### ZutKERT ScouTT RASENBERGER

MALCOLM L. BENGE

BYHAND U.S. DepartmentofTransportation Docket Management Facility West Building Ground Floor Room W12-140 1200 NewJerseyAvenue, S.E. Washington, D.C. 20590 August 26, 2014 888 Seventeenth StreetNW, Suite700 Washington,DC 20006-3304 Phone 202.298.8660 Fax 202.342.0683

www.zsrlaw.com

DIRECTDIAL(202) 973-7904 mlbenge@zsrlaw.com

:. .,



### Re: Petition ofOceaneering International, Inc. for Exemption Pursuantto 14C.F.R. Part 11, Oceaneering International, Inc. ("01" or "Petitioner") hereby applies for an exemption in orderto conduct commercial use operations with the Wookong DJI 5800 and AeronavicsX4 Titanium unmanned aerial systems ("UAS"). In accordance with the requirements ofthe Federal Aviation Administration ("FAA"), Petitioner's UAS operations have been designed to achieve a level ofsafety equivalentto that provided by the FAA regulations from which an exemption is requested. In support ofits exemption request, 01 provides the following information. 

### Petitioner Established over50 years ago, 01 has a long history ofdeep-sea safety and inspection operations using remotely-piloted vehicles. These operations have largely been conducted in support ofthe offshore oil and gas industry, with afocus on deepwaterapplications. Ol's operations have included drilling platform inspections, construction ofdeep-sea hardware and distribution systems, the installation ofsub-sea blow-out prevention devices, Navy submarine rescue and recompression systems, and full service ship repairforthe U.S. Government including submarines. Through these activities, 01 has accumulated substantial expertise in the safe and reliable operation of underwater remotely-piloted vehicles for commercial applications. 01 is now proposingto expand its operation of remotely-piloted devices to include the commercial use ofsmall UAS aircraftforvarious aerial inspection and surveying purposes. 

### Proposed Commercial Uses 01 proposes to use the Wookong DJI 5800 and Aeronavics X4 Titanium small UAS aircraftfor multiple commercial applications, including safety inspections and aerial surveying ofthefollowing remote ordifficult-to-accessfacilities:

Zuckert, Scoutt & Rasenberger, L.L.P.ZucKERT ScouTT RASENBERGER

• Oil and Gas platforms • Flare booms/stacks- both onshore and offshore • Refineries and processing stations • Pipelines • Power lines • Bridges and infrastructure including rail bridges • Wind turbines • Solarfarms. August 26, 2014 Page 2

01 also envisions UAS operations in support ofemergency response activities on behalfofthe National Transportation Safety Board, the Department ofthe Interior's Bureau ofSafety and Environmental Enforcement, the U.S. Coast Guard, and any otherfederal orstate government agency which may require its services and personnel. All ofOl's proposed UAS operations are intended to facilitate safety inspections and aerial surveying in areas where the performance ofthose functions using current methods involves considerable expense and/ora substantial risk of injury. Many ofthese functions must be performed in hazardous environments. Others may be performed much more efficiently by an unmanned aircraft with the abilityto hoverand capture images at close range. The commercial UAS applications which 01 proposes will therefore result in a significant enhancement ofsafety, by reducing the risks associated with current inspection methods and enhancing current inspection techniques. Proposed UAS Aircraft 01 plans to conduct commercial UAS operations with the Wookong DJI S800 aircraft and Aeronavics X4 Titanium. The DJI S800 is a small UAS with a maximum takeoffweight of 15.41bs. The X4 Titanium is a small UAS with a maximum takeoffweight of28.6 lbs. At all timeswhile conducting commercial operations, 01 will operatethe DJI S800 and Aeronavics X4 Titanium under line-of-sight conditions with a hands-on control system, i.e., dual gimbals, in response to commands from an 01 employee with specialized flighttraining; neither aircraft will perform commercial operations autonomously or in accordance with a pre-programmed flight plan. The DJI S800 has six batterypowered motors and the Aeronavics X4 has eight. Ifone ofthe motors on eitheraircraft experiences a powerfailure, the DJI S800 and the Aeronavics X4 will hover in place, orbiting around the motorthat has failed. In the eventthatthe signal between the control system and the DJI S800 orthe Aeronavics X4 Titanium is lost or disrupted, both aircraft are designed to hoverfor approximately 5 seconds attemptingto regain the data link. Ifthe UAS is equipped with a GPS communication system and is unable to re-establish contact with the control station, it will rely on an auto-pilotfeature that returns the UAS aircraftto the home pointvia the original flight path from the launch point. This will eliminate "fly-away" incidents and otherflight deviationsthat are known to occurwith othertypes of UAS aircraft. Both the S800 and the X4 have been used extensively in Europe and the United Kingdom for commercial cinematography and surveywork due to both platforms being stable and simple to operate. During the past Winter Olympics, the X4 was the primary system used forfilming most ofthe eventsZucKERT ScouTT RASENBERGER August 26, 2014 Page 3

