### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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May 21 , 2015 U.S. Departm ent of Transportation Docket Managem ent System 1200 New

Jersey Avenue SE Wa shington, D.C. 20590 **Subject Matter:** Exem ption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal Aviation Regulations from ; 14 CFR 61.113 (a) 

### & (b); 91.7 (a); 91.119 (c); 91.121; 91.151 ( a)(1); 91.405 (a); 91.407(a) (1 ); 91.409 (a) (2); 91.417 (a) 

### & (b). **To whom it may**

**concern:** In accordance with Section 333 of the Federal Aviation Adm inistration (FAA) Mode rnization and Reform Act of 2012, JOSA Industries, LLC respectfully petitions the Secretary of Transportation and the Federal Aviation Adm inistration for an exem ption of the above mentioned Federal Aviation Regulations, for the purpose of business operatio ns of small

- unm anned aerial system s (UAS). Furtherm ore, the details of this petition will describe in a m ore detail the m anner in w hich JOSA Industries, LLC is seeking the exem ption request. **A. Summary of the Petition** JOSA Industries, LLC form ally requests exem ption from the following Federal Aviation Regulations (FARs) that are found under Title 14 of the Code of Federal Regulations (CFR): 14 CFR 61.113 (a) 

### & (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a)(1); 91.405 (a); 91.407(a) (1 ); 91 .409 (a) (2); 91.417 (a) 

### & (b). JOSA Industries, LLC seeks approval and exem ption from the above listed CFRs to operate the DJI Phantom 2 Vision+ for the purpose of providing high resolution aerial im agery for com pensation/hire to companies and individuals . The operation of the DJI Phantom 2 Vision+ by JOSA Industries, LLC will abide by all m anufacturer approved operation lim itations, Advisory Circular 91

- 57, other limitations stated in this docum ent, and all recommendations by the FAA and other governm ent agencies. **B. Petition for Exemption** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, JOSA Industries, LLC , operator of small unm anned aerial systems, conducting aerial photography/ aerial inspection for business purposes over the following areas; (1) over land, waterways, and oceans; (2) operation over and/or in non

- restricted National Parks, National Forests, and non

- navigable airspace using nonintrusive recording devices; and (3) operation in otherwise unrestricted U.S. States and Territories. All proposed operations would be conducted under controlled conditions in airspace that is: (1) lim ited, (2) predetermined, and (3) access controlled. Aviation using comm ercial grade photography/ rem ote sensing im aging devices, is formally requesting for exem ption to the above m entioned Federal Aviation Regulations for commercial operation of its unm anned aerial system in accordance with lim itations described within this docum ent or as established by the Federal Aviation Adm inistration required by Section 333. JOSA Industries, LLC is requesting exem ption that would allow the operation of their UAS for aerial photography and inspection lim ited, predeterm ined and access controlled airspace. The use of aerial photog raphy by small unm anned aerial system s/vehicles will im prove aviation safety by reducing the hazard of low flying m anned aerial photography in traditional sm all aircraft as well as increase the capacity of National Airspace System by allowing aerial photog raphy to be conducted without utilization of lim ited airport/airspace resources.

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- 7611 If the exem ption is approved, JOSA Industries, LLC would enhance safety and m eet the requirem ent of the Secretary of Transportations responsibilities described in Section 333(c) of the FAA Modernization and Reform Act of 2012. **C. Name and A ddress of the Petitioner**  JOSA Industries, LLC Attn: Jorge Sosa Ph one : 337

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- 7611 Em ail: aerials@josaindustries.com Address: 163 Rue du Belier Apt 104 Lafayette LA 70506 **D. Petitioner Petitions for Exemption of the Following Regulations** 1 4 C F R 9 1

. 4 0 5 ( a ) 1 4 C

. F

. R

. 9 1

. 1 1 9 ( c ) 1 4 C F R 4 0 7 ( a ) ( 1 ) 1 4 C F R 6 1

. 1 1 3 ( a ) & ( b ) 1 4 C

. F

. R

. 9 1

. 1 2 1 1 4 C F R 4 0 9 ( a ) ( 2 ) 1 4 C

. F

. R

. 9 1

. 7 ( a ) 1 4 C F R 9 1

. 1 5 1 ( a ) 1 4 C F R 4 1 7 ( a ) & ( b ) JOSA Industries, LLC operates unm anned aerial system s that are multi

