Justin K. Sellers, President, CEO Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 18August2015 U.S. DepartmentofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR part 21; 14 CFR 61.113 (a) 

### & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) 

### & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) 

### & (b). Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 C.F.R

. Part 11, Sellers Imaging, LLC ("The Applicant"), developer and operator of Small Unmanned Aircraft Systems ("SUASs") equipped to conduct Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, 

### wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetricAnalysis, Research and development, traffic monitoring, and sporting events, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its SUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333.
As described more fully below, the requested exemption would permit the operation ofsmall, unmanned, and relatively inexpensive sUAS under controlled conditions in airspace that is 1)1imited, 2) predetermined, 3) controlled as to access, and 4) would provide safety enhancements to the already safe operations in the infrastructure and business operations industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (The FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraftsystems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: Sellers Imaging, LLC ATIN: Justin K. Sellers Ph: (843)655-8944 Email: Justin@Sellerslmaging.com Address: 303 Foxchase Circle North Augusta, SC 29860

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARYRegulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 (a) 

### & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2} 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) 

### & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 91.407 (a) (1) 14 C.F.R. 91.409 (a) (2) 14 C.F.R. 91.417 (a) 

### & (b) This exemption application is expressly submittedto fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems mayoperate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." 

### Jd. §333(C) (emphasis added). 1 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 ofthe Act, which includes sUASs, from the requirements that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section oranysections 44702-44716 ofthis title ifthe administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203 (a) (1). Sellers Imaging, LLC's sUASs (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including payload. They operate under normal conditions ata speed of no morethan 55 knots and have the capability to hover and move in

1Applicant interprets this provision to place the duty on the administrator to not only process applications for exemptions under §333, but forthe Administrator to craft conditions for the safe operation ofthe UAS. if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPR IETARYthe vertical and horizontal plane simultaneously. They will operate only in line ofsight and will operate onlywithin the sterile area described in the confidential Sellers Imaging, LLC Unmanned Aircraft Systems Operations Manual, attached as Appendix 2 (hereinafter "The Manual") 2• Such operations insure thatthe sUAS does "not create a hazard to users ofthe national airspace system orthe public." 3 Given the small size ofthe sUASs involved and the restricted sterile environmentwithin which they will operate, the applicantfalls squarely within that zone ofsafety (an equivilant level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant SUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authoritycontained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, the granting ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grantthe requested exemption without delay. 

### Background Information Sellers Imaging, LLC is in the business ofconsulting on, building, and maintaining mission specific sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual InspectionPrimarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. Sellers Imaging, LLCs' clients lookto us for safe operations ofsUAS. We have developed specific safe UAV operational procedures. Increasingly, we have clients looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public ServicePrimarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetricAnalysis, Research and development, traffic monitoring, and sporting events.

2 Applicant submits this manual as a Confidential document under 14CFR 11.35 (b) as the entire manual contains proprietary information thatthe applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act 5 U.S.C. 552 et. Seq. 3 Reform Act Section 333(b). Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY



# ---------------------------------------------------------------------------------------- ---- ---Operations performed 

### by Sellers Imaging, LLC include:

Precision Agriculture 2D and 3D Mapping Photography Cinematography Aerial Data Collection Visual Inspection- Primarily: Towers Poles Pipelines power lines cables bridges chimneys vertical structures solar arrays wind generators power stations and substations coal ash ponds absorbers buildings Real Estate Golf Courses Orthographic Photography Special Events Construction Progress Public Service
- Primarily: Search & Rescue Law Enforcement Fire Security Disaster Management & Relief Wildfires Floods Hurricanes news broadcasting tornados Banner towing Announcements animal tracking Alzheimer patient tracking Radiation detection Noxious gas detection Forestry & logging Insurance Assessments Surveys Mining volumetric Analysis Research and development Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARYtraffic monitoring sporting events As part ofthis Sellers Imaging, LLC is requesting FAA Exemption for sUAS operations for safety, inspection and video capture Usage. 

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraftthat have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations underthe current regulatory structure because the proposed operations represent a safety enhancement to the already safe Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. Sellers Imaging, LLCs' clients lookto us for safe operations of sUAS. We have developed specific safe UAV operational procedures. Increasingly, we have clients looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados

. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, M ining, volumetric Analysis, Research and development, traffic monitoring, and sporting events operations conducted with conventional aircraft. These limitations and conditions to which Sellers Imaging, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include: 

### 1. The sUAS will weigh less than 551bs. 2. Flights will be operated within line ofsight, unless an addendum is released or other appropriate FAA guidelines supercede