from the air. Both systems have substantial commercial operating experience outside the U.S. and are known for being rugged with a history of reliability in flight. Operating Conditions 01 will conduct commercial operations with the DJI 5800 and Aeronavics X4 Titanium only in accordance with a highly-detailed set ofsafeguards governing all phases offlight operations. 01 employees responsible for UAS operations will always place a priority upon minimizing risk to personnel, equipment, assets and the environment. To ensure the highest level ofsafety, UAS flight operations will only be conducted after an extensive safety briefing (including 01 and customer personnel) and a risk analysis have been conducted. All UAS flights operated by 01 will be conducted by a minimum ofthree operational personnel, including asystem supervisor. No flights may be initiated unless a preflight checklist has been completed and signed by all those 01 employees performingthe checks. The checklist procedure includes a detailed inspection ofthe DJI 5800 and Aeronavics X4 Titanium priorto the initiation ofany operations. Attached as Exhibit A to this exemption petition is a copy ofOl's pre- and post-flight checklist. 1Any UAS operationsto be conducted at an altitude of less than ten feet require the prior approval of01 supervisory personnel. Most importantlyfrom a safety perspective, operations directly overhead 01 and customer personnel are not permitted as the UAS aircraft must be operated at all times at no more than a 30 degree obliqueto any personnel. There are several additional mandates that 01 employees must observe in connection with all commercial operations with the DJI 5800 and Aeronavics X4 Titanium, including the following:

• No flights through an established Air Defense Identification Zone (ADIZ) • UAS flights shall not exceed 400 feet above ground or above the sea level per FAA Advisory Circular 91-57 • All flights will be conducted in Class Gairspace • All flights will be conducted within line-of-sightof UAS operator • All flights will be conducted in accordance with Class Gairspace visibility requirements • Wind speed shall not exceed 25 knots • UAS operations will be conducted during daylight hours • A NoticetoAirmen {NOTAM) will be filed with the FAA priorto each UAS operation • All 01 crews will have an air-air radio system for communication with lowflying airtraffic in the area surrounding UAS operations (programmed with 123.025 common Air-Air Frequency, and the local frequencyforthe area ofoperation) • All 01 crews will have an up to date HelicopterSafetyAdvisory Conference Air Frequency card

1 All exhibitstothis exemption petition are submitted to the FAA with a requestfor confidential

treatment as they constitute commercially-sensitive proprietary data.ZucKERT ScouTT RASENBERGER August 26, 2014 Page 4

At no point in time will Ol's UAS aircraft be allowed to share airspace with commercial aircraft. Priorto conducting operations within three miles from any airport runway, 01 will notifythe airport operatoror the airporttower, as the case may be, in compliance with FAA Advisory Circular 91-57. 01 employees are instructed to terminate any UAS operations when an approaching commercial aircraft is within five nautical miles.
As Exhibit Bto this exemption petition, 01 is submitting a copy of its 