- rotorcraft equipped with precision flight and stab le hovering, radar positioning, return hom e, onscreen real

-tim e flight param eters, on

- board NAZA computer stabilization controller and GPS, the UAS w ill weigh less than 55 lbs. or less and most typically include cam era/payload. Norm al UAS operations are co nducted at speeds well below 100 KIAS utilizing the functions of rotorcraft; it has the ability to hover. JOSA Industries, LLC will only operate in line of sight and will operate in airspace described in this docum ent or as specified by the FAA. All UAS op erations will be vetted by JOSA Industries, LLC operator/ qualified personnel to confirm that there are no hazards to users of the National Airspace System or innocent bystanders or general public. **E. How the request benefits the public as a whole** JOSA Industries, LLC believes that the safe, limited, and controlled operations of its unmanned aerial systems (UAS) described in this docum ent will m eet and exceed the strict safety and security standards of the FAA and/or national security issues. Moreover, J OSA Industries, LLC believes that the utilization of UAS described in this docum ent w ill benefit the public as a whole in five ways; 1) JOSA Industries, LLC continued commitment to keep the highest level of safety during its UAS operations and set industry standards for safe UAS operations for future operators 2) Reduce the risk to life and property 3) Reducing National Airspace System (NAS) congestion through utilization of small (less than 55lbs.) UAS instead of conventional aircraft during aerial photography/ inspection operations. 4) Reducing noise and air pollution created by conventional fixed wing/rotor w ing aircraft, and 5) Increase aerial photography/inspection industry econom ic growth. JOSA Industries, LLC utilization of UAS (DJI Phantom 2 V ision +) for the purposes of aerial photography/ inspection w ill be a leader in using and setting industry best practices for safe UAS operations in the NAS. Additionally, utilization of UAS will reduce the risk to life and property by lim iting the use of conventional aircraft such as fixed

-wing and rotor

-wing aircraft w ith weights in excess of 1000lbs and carrying hundreds of gallons of flammable fuels flying at low altitudes. The

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- 7611 UAS described in th is docum ent is less than 55 lbs. carries a sm all battery as a power source and can effectively do the sam e job as conventional aircraft with reduced likelihood and severity of risk. Moreover, the utilization of UAS will reduce UAS congestion by reduced usage of conventional aircraft requiring access to UAS. An a dditional benefit will be reductions in noise and air pollution fro m conventional aircraft by utilization of sm all UAS using batteries as the m ain source of power instead of fossil fuels used by conventional aircraft. Finally, the utilization of UAS for ae rial photography/ inspection w ill allow for positive econom ic growth in the aerial photography/ inspection industry, as well as peripheral industries that rely on aerial photography/ inspection, i.e., building construction, real estate, and inspection serv ices. **F. Limitations and Conditions** JOSA Industries, LLC will describe in this document the proposed lim itations and conditions of its UAS operations. These operations and conditions are intended to provide safe operations up and beyond current regulatory framework that apply to sim ilar operations. Moreover, th e lim itations and conditions described below JOSA Industries, LLC wi ll accept to be held accountable when conducting business/commercial UAS operations from the FAA issued exem ption: 1. The UAS maxim um take

- off weight (MTOW ) will be less than 55 lbs. JOS A Industries, LLC : I. DJI Phan tom DJI Phantom 2 Vision + II. Other DJI manufactured UAS 2. The pilot in command (PIC) of the UAS w ill possess at least a JOSA Industries, LLC training session, which includes and not lim ited to ground station, UAS operation, em ergency procedure, maintenance tracking and pre

-flight checklist. 3. Operator PIC qualifications criteria and dem onstrated ability to operate UAS I. Com pleted initial a nd or recurrent training prior to UAS operations. Follow training guidance in accordance with m anufacturer. II. All training will be docum ented and recorded III. PIC will dem onstrate evasive and em ergency m aneuvers IV. Maintaining appropriate distances fro m persons, vessels, vehicles, and structures as per FAA regulations V. PIC qualification flight hours will be logged in a m anner consistent with 14 CFR 61.51. 4. The Visual Observer (VO) qualifications and dem onstrated ability I. Com pleted initial t raining prior to UAS operations II. All training will be docum ented and recorded 5. Training operations for PIC and VO (training, proficiency, and experience building) will only be conducted during dedicated training sessions. During training, proficien cy, and experience building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UAS w ith appropriate distance from nonparticipants in accordance with 14 CFR 91.119. 6. All UAS operatio ns will rem ain below 400 feet above ground level. UAS operations will utilize no less than two qualified people. The first person will be operator of the UAS flight controls “pilot in command” (PIC). The second person, visual observer (VO), w ill be used to assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and will not perm itted to operate the UAS cam era or other instrum ents. 7. The UAS will be operated within the line of sight (LOS) of the PIC at al l tim es. The PIC will be able to use hum an vision unaided by any device other than corrective lenses. The PIC will have an

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- issued airm an m edial certificate. First person view (FPV) w ill not be used by the PIC or visual observer (VO). The UAS will not b e operated by the PIC from any m oving device or vehicle. UAS operations will not be perm itted unless there is enough power to fly to the UAS to the intended landing point at a norm al cruise speed and land the UAS w ith 30% battery power rem aining. 9. The PIC will be designated before flight and will not transfer controls for the duration of flight. The PIC will ensure that the VO can perform all of their essential functions. All operations will utilize a VO. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not perm itted to operate the cam era or other instrum ents. The UAS will rem ain clear and yield the right of way to all manned aviation o perations at all tim es 10. Pre

-flight operati ons w ill include the use of a Preflight Checklist as stated by DJI . Additionally, prior to each flight the PIC will conduct and preflight inspection of the UAS and Ground Control Station to ensure it’s in a co ndition for safe flight. All discrepancies found during the preflight inspection will prohibit flight operations until the necessary m aintenance has been perform ed and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, a lterations w ill be properly docum ented in the aircraft records. 11. If the UAS has undergone m aintenance or alterations that affect the UAS operation or flight characteristics there will be a functional flight test by the PIC and the PIC will m ake and en try in the aircraft records. All m aintenance will follow the UAS m anufacturer’s aircraft/component, maintenance, overhaul, replacem ent, inspection, and life lim ited requirements. 12. Each UAS w ill com ply with all m anufacturers Safety Bulletins. 13. The operator will carry out its m aintenance, inspections, and record keeping requirem ents, in accordance with the m anufacturers operating docum ents. All Maintenance, inspection, alterations, and status of replacem ent/overhaul com ponent parts m ust be noted in the aircraft records, including total tim e in service, description of work accom plished, and the signature of the authorized person returning the UAS to service. 14. Authorized persons will m ake entry in the aircraft record of corrective action taken aga inst discrepancies discovered between inspections. 15. The UAS w ill not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreem ent with that airport’s managem ent is obtained, and the operation is conducted in accordance w ith a NOTAM as required by the operator’s Certificate of W aiver. All UAS operations will not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles fro m the PIC. Controlled airspace will be utilized with prior perm ission from Air Traffic Control or the Federal Aviation Administration. At all tim es, in all situations, without exception, the PIC will maintain visual line of si ght w ith the UAS. 16. The UAS w ill not be operated over congested or densely populated areas. 17. The UAS w ill rem ain clear and yield the right of way to all m anned aviation operations at all tim es. The UAS will not be flow n at an indicated airspeed exceeding 30 knots. 18. All operating documents w ill be accessible during UAS operations. JOSA Industries, LLC may update or revise operating docum ents, however; it w ill track revisions and present updated revised docum ents the adm inistrator upon request.