. 3. Maximum total flight time for each operational flight will be 60 minutes

. Flights will be terminated at 25% battery power reserve; should that occur prior to the 60 minute time limit. 4. Flights will be operated atan altitude of no more than 400 feet AGL (Above Ground Level) or, not more than 200 feet above an elevated platform from which the flight is planned. 5. Minimum crew for each operation will consist ofthe sUAS pilot and the Visual Observer. 6. The sUAS pilotwill be a specially trained staff member of Sellers Imaging, LLC. Knowledgable ofthe airspace within which the operation will take place and how that airspace fits into the NAS. 7. The sUAS pilotwill be the Pilot in Command (PIC). Ifa pilot certificate holderotherthan the sUAS Pilot, who possess the necessary PIC qualifications, is also present on site, that person can also be designated as PIC. 8. The sUAS will onlyoperate within defined boundaries as outlined in Section 8.4 ofthe manual. 9. A briefingwill be conducted in regard to the planned sUAS operations priorto each mission. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be presentfor this briefing.
Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY

### 10. The operatorwill file a FAA form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office (FSDO). 11. The operatorwill obtain the consent ofall persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required by section 8.4 ofthe manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. 12. The operatorwill submit a written Plan ofActivities to the FSDO three days before the proposed mission as required in Section 8.1 ofthe Manual. Items will include: a. Dates and times for all flights; b. Name and phone numberofthe operator for the UAS mission conducted underthis petition of exemption; c. Make, Model, and serial or N-numberof UAS to be used; d. Name and certificate numbers of UAS PICs involved in the mission; e. A Statement thatthe operator has obtained permission from property owners or property owners' representatives and/or local officials to conduct the mission; f. The list ofthose who gave permission made available to the inspector upon request; g. Signature ofexemption-holder or representative; and h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state overwhich the mission will be conducted and the altitudes essential to accomplish the operation. 13. Pilot and observer will have been trained in operation of UAS generally and received up to date information on the particular UAS to be operated as required in Sections 7.4 and 7.5 ofthe manual. 14. Observer and pilot will at all times be able to communicate by voice. 15. Written and/ororal permission from the relevant property holders will be obtained. 16. Al l required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or otherappropriate governmental agencies. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have the capability to return to a predetermined location within the security Perimeter and land. 18. The sUAS will have the capability to abort aflight in case of unpredicted obstacles or emergencies. 14 C.F

.R

. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R

. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a)(1). Given the size and limited operating area associated with the aircraftto be utilized bythe applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49U.S.C. §44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airwrothiness certificate without the restrictions and conditions proposed

. The sUAS to be operated hereunder is less than 551bs

. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the manual. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and observer, pursuant tothe Manual's policies, and under and in compliance with local public safety requirements, to provide security for the area ofoperations as is now done with conventional Precision Agriculture, Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events

. The FAA will have advanced notice ofall ofthese operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R

. part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. 

### 14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "Restricted," "Light-sport," "experimental," or "Provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to a cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Given the size of the sUAV, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe UAS as "Experimental. " The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

### 14 C.F.R. §61 .113 (a) & 

### (b): Priva te Pilot Privileg esand Limitations: Pilot in Command. Sections 61.113 (a) 

### & (b) limit private pilotsto non-commercial operations. Because the UAS will not carry a pilotor passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operatingthe aircraftto have specially trained staffoperate this small UAS. Unlike a conventional Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 --- CONFIDENTIAL AND PROPRIETARYaircraft that carries the pilot and passengers, the sUAS is remotely controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level ofsafety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilots certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested by specially trained staffas the PIC exceeds the present level ofsafety achieved by 14 C.F.R. §61.113 

### (a) 

### & (b).
14 C.F.R. §91.7(a) : Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthycondition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use of safety checklists priorto each flight, as setforth in Sections 9

.1 and 9.6, an equivalent level ofsafety will be provided.
14 C.F.R. §91 .9 (b) (2) : Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.- registered civil aircraft

... (2) For which an airplane or rotorcraft Flight Manual is not required by §21 .5 ofthis chapter, unless there is available in the aircraft a current Approved airplane or rotorcraft Flight Manual, approved manual material, markings, and placards, Or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no piloton board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control pointwhere the pilotflying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607 8737, 8738, 9299, 9299A, 9565,95658, 10167A, 10602, 32827, and 10700

. 14 C.F.R. §91 .103: Preflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided for the aircraft, an exemption will be needed. An equivalent level ofsafety will be provided as set forth in Sections 8 and 9 ofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before initiation offlight.
14C.F . R. §91 . 109: Flight Ins truction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functional dual controls.