### General Procedurefor the Operation of RAVSystems. Operator Requirements Ol's commercial UAS operations will build on its years ofexperience as an underwateroperator of remotely-piloted vehicles. Only 01 employees who have undergone and successfully completed a rigorous competency assessment evaluation will be selected to operate the DJI S800 and Aeronavics X4 Titanium.2 Operators must demonstrate not only a superior knowledge ofthe technical issues · associated with UAS systems, including the full range ofthe capabilities and limitations ofthe DJI S800 and Aeronavics X4 aircraft, but also must show sound pilotingtechniques and the abilityto navigate around structures. In orderto retain their status, 01 employees conducting UAS commercial operations must enforce compliance with the company's policy of "working underthe more stringent rule." Some ofthe 01 employees selected to be operators ofthe DJI S800 and Aeronavies X4 have previous significant experience as the operators of undersea remotely-piloted vehicles. In additionto their other qualifications, 01 employees who operatethe DJI S800 and Aeronavics X4 will undergo an extensive program ofsimulatortraining as well as hands on flighttraining in a simulated inspection environment. Simulatortraining will allowthese employees to gain experience with the specificflight characteristics ofthe DJI S800 and Aeronavies X4 priorto any actual commercial operations.
The following requirements will apply to anycommercial UAS operations conducted by 01:

• A pilot-in-command (PIC) will be designated at all times for each flight • The PIC will be directly responsible for, and have final authorityoverthe operation of the UAS • The PIC will not perform concurrent duties as the visual observer • The PIC will be qualified on the DJI 5800 aircraft and Aeronavics X4 Titanium • The PIC will exercise control overthe UAS as itwill not maneuver autonomously. Given their experience with remotely-piloted vehicles, the amount of required simulator training, and the operational procedures applicable to 01 employees operatingthe DJI 5800 and Aeronavics X4 Titanium for commercial purposes, 01 PICs should not be required to hold an FAA pilot

2 A copy ofOl's CompetencyAssessment Scheme is attached as Exhibit Cto this exemption petition.ZucKERT ScouTT RASENBERGER 

### August 26, 2014 Page 5

certificate. The commercial UAS operations by 

### 01 will resemble the circumstances underwhich the FAA will issue a Certificate ofWaiver orAuthorization to UAS operators without requiring pilot certification. All operations will be in Class Gairspace, conducted during daylight hours undervisual line-of-sightflight procedures no more than one-half nautical mile laterally from the 

### 01 PIC. All 

### 01 PICs also will hold, at a minimum, avalid FAA second-class medical certificate. In accordance with the qualifications established by the FAA forthe pilots of UAS aircraft operating pursuant to a COA undersimilarflight conditions, Ol's PICs should therefore be deemed qualified once they have successfully completed an FAA private pilot ground instruction course and passed the FAA Private Pilot examination or an FAA-recognized equivalent. 3


### The managerfor Ol's commercial UAS operations is Bryan Foster, a recognized UAS industry expert. Mr. Foster has overthirtyyears ofexperience building, flying and maintaining remotely-piloted systems, including 12years as an instructorand 5 years of utilizing remotely piloted systems while in the U.S. Army Military Intelligence Corps. He has over 20,000 hours ofexperience operating remotelypiloted vehicles, and conducts between 500-750 UAS flights peryear. This knowledge and experience has been incorporated intothe training, flight procedures and maintenance recordkeeping developed for Ol's commercial UAS operations. Exemption Request


### 01 is requesting an exemption from FAA regulations in orderto conduct commercial UAS operations with a DJI S800 and Aeronavics X4 aircraft. Attached is a list ofeach FAA regulation from which 

### 01 is requesting an exemption and thejustification for each such exemption. In accordance with FAA requirements, in the case ofeach requested exemption, 

### 01 is suggesting alternate methods of compliance that will provide a level ofsafety equivalent tothat provided by the regulation from which an exemption is sought. Ol's request is consistent with the FAA's policies forthe granting ofexemptions. Italso is in accordanee with the direction provided by Congress in Section 333 ofthe FAA Modernization and Reform Act of2012 ( 11

### FAA Modernization Act"), instructingthe Secretary ofTransportation to determine which UAS aircraft operating 11

### Within visual line ofsight" may be integrated intothe National Airspace System rNAS") before the development of regulations governingthe commercial use ofothertypes of UAS aircraft.4 

