/Faci l ity Directory (AFD) or for airports not denoted

with an ARP, the center of the airport sy m bol as denoted on the current

FAA

- published aerona u tic a l ch a rt, u nless a letter of agree m ent with t h at airpo r t’s

m anage m ent is obt a i ned or otherwise per m itted b y a COA issued to the e xe m ption

holder. The letter of agree m ent with the a i rport m anage m ent must be m ade available to

the Ad m i nistrator or any law enforce m ent official upon request.

17. The UA m a y 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 m iles from the PIC.

18. If the UAS loses com m unications or loses its GPS signal, the UA m ust return to a

pre

- deter m ined location within t h e p rivate or co n t rolled

- acce s s property.

19. The PIC m u st abort the f light in the event of unpredicted obstacles or e m ergencies.

20. The PIC is prohibited fr o m beginning a flight unless (con s idering 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 m anufacturer if greater.

21. Air Traffic Organizati o n (ATO) Certificate of Waiver or A utho r ization (COA). All
operations shall be conducted in accord a nce with an ATO

- issued COA. The

exe m ption holder m ay apply for a new or a m ended COA if it intends to conduct
operations that cannot be conducted under the ter m s of the attached COA.

22. All aircraft operated in accor d a n ce with this exemption m ust be identified by serial

nu m ber, registered in accordance with 14 CFR p a rt 47, and have identification

( N

− Nu m ber) m arkings in accorda n ce with 14 CFR part 45, Subpart C. Markings m ust be

as large as practica b le.

23. Docu m ents used by the operator to ensure t h e safe operation and flight of the UAS and

any docu m e nts required under 14 CFR §§ 91.9 and 91.203 m u st be available to the PIC

at the G round Control Station of the UAS any ti m e the aircraft is operating. These

doc u m ents m ust be m ade availa b l e to the Ad m i nistrator or any law enforcement official

upon request.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 24. The UA m u st re m ain clear and give w a y to all m anned aviation operations and acti v ities

a t all ti m es.

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

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

a. Barriers or structures are present that sufficiently p r otect nonparticipating persons

from the UA and/or de b ris in the eve n t of an acci d ent. The o p erat o r m ust ensure

that nonparticipating persons re m ain under s u ch protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operatio n s m ust cease im m ediately in a m anner ensuring the safety
of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struc t ures has granted per m ission
for operating closer to those objects and the PIC has m ade a safety assess m ent of

the risk of operating closer to those objects and deter m ined that it does not

present an u ndue hazard.

c. The PIC, VO, operator trainees or e s sential pers o ns are not c o nsidered
nonparticipating persons under this exe m ption.

27. All operati o ns shall b e conducted o v er pri v ate o r contr o lle d

- access pro p erty with

per m ission from the property owner/contr o ller or authorized representative. Per m ission

from property owner/co n t roller o r authorized rep r esent a tive w ill b e obtained for each
flight to be conducted.

28. Any incident, accident, or flight operation that tr a nsgress e s t h e later a l or v ertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA ' s UAS Integration O ff i ce (AF S

− 80) within 24 hours. Accidents m ust be
reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: w ww.ntsb.gov

.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) STATUTORY CRITERIA PROVIDED IN SECTION 333

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 requirement for an airworthiness certificate, upon
consideration of the size, weight, speed, operational capability, and proximity to airports and
populated are as of the particular UAS. In all cases, an analysis of these criteria demonstrates that
the UAS operated without an airworthiness certificate and under the restrictions proposed will be
at least as safe, or safer, than a conventional aircraft (fixed wing o r rotorcraft) operating with an
airworthiness certificate without the restrictions and conditions proposed.

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an
onboard pilot, there is no ability or place to carry certification and registration documents or to
display them on the unmanned aircraft. An equivalent level of safety will be achieved by keeping
these documents at the ground control point where the pilot flying the UA will have immediate

access to them. Given the size o f the unmanned aircraft, the FAA registration number will be
displayed on the airframe in as large a font as possible.