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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19. All docum ents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any tim e the UAS is operating. These docum ents w ill be m ade available to the Adm inistrator or any law enforcem ent official upon request. 20. Prior to all UAS flight operations, the pilot in command w ill conduct a visual inspection of the property and attem pt to inform all persons on the property of the UAS operations. Flight operation will be 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: I. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons rem ain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease imm ediately and/or; II. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted perm ission and the PIC has m ade a safety assessm ent of the risk of operating closer to those objects and determ ined that it does not present an undue hazard, and; III. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 21. The PIC of the UAS and VO involved with each UAS fligh t operation w ill have received initial training, and recurrent training on a periodic basis to keep up

-to

- date on, applicable governm ent regulations, airspace regulations, m anufacturer updates, and other inform ation regarding UAS operations in the NAS. 22. The PIC and VO will be able to verbally communicate at all tim es. Electronic m essaging or texting will not be perm itted during flight operations. 23. If the UAS loses communications or loses its GPS signal, it will return to a pre

- determ ined location with the planned operating area and land or be recovered in accordance with the operating docum ents. 24. The PIC will abort the flight in the event of unpredicted obstacles or em ergencies 25. The visual observer will carry and utilize fire extinguishi ng equipm ent in case of an em ergency. 26. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual m eteorological conditions (VMC). Flights under special visual flight rules (SVFR) are n ot authorized. 27. UAS operations will be identified by serial num ber, registered in accordance with 14 CFR part 47, and identification (N

- Num ber) marking in accordance with 14 CFR part 45, Subpart C. The markings w ill be a large as practical. 28. UAS operations, if required by controlled airspace, will request a Notice to Airm an (NOTAM) no more than 72 hours in advance, but not less than 48 hours prior to the operation. 29. All UAS operations will com ply w ith Federal Communications Commission or othe r appropriate governm ent oversight agency requirem ents

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- 7611 30. All operations shall be conducted over private or controlled

- access property with perm ission fro m the land owner/controller or authorized representative. Perm ission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov. 32. Unless otherwise specified the UAS, the UAS PIC, and the UAS operations will com ply with all applicable parts of 14 CFR includin g, but not limited to, parts 45, 47, 61, and 91. **G. Specific Sections of 14 CFR from which JOSA**  **Industries, LLC Seeks Exemption**  **14 C.F.R. § 61.113** (a) 

### & **(b): Private Pilot Privileges and Limitations: Pilot in Command** 

**.** The proposed UAS operations by JOS A Industries, LLC would employ All UAS Pilot in Commands ( PICs ) to go through a JOSA Industries, LLC ground school and flight lessons in accordance with manufactures and industry guida nce prior to operations. All JOSA Industries, LLC PIC’s will only operate the UAS as stated in this document and/or as recommended by the FAA. All JOSA Industries, LLC UAS operations will be controlled and limited, all flights will be coordinated ahead of time. JOSA Industries, LLC fe els that the level of safety will be equivalent or in excess that of a commercial pilot operations. JOSA Industries, LLC objective is to safety operate UAS in a controlled manner at a reduced risk level that would not require a commercial pilot certificate. **14 C.F.R. §91.7(a ): Civil aircraft airworthiness.**  JOSA Industries, LLC would like to request and exemption to operate their UAS without an airworthiness certificate. Instead, JOSA Industries, LLC will verify the airworthiness of the UAS prior to each flight to ensure that the UAS is airworthy prior to each and every flight. All record keeping of maintenance actions will be documented in the same man ner as a conventional aircraft. In order to meet or exceed level of safety as described in 14 C.F.R. §91.7(a ). JOSA Industries , LLC operations will include: Pre

-flight operations prior to each flight the PIC will conduct and preflight inspection of the UAS and Ground Control Station to ensure it’s in a condition for safe flight. All discrepancies found during the preflight inspe ction will prohibit flight operations until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, alterations will be properly documented in the aircraft records. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the aircraft records. All maintenance will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limited requirements. Each UAS will comply with all manufacturers Safety Bulletins. The operator will carry out its maintenance, inspections, and record keeping requirements, in accordance with the manufacturers operating documents. All Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, a nd the signature of the authorized person returning the UAS to service. Authorized persons will make entry in the aircraft record of corrective action taken against discrepancies discovered between inspections.