### Because ofthe relatively small size, lightweight, speed and operational capabilities ofthe DJI S800 and Aeronavics X4, as well as the strictvisual line ofsight protocols underwhich these UAS will be operated by 

### 01, the OJI S800 and Aeronavics X4 aircraft may be safely operated without creating a hazard to other users ofthe NAS orathreatto national security. The DJI S800 and Aeronavics X4, operated as proposed herein, is therefore thetype of UAS that oughtto be the subject ofoperational

3 

### See FAA Notice 8900.227 Unmanned Aircraft Systems Operational Approval, pp. 20-21. 4 See, 

### Pub. Law 112-95, 126 Stat. 11, § 

### 333.ZucKERT ScouTT RASENBERGER August 

### 26, 2014 Page 6
approval by the Department ofTransportation priortothe issuance of regulations governingthe operation ofsmall unmanned aircraft systems generally. The UAS operations to be conducted by 01 pursuant to the requested exemption offer significant safety enhancements over current methods of providing the same commercial services. Ol's DJI 

### 5800 and Aeronavics X4 aircraft have the ability to fly into difficult-to-access areas that present substantial hazards to other methods ofdata collection, including those involving close-up inspections by human beings. In evaluating Ol's request for an exemption, the FAA should consider notjustthe ability of01 to achieve a level ofsafety equivalentto that afforded by the regulations from which an exemption is sought, but also the safety benefits to be derived from using UAS aircraftfor services now performed by other means at substantially greater risk to human life. As demonstrated below, the FAA can allowthese benefitsto be realized without compromising its obligation to promote the highest level ofaviation safety.

Respectfully submitted,

Counsel for Oceaneering International, Inc.ZucKERT ScouTT RASENBERGER

OCEANEERING INTERNATIONAL, INC.- EXEMPTION REQUEST August 26, 2014 Page 7

Oceaneering International, Inc. requests an exemption from the following regulations ofthe Federal Aviation Administration:
1. 14 C.F.R. § 45.23(b)- Display of marks; general This regulation requires the display ofan "N" registration mark on any U.S.-registered aircraft. Additional markings are required for limited or restricted category aircraft, experimental aircraft or provisionally-certificated aircraft on the entrance to the cabin, cockpit or pilot station. Equivalent level ofsafety analysis: The FAA has yetto indicate whether UAS aircraft will be subjectto its aircraft registration requirements. The FAA's Integration ofCivil UnmannedAircraftSystems in the NationalAirspace System (NAS) Roadmap published in November2013 is silent on this point. As UAS aircraft are notcurrently required to be registered with the FAA, it is not necessary for Ol's UAS aircraft to be marked with an "N" registration number.
The surface area ofthe DJI 5800 and Aeronavics X4 is not large enough to contain any ofthe markings required by the FAA for limited or restricted category aircraft, experimental aircraft or provisionally-certificated aircraft. One ofthe purposes served by these markings is to caution passengers onboard such an aircraft (including any pilot) that it does not meet all ofthe FAA's requirements for astandard category certificate ofairworthiness. As the DJI 5800 and Aeronavics X4 will not carry any passengers, and otherwise will operate in accordance with strictly-controlled flight parameters, the absence ofsuch a warning on the DJI 5800 and Aeronavics X4 will not result in any reduction in the overall safety ofthe operation.
01 is willing to include any markings that may be required by the FAA in connection with its commercial UAS operations, with the understandingthatthe surface area ofthe DJI 5800 and Aeronavics X4 will not permit letteringthat is largerthan%- one inch in height. In addition, if requested by the FAA, 01 can place markings on each ofthe control stations used to operate Ol's UAS aircraft.


### 2. 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. § 91.203: Civil Aircraft: Certifications Required Under 14 C.F.R. § 91.203, all U.S.-registered aircraft are required to have a certificate of airworthiness issued by the FAA. Part 21, Subpart Hofthe FAA's regulations establishes the procedural requirements forthe issuance ofairworthiness certificates by the FAA. Equivalent level ofsafety analysis: The strict operational limitations underwhich 01 will conductflights for commercial UAS applications (e.g., daylight operations, use ofClass Gairspace, all flights within lineof-sight ofthe operator) are at least as restrictive as the limitationsthat applyto the operation of limited or restricted category, experimental or provisionally-certificated aircraft. The DJI 5800 andZucKERT ScouTT RASENBERGER August 26, 2014 Page 8

Aeronavics X4 do not carry a pilot or any other passengers and theirsmall size and electric motor reduce the dangerthat any collisions with the ground or structures will involve anything more than the loss of the DJI S800 and Aeronavics X4. Automatic descent ofthe DJI S800 and Aeronavics X4 upon loss ofthe data linkwith its control station eliminates the potential for "fly away" incidents. The concerns behind the need forthe certification ofan aircraft's airworthiness are mitigated by the DJI S800's and Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their construction, all ofwhich reduce the risk ofdamage to surroundingstructures. 

### 3. 14C.F.R. § 61.133(a): Commercial Pilot Privileges and limitations
FAA regulations generally require that an aircraft may engage in operationsfor compensation or hire only if it is flown by a person holding a commercial pilot certificate. 14 C.F.R. § 61.133(a). 01 submits that hands-on experience with the flight characteristics ofthe DJI S800 and the Aeronavics X4 and UAS aircraft generallyare afar more effective guarantee offlight safetythan a commercial pilot certificate would be in connection with Ol's proposed commercial UAS services. Equivalent level ofsafety analysis. Ajoystick-operated UAS, such as the DJI S800 and Aeronavics X4, has flight characteristics substantially differentfrom manned aircraft. The propulsion system and control surfaces on the DJI S800 and Aeronavics X4 respond to inputsthat are transmitted remotelyfrom the joystick located on the control station. A commercially-licensed pilotwould need to "unlearn" almost all the principles offlying a manned aircraft in orderto successfully operate the DJI S800 and Aeronavics X4. On the other hand, an operatorwho had done all his or her "flying" on the DJI S800 and Aeronavics X4, with no previous flight experience with manned aircraft, would know no othertype ofairborne system butwould be intimatelyfamiliarwith maneuveringthe DJI S800 and Aeronavics X4.
01 therefore emphasizes UAS training and flight experience forthose employees who will operate the DJI S800 and Aeronavics X4 for commercial services. An 01 employee will not be able to act as an operatorof DJI S800 and Aeronavics X4 commercial services until successfully completing a minimum of25 hours of UAS training flights (150 ten-minute flights). Successive levels of responsibility for UAS operations require additional hours offlight experience, as follows:
Position Technician Pilot Senior Pilot Supervisor Superintendent Minimum Required Flight Experience
25 hours ofoperations (150 ten-minute flights) 75 hours ofoperations (450 ten-minute flights) 150 hours ofoperations (900 ten-minute flights) 250 hours ofoperations (1500 ten-minute flights) 400 hours ofoperations (2400 ten-minute flights)
The above-listed hours will be recorded in ASA-SP-30 pilot logbooks subjectto inspection by FAA personnel at anytime. Attached as Exhibit Dis a summary ofOl'straining program for UAS operators.ZucKERT ScouTT RASENBERGER August 26, 2014 Page 9
By requiring extensive flight experience with the DJI 5800 and Aeronavics X4 priorto conducting commercial operations, 01 employees will have a bettergrasp ofthe handling ofthat aircraft and the available options in the event ofan emergencythan they would by holding a commercial pilot certificate for an entirely differenttype ofairborne system.
01 also conducts extensive simulatortraining and flight trainingfor each of its DJI 5800 and Aeronavics X4 operators. Simulatortraining is in addition to the hands-on training experience required ofeach 01 employee priorto conducting commercial operations with the DJI 5800 and Aeronavics X4 aircraft. The amount oftraining- under simulator conditions and hands-on- that 01 employees must complete before conducting commercial UAS services provides a level ofexperience specific to UAS flight operations that cannot be duplicated merely by holding a commercial pilot certificate. The 01 operators ofthe DJI 5800 and Aeronavics X4 will thus be better prepared to conduct UAS flights than a commercially-licensed pilotwho has never operated a UAS aircraft and is unfamiliarwith its flight characteristics.
In addition to UAS operational experience and simulatorflighttraining, 01 also will require that before becoming a UAS operator an employee must complete an FAA-approved private pilot ground instruction course and have successfully passed the FAA Private Pilot written examination oran FAArecognized equivalent. Operators of01 UAS aircraft will therefore receive instruction in aeronautical navigation, meteorology and aviation regulations priorto conducting commercial UAS operations.
4. 14C.F.R. § 91.7(a): Civil Aircraft Airworthiness.
This regulation prohibitsthe operation ofan aircraft unless it is in an airworthy condition. The DJI 5800 and Aeronavics X4 will not be the subject ofan airworthiness certification process priorto their use by 01 for commercial UAS services. Equivalent level ofsafety analysis. The strict operational limitations underwhich 01 will conductflights for commercial UAS applications (e.g., daylight operations, use ofClass Gairspace, all flights within lineof-sight ofthe operator) are at least as restrictive as the limitationsthat applyto the operation of limited or restricted category, experimental or provisionally-certificated aircraft. The DJI 5800 and Aeronavics X4 do not carry a pilot or any other passengers and theirsmall size and electric motor reduce the dangerthat any collisions with the ground orstructures will involve anything more than the loss of the DJI 5800 and Aeronavics X4. Automatic descent ofthe DJI.S800 and Aeronavics X4 upon loss ofthe data link with its control station eliminates the potential for 1/fly away" incidents. The concerns behind the need forthe certification ofan aircraft's airworthiness are mitigated bythe DJI S800's and Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their construction, all ofwhich reduce the risk ofdamage to surrounding structures.ZucKERT ScouTT RASENBERGER August 26, 2014 Page 10

5. 14 C.F.R. § 91.9{b}(2): Civil Aircraft Flight Manual, Marking and Placard Requirements. This regulation requires that an approved flight manual, manual material, markings, placards or some combination thereof be placed onboard the aircraft. Neither DJI S800 northe Aeronavics X4 has a configuration suitable for compliance with this requirement. Equivalent level ofsafety analysis. The DJI S800 and Aeronavics X4 are linked to a computerthatserves as the control station. The instruction manual forthe DJI S800 and Aeronavics X4 can be downloaded to the computer and accessed by the operator, in much the same waythat pilots ofcommercial airliners are able to access flight manuals on tablet devices that serve as "electronicflight bags." All manual material, markings and placards relevant to the operation ofthe DJI S800 and Aeronavics X4 can be displayed on the screen ofthe computerthat serves as the control station, as required. The instruction manual forthe DJI S800 and Aeronavics X4 will therefore be justas accessible as aflight manual carried onboard a commercialjet.
6. 14C.F.R. § 91.109(a) and 14 C.F.R. § 91.109{c): Flight Instruction: Simulated Instrument Flight and Certain Flight Tests. Underthis regulation, aircraft used fortraining purposes must have dual flight controls, subject to certain exceptions. FAA regulations also require that whenevertraining is provided in a simulator, the simulator must have asecond control seat occupied by a safety pilotwho possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. Neither Ol's UAS aircraft northe simulator used by 01 forflight training purposes complies with these FAA requirements. Equivalent level ofsafety analysis. 01 has developed an extensive flight instruction training program for its employees who will conduct commercial UAS operations. Flight instruction is provided through 01 and consists ofground instruction and flighttraining. Furthertraining will be conducted with a computerflight simulatorwith a review ofoperatorskills on a monthly basis. Pilots will be required to perform frequent trainingflights and refresherflights, at eitheran FAA-approved field oron 01 property with suitable objects for pilotsto navigate to and around in a simulated commercial environment. As all operations ofthe DJI S800 and Aeronavics X4 are conducted with ajoystick, a dulyqualified 01 employee with UAS flight experience atthe Supervisor level will be able to observe all operatortraining by standing orsitting nextto the computerthat is used as the control station. Similarly, as flight simulations ofthe DJI S800 and Aeronavics X4 also are displayed on a computer screen, an 01 employee with high-level UAS flight experience is able to sit nextto the operator and directly observe all phases ofsimulatortraining. In this manner, 01 will be able to satisfythe FAA's interest in having simulatortraining observed by a highly-experienced operator. The requirementfor dual flight controls on an aircraft used fortraining purposes is mitigated by the DJI S800's and Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in theirconstruction, all ofwhich reduce the risk ofdamage to surrounding structures in the event ofan operator errorthat results in the loss ofthe aircraft.ZucKERT ScouTT RASENBERGER