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDE NTIAL AND PROPRIETARYsUASs and remotely piloted aircraft, by their deisgn do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a numberofaircraft and for flight instruction in experimental aircraft. See Exemtpion Nos. 5778K & 9862A. The equivalent level ofsafety is provided by the fact that neither the pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft

. 14C.F.R. §91 .119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil 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 prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400AGL, or not more than 200 feet above an elevated platform from which operation is planned, an exemption may be needed to allow such operations. As set forth herein, exceptfor the limited conditions stated in the M anual the UASw ill never operate at higherthan 400 AGL. It will, however, be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner, representatives ofthe propertyowner or local officials. Because ofthe advanced notice to the property owners and participants in the mission, all affected individuals will be aware ofthe planned flight operations as set forth in Section 6.2, 8.1 and 8.2 ofthe Manual. Compared to flight operat ions with aircraft or rotorcraft weighing far more than the maximum SSibs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. The FAA will have advanced notice ofall ofthese operations. These safety enhancements, which already applyto civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events industries. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14 C.F.R. §91 .121Altimeter Settings

Sellers Imaging, LLC 303 Foxchase Circle Nor th Augusta, SC 29860--- CON FIDENTIAL AND PROPRIETARYThis regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimetersetting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant tothe Manual and safety checklist, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 

### 14 C.F.R. §91 .151 (a) : Fuel Requirements for Flight in VFR Conditions Section 91. 151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first pointof intended landing, and, assuming normal cruising speed - (1) During the day, to fly afterthatfor at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes." The battery poweringthe sUAS provides approximately 30-37 minutes of powered flight. To meet the 30- minute reserve requirement in 14 C.F.R. §91. 151, sUA$ flights would be limited to approximately 20 m inutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 C.F.R. §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.15 1 (a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limitingsUA$ flights to 20 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 20 minutes or 25% of battery powerwhichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808. 

### 14 C.F.R. §91.202 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following:
(1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate require by paragraph (a) ofthis section or a special flight authorization issues under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers and crew.
Sellers Imaging, L L

C303 Foxchase Circle North Augusta, SC 29860--- CONFIDE NTIAL AND PROPRIETARYThe UAS fully loaded weighs no morethan 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (a); 407 (a) (1}; 409 (a) (2}; 417 (a) 

### & (b) : Maintenance Ins pections These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph ©ofthis section, have discrepancies repaired as prescribed in Part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43

. Given that these sections and Part43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant tothe flight manual and operating handbook as references in the Manual (See Sections 8.6 and 9). An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land immediately and will be operatingfrom no higher than 400ft AGL. As provided in the Manual, the operatorwill ensure that the UAS is in working order priorto initiating flight, perform required mai ntenance, and keep a log ofany maintenance performed

. 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 equivalent level ofsafety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R

. Part 21, 14 C

.F.R. 45.23(b), 14 C.F.R. 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 C.F. R. 91.9 (b) (2), 14 C.F.R. 91.103, 14 C.F.R. 91.109, 14 C.F

.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C

.F.R. 91.203(a) 

### & (b), 14 C.F.R. 91.405 (a), 14 C.F.R. 91.407 (a) (1), 14 C.F.R

. 91.409 (a) (2), 14 C.F.R. 91.417 (a) 

### & (b). to operate commercially a small unmanned vehicle (551bs or less) in motion picture and television operations

. Approval ofexemptions allowing commercial operations of sUASs in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. The FAA will have advanced notice ofall ofthese operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARYEstate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, usingjetor piston powered aircraft, operate at extremely low altitudesjustfeet from the infrastructure being inspected and in extreme proximityto people and structures; and presentthe risks associated with vehicles thatweigh inthe neighborhood of4,0001bs, carrying large amounts ofjetA orotherfuel. Such aircraft must fly to and from the work location. In contrast, a sUAS weighing fewer than SSibs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the worksite and notflown. The sUAS will carry no passengers or crew and, therefore, will notexpose them to the risks associated with manned aircraft flights. The operation ofsmall UASs, weighing less than SSibs., conducted in the strict conditions outlines above, will provide an equivalent level ofsafety supportingthe grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slowspeeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity tothe ground and people. 

### Privacy All flights will occur over private orcontrolled access property with the property owner's prior consent and knowledge. Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual InspectionPrimarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events

. The FAA will have advanced notice ofall ofthese operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings

. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events operations will be performed for people who have also consented for work to be performed orotherwise have agreed to be in the area where UAS flight will take place. 

### Conclus ion Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012- size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplican'ts UAS in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARYwind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. The FAA will have advanced notice ofall ofthese operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, powerstations and substations, coal ash ponds, absorbers, and buildings. Real Estate, GolfCourses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

### & Rescue, Law Enforcement, Fire, Security, Disaster Management 

### & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patienttracking, Radiation detection, Noxious gas detection, Forestry 

### & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events industries pursuant to the Manual appended hereto.

Sellers Imaging, LLC

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY