**12/8 /2015** 

**Nicholas T. LaRiviere Sr Firefly Aerial Solutions LLC**  **40 Grayson St Biddeford, ME. 04005**  **207**

**- 504** 

**- 7773** 

**Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H** 
**14 CFR 45.23(b) 14 CFR 61.113(a) and (b)**  **14 CFR 91.7(a) 14 CFR 91.9(b)(2)**  **14 CFR 91.103 14 CFR 91.109**  **14 CFR 9 1.119(c)**  **14 CFR 91.121 14 CFR 91.151(a)**  **14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a)**  **14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2)**  **14 CFR 91.417(a) and (b)**

**Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform A** **ct”) and 14 CFR Part 11, Nicholas T. LaRiviere owner of Firefly Aerial**  **Solutions LLC , hereby applies for an exemption from the listed Federal Aviation**  **Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are condu**  **cted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.** 
**Commercial operation of an UAS, as described herein, which are equipped with camera(s)**  **a nd sensors, would provide professional services in the following** 
**areas: 1.**  **Aerial photography and/or video for public and/or private use including**

**real estate, Architecture, Weddings, land surveying, engineering and other related professional activities.**  **2. Aerial video and/or photography for public and/or private use including**  **television, public Events, cinematography and newsgathering, Weddings. 3.**  **Aerial inspection/photography of residential/commercial structures under contract with the owners or local gove**  **rnment authority. 4.**  **Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind**  **turbines and cell towers. 5.**  **Aerial video/photography or providing live video feed to assist with**

**sear ch and rescue operations in cases of an emergency or natural disaster**  **only when the local authorities or government has requested it by contract or donation.**  **6. Training to persons individually or belonging to both private and/or public**  **organizations to incr ease awareness and improve safety for current and**  **future UAS operations within the NAS.**

**As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this document under controlled conditions in**  **the NAS t hat would be** 

**1. Limited**  **2. Controlled**  **3. Predetermined**  **4. Safe** 

**Approval of this exemption would increase p**  **ublic awareness of UAS operations**  **and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA Administrator’s) resp**  **onsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”** **Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, plan**  **s to operate a** 

**UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3**  **Professional is referred to as a quad** 

**- copter with a maximum gross weight of**  **about 3 pounds. It is equipped with four rotors that are driven by electric**  **motors powered by batteries. The UA has a maximum airspeed of 16 m/s.**

**Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, also plan**  **s to operate**  **a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or Inspire 1) and a transportable ground station. The**  **DJI Inspire 1 is referred to as a**  **quad**

**- copter with a maximum gross weight of about 6.5 pounds. It is equipped**  **with fou r rotors that are driven by electric motors powered by batteries. The UA**  **has a maximum airspeed of 22 m/s.**

**Also, given the small size of the UAS’s involved and the restricted controlled environment within which they will operate, the applicant fits with**  **in that zone of safety (an equivalent level of safety) in which Congress envisioned that the**  **FAA must, by exemption, allow commercial operations of UASs to commence**  **immediately. Also due to the size of the UASs and the controlled areas in which**  **the releva nt UASs will operate, approval of the application presents no national**  **security issue. Given the following, the grant of the requested exemptions is clearly in the public interest:** 

**Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, proposes th**  **at the exemption requested herein apply to civil aircraft that have the characteristics**  **and that operate with the limitations listed herein. These limitations provide for an exceptional level of safety to operations. These limitations and conditions to**  **whi ch**  **Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, agrees to be**  **bound when conducting commercial operations under an FAA issued exemption including:** **1. The UAS will weigh less than 55 lbs.**

**2. Flights will be operated within line of sigh t of operator.**  **3. Maximum total flight time for each operational flight will be 30 minutes. 4.**  **Flights will be terminated at 20 % battery power reserve.**  **5 . Flights will be operated at an altitude of no more than 400 feet AGL**  **6 . UAS operator will be trai**  **ned and certified in the proper safety and operations of the UAS.**  **7 . The UAS will only operate within a controlled area as defined in the**  **Procedures. 8**  **. The operator will post advisor notice around the controlled area. 9**  **. The operator will have been trained in operation of UAS generally and received up** 

**- to** 
**- date information on the particular UAS to be operated as**  **required. 10**  **. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return t**  **o a pre -**  **determined location within the Security Perimeter and land.**  **11 . The UAS will have the capability to abort a flight in case of unpredicted**  **obstacles or emergencies.**
**Accordingly, the applicant respectfully requests that the FAA grant the requested**  **exemption and are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to**  **working with your office. Please contact us at any time if additional information or clarifications are neede**  **d.**
**Sincerely,**

**Nicholas T. LaRiviere Firefly Aerial Solutions LLC**