7. 14C.F.R. 91.119: Minimum Safe Altitudes: General August 26, 2014 Page 11

This regulation specifies the minimum altitude in various flight environments belowwhich aircraft are not allowed to operate. 01 will conductthe commercial services it proposes to operate belowthe FAA-specified minimum of500 feet above the surface and closer to vessels and structures than the minimum separation of500 feet mandated by the FAA. Equivalent level ofsafety analysis. The operation ofthe DJI S800 and Aeronavics X4 aircraft exclusively in Class G airspace (i.e., below 500 feet) is intended as a safety measure to provide a level ofseparation between Ol's commercial UAS operations and the operation of manned aircraft at altitudes above 500 feet. In this case, limitingthe DJI S800 and Aeronavics X4 to flights belowthe 500foot minimum will enhance safety ratherthan compromise it. 01 will need to operate the DJI S800 and Aeronavics X4 closerthan 500 feet to structures in orderto conduct the inspectionsthat will comprise a major part of Ol's commercial UAS services. However, Ol'sflight procedures include the company's own requirements regarding the minimum level ofseparation between the DJI S800 and Aeronavics X4 and any nearby structures orfacilities. In addition, the risk ofdamage to any nearby structures orfacilities is reduced by Ol's S800's and Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their construction. 8. 14C.F.R. § 91.121: Altimeter Settings Pursuant to this regulation, an aircraftthat is operating below 18,000feet above Mean Sea Level must contain an altimeterthat is set to one ofseveral designated altimeter settings priorto departure. Neitherthe DJI S800 northe Aeronavics X4 includes an altimeter. Equivalent level ofsafety analysis: The operation ofthe DJI S800 and Aeronavies X4 aircraft exclusively in Class G airspace (i.e., below 500 feet) awayfrom commercial traffic and ATe-controlled airspace reduces the need for an altimeteronboard Ol's UAS aircraft. The altitude ofOl's UAS aircraft above Mean Sea Level and its GPS coordinates will be displayed on the screen ofthe remote control station used by the 01 operatorto perform any commercial services. The 01 operatorwill have continuous situational awareness ofthe UAS altitude and position as flight operations will be conducted under lineof-sight flight procedures. 9. 14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. FAA regulations require that a rotorcraft operating underVFR conditions have sufficientfuel to flyto the first point of intended landing and, assuming normal cruising speed, to flyfor at least an additional 20 minutes. Ol's DJI S800s arid Aeronavics X4 have a maximum operatingtime of20 minutes. Equivalent level ofsafetyanalysis. The FAA's regulations require sufficient reserves ofadditional fuel to enable a rotorcraft to find the nearest suitable landing zone ifthe intended landing facility is not available. The additional time that a rotorcraft is required to be able to operate is less than the time required to allowfixed-wing aircraftto find a suitable landing field (30 minutes duringthe day, 45 minutes at nightL reflecting the relative scarcity of landing fields for aircraftversus landing zones suitable for rotorcraft. By similar logic, the additional fuel required for UAS aircraft should beZucKERT ScouTT RASENBERGER 

### August 26, 2014 Page 12
dramatically less than for rotorcraft, as UA5 aircraft are small enough to land virtually anywhere. Because the DJI 5800 and Aeronavics X4 initiates an automatic spiral descent upon any loss of power, there is no need to require additional flying time forthe DJI 5800 and Aeronavics X4 to find asuitable landing zone. The concerns behind the FAA's surplus fuel requirementfor rotorcraft are mitigated by the DJI 5800's and Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their construction, all ofwhich reduce the risk ofdamage to surrounding structures. 10. 14 C.F.R. § 91.203(a) & (b): Civil Aircraft: Certifications Required. 