14 C.F.R. § 61.23(a) & (c): M EDICAL C ERTIFICATES

Exemption # 11221, # 11284, #11326 and many others have provided that a U.S.

driver’s li cense could be used in lieu of the medical certificate.

14 C.F.R. § 61.101( e )(4) & (5): R ECREATIONAL P ILOT P RIVILEGES AND L IMITATIONS & 14

C.F.R. § 61.315( a ): S PORT P ILOT L IMITATIONS

.

Exemption # 11221, # 11284, #11326 and many others have provided that the “PIC
must hold either an airline transport, commercial, private, recreational, or sport pilot

certificate.” Likewise, MTIDA is also performing commercial UAS work and is asking for

the same restrictions which have be en previously deemed to provide an equivalent level of
safety as the burdensome regulations.{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) 14 C.F.R. § 61.113 (a): P RIVATE P ILOT P RIVILEGES A ND L IMITATIONS : P ILOT I N

C OMMAND

.

Sub

- sections 61.113(a) limit private pilots to non

- commercial operations. Beca use the
UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent
level of safety of current operations by requiring the PIC operating the aircraft to have a
private pilot's license rather than a commercial pilot's licens e to operate this small UAS.
Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely
controlled with no living thing on board.

14 C.F.R. § 91.7( a ): C IVIL A IRCRAFT A IRWORTHINESS

.

The Phantom 2 and DJI Inspire 1 have been previously approved in many past

e xemption s, including # 11784

. The Phantom 3 was approved in exemption # 11696.

14 C.F.R. § 91.119: M INIMUM S AFE A LTITUDES

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119
(d) allows helicopters to be operated at less than the minimums prescribed, provided the
person operating the helicopter complies with any route or altitudes prescrib ed for helicopters
by the FAA.

Because of the lack of flammable fuel, any risk associated with these operations is
far less than those presently presented with conventional aircraft operating at or below 500

AGL. In addition, the low

- altitude operations of the UAS will ensure separation between
these small UAS operations and the operations of conventional aircraft that must comply

with Section 91.119.

14 C.F.R. § 91.121: A LTIMETER S ETTINGS

This regulation requires each person operating an aircraft to main tain cruising altitude by
reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) altimeter setting available before departure." As the UAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety
will be achieved by the operator, pursuant to the operating manuals.

14 C.F.R. § 91.151( a ): F UEL R EQUIREMENTS FOR F LIGHT IN VFR C ONDITIONS

Section 91.151 (a) prohibits an individual from beginn ing "a flight in an airplane under
VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel
to fly to the first point of intended landing, and, assuming normal cruising speed

- (1) During the
day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes."

Applicant believes that an equivalent level of safety can be achieved by prohibiting the
PIC from beginning a UAS flight unless (considering wind and forecast weather conditi ons and
assuming normal cruising speed) “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.” Exemption # 11 326 , at page 5.

14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): M AINTENANCE

I NSPECTIONS

These regulations require that an aircraft operator 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" 5 and others shall inspect or maintain the aircraft in compliance with Part 43. Given

that the se sections and Part 43 apply only to aircraft with an airworthiness certificate, these
sections will not apply to the applicant. An equivalent level of safety will be achieved because
these small UAS’s are very limited in size and will carry a small paylo ad and operate only in
restricted areas for limited periods of time. Moreover, the operator is the person most familiar
with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

5 14 C.F.R. § 91.405(a).{01247671.1 }
Nashville City Center, Suite 1600

- 511 Union Street

- Nashville, Tennessee 37219

615.238.6300 (phone)

- 615.238.6301 (fax) equivalent level of safety. Lastly, the petitioner will operate in accordance with the manuals
submitted confidentially which will provide an equivalent level of safety as the burdensome
regulations.

CONCLUSION:

The operation of MTIDA using a small UAS, weighing less than 55 lbs., conducted under
the proposed restrictions outlined above, will provide an equivalent level of safety supporting the
grant of the exemptions requested herein.

If I can be of any assistance to further expedite this petition, please do not hesitate to

contact me at (615) 238

- 6312 or at my email jmackler@bonelaw.com.

Sincerely yours,

____________________ James E Mackler, Esq.