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- 7611 **14 C.F.R. §91.119 (c): Minimum safe altitu des**  JOSA Industries, LLC would like to request an exemption to 91.119 paragraph (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure

. All flights will be conducted with within visual line of sight and with prior perm ission from the owner of the property or local municipality. Additionally, all persons, vessels, vehicles, not directly involved with the operation will be notified and cleared of the area w here the proposed UAS operations will be conducted. The advance notice and access restricted area will m aintain an equivalent level of safety of that described in 14 C.F.R. §91.119 (c): Minim um safe altitudes. **14 C.F.R. §91.121 A ltimeter Settings**  JOSA Industries, LLC is requesting an exem ption from 14 CFR 91.121 requiring each person operating an aircraft shall m aintain the cruising altitude by reference to an altim eter that is se when operating below

18,000 feet m ean sea level to the elevation of the departure airport or an appropriate altim eter setting available before departure. To m eet the equivalent level of safety, the UAS operated by JOSA Industries, LLC has GPS altitude readout instead of a barom etric altimeter. The JOSA Industries, LLC qualified PIC w ill main tain the equivalent level of safety by confirming the altitude of the launch site shown on the GPS altitude indicator prior to each flight. The operating docum ents w ill require confirm ation of the launching site altitude on the UAS GPS altitude indicator b efore each flight. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** JOSA Industries, LLC believes that an equivalent level of safety can be achieved by following the UAS m anufacturer’s operating docum ents with regard to battery voltage. In order to achieve or exceed the level of safety, the JOSA Industries, LLC PIC w ill not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the intended landing point at norm al cruising speed and l and the UAS with no less than 30% of battery power. **14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) &**  **(b): Maintenance Inspections** JOSA Industries, LLC UAS operations will keep an equivalent level of safety as described below. JOSA Industries, L LC will perform preventative and required m aintenance on its UAS as required by the m anufacturer and/or FAA safety/service bulletins. If a mechanical event occurs the UAS will land immediately. The operator will m ake sure that the UAS is in an airworthy co ndition prior to each flight operation. The operator will perform m aintenance on its UAS and will m aintain thorough record keeping of any maintenance perform ed. In order to meet or exceed level of safety as described in 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b). JOSA Industries, LLC operations will include: Pre

-flight operations: prior to each flight the PIC w ill conduct and preflight inspection of the UAS and Ground Control Station to ensure it’s in a condition for safe flight. All discrepancies found during the preflight inspection will prohibit flight operations until the necessary m aintenance has been perform ed and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, alterations w ill be properly documented in the aircraft records. If the UAS has undergone m aintenance or a lterations that affect the UAS operation or flight characteristics there will be a functional flight test by the PIC and the PIC will m ake and entry in the aircraft records. All m aintenance will follow the UAS m anufacturer’s aircraft/component, maintenance , overhaul, replacem ent, inspection, and life lim ited requirements. Each UAS w ill com ply with all m anufacturers Safety Bulletins. The operator will carry out its maintenance, inspections, and record keeping requirem ents, in accordance with the m anufacturers operating docum ents. All Maintenance, inspection, alterations, and status of replacem ent/overhaul com ponent parts m ust be noted in the aircraft records, including total tim e in service, description of work accom plished, and the signature of the authori zed person returning the UAS to service.

### JOSA	Industries **,	LLC_**

**_______________________________________________________________________** 1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)

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- 7611 Authorized persons will make entry in the aircraft record of corrective action taken against discrepancies discovered between inspections. **H. Publication Summary** The following summ ary is provided for publi cation in the Federal Register. Pursuant w ith Section 333 of the FAA Modernization and Reform Act of 2012, JOSA Industries, LLC requests an exem ption from the following rules: 14 CFR 61.113 (a) 

### & (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a)(1); 91.405 (a); 91. 407(a) (1); 91.409 (a) (2); 91.417 (a) 

### & (b). Exem ption from these regulations will allow JOSA Industries, LLC ` to operate comm ercially a UAS, DJI Phantom 2 Vision+ (55lbs or less), for Aerial Photography/ Inspection Operations. If approval of the exempti on is granted, JOSA Industries, LLC would conduct commercial operations of the approved UAS for aerial photography/inspection for business operations over land, water

-ways, and oceans; operation over/in non - restricted National Parks, National Forests, flight in non

- navigable airspace, using non

- intrusive recording devices, operation in otherwise unrestricted US States/Territories. The use of UAS of less than 55 lbs

. with power source is a safer and more econom ical m ec hanism than utilization of conventional aircraft. JOSA Industries, LLC proposed commercial operations of UAS would be conducted under controlled conditions in airspace that is: lim ited, predeterm ined, and access controlled