### The FAA requires that all civil aircraft have an appropriate and current airworthiness certificate and thatthe airworthiness certificate or special flight authorization foran aircraft be displayed atthe cabin or cockpit entrance so that it is visible to passengers orcrew. The DJI 5800 and Aeronavics X4 do not have acurrent airworthiness certificate nordo they have asurface area large enough to display a certificate ofairworthiness orspecial flight authorization. Equivalent level ofsafety analysis. The strict operational limitations underwhich 01 

### will conduct flights for commercial UA5 applications (e.g., daylight operations, use ofClass Gairspace, all flights within lineof-sight ofthe operator) are at least as restrictive as the limitationsthat applytothe operation of aircraftthat have been issued limited or restricted category, experimental or provisional certificates of airworthiness. The concerns behind the need forthe certification ofan aircraft's airworthiness are mitigated by the DJI 5800's and Aeronavics X4's limited operational range, small dimensions and the use oflightweight materials in theirconstruction, all ofwhich reduce the risk ofdamage to surrounding structures. One ofthe purposes served by the requirementto display a certificate or airworthiness onboard an aircraft is to advise passengers (including any pilot) thatthe aircraft meets all ofthe FAA's requirementsfora certificate ofairworthiness. As the DJI 5800 and Aeronavics X4 will not carry any passengers, and otherwisewill operate in accordance with strictly-controlled flight parameters, the absence ofsuch awarning on the DJI 5800 and Aeronavics X4 will not result in any reduction in the overall safety ofthe operation. 01 

### is willing to include any markingsthat may be required bythe FAA in connection with its commercial UA5 operations, with the understanding thatthe surface area ofthe DJI 5800 and Aeronavics X4 will not permit letteringthat is largerthan%- one inch in height. 11. 14C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Aircraft Maintenance and Inspections; Maintenance Records. 

### FAA regulations impose various requirements regarding the maintenance ofcivil aircraft, including periodic inspections, approval for return to service by a qualified mechanic following maintenance or repair, an airworthiness inspection and certain rules concerning maintenance recordkeeping. Ol's maintenance ofits DJI 5800 and Aeronavics X4 aircraftwill not satisfy these requirements.ZucKERT Scourr RASENBERGER August 26, 2014 Page 13

Equivalent level ofsafety analysis. 01 will maintainthe DJI 5800 and Aeronavies X4 in accordance with the manuals and operating handbook provided by the manufacturer. Because ofthe DJI S800's and Aeronavics X4's small size and lightweight construction, 01 will be able to subject itto top-to-bottom examination aftereveryflight. All pre- or post-flight maintenance, equipmentfailures, charge cycle logs, fault/repair logs, inspections and general maintenance records will be kept on file for a minimum of three years. 01 has developed a lengthy pre/post-flight checklist; any aircraftwith is unable to meet all the requirements for safe operation will be removed from service immediately and will not return to service until any defects have been remedied. Moreover, if mechanical issues arise, the DJI 5800 and Aeronavics X4 can land immediately as theywill be operating at an altitude no higherthan 500 feet. The manufacturers periodically update parts and software forthese UAS aircraft. Each time a UAS is tested in the office, 

### 01 checks forthe most recent stable software issued by the manufacturer 

### {01 will not use Beta software). Ifany parts have been updated by the manufacturer, 01 immediately places them on orderto ensure its UAS aircraft have the most recent equipment and software. The number ofhours that a UAS is in operation are logged by 

### 01 to ensure proper life of components as well as the flight packs that provide power. Once a DJI 5800 and Aeronavics X4 aircraft has been removed from service its unique ID and serial numberwill not be re-issued.