UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 UAV

- Assistance LLC

Attn: Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043

March 3, 2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 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 ; 9 1.119 ; 91.121; 91.151(a) ; 91.203 (a) & (b) ; 91.405 (a); 91.407(a) (1); 91.409 (a) (2) ; 91.417 (a) & (b). Sec tions 44703 and 44711 of title 49

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, UAV

- ASSISTANCE LLC (“the applicant”)

, solo developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to

conduct Airborne Photographic, Video, Inspection and Sensor Data Collection services

, hereby applies for an exempt ion from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

A special exemption from sections 44703 and 44711 of title 49 is also requested due to the applicant’s extensive specialized sUAS pilot training and experience

.

As described more fully below, the requested exemption would permit the operation of small, unmanned

, and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited

, 2) predetermined

, 3) controlled as to access

, and 4) would provide safety enhancements to the already safe operations in the filming, photographing and se nsor data collection presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 2 The name and address of the applicant is:

UAV

- ASSISTANCE LLC

At t n: Mi c ha el Tranc hitel la

Ph: 301

- 752

- 7519

Email: uav

- assistance@verizon.net

. 3181 Burgess Mill Way Unit D Ellicott City, MD 21043

.

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 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 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

Sec tions 44703 and 44711 of title 49

This exemption application is expressly submitted to fulfill Congress’ goal in

pas sing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely

in the national airspace system (NAS) before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UAS ’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirementsUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 3

for the safe operation of such aircraft in the national airspace system.” Id. §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 of the Act, which includes sUASs, from the requirement that all

civil aircraft must have a current airworthiness certificate.

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

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f)

and 49 U.S. Code § 44703 See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

The applicant’s sUAS (Appendix 1) are Fixed Wing and Rotorcraft , weigh ing 55 or fewer lbs. including payload. They operate under normal conditio ns at a speed of no more

than 15 to 35 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously and move in the horizonta l plane . They will operate only in line of sight and will operate only within the sterile area described in the Unmanned Aircraft Systems Op erations Manual, attached as Appendix 2 (hereinaf ter “the Manual”)

. Such operations insure that the sUAS does “not create a hazard to users of the national airspace system or the public. ” 2

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an

e quivalent 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 restricted areas in which the relevant sUASs will operate,

approv al of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operation s, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for Airborne Photographic, Video, Inspection and Sensor Data Collection services and , the grant ing of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Background Information

The applicant is in the business of providing Airborne Photographic, Video, Inspection and Sensor Data Collection services

. The applicant operates on a solo basis

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft con ditions for the safe operation of the

UAS , if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

2 Reform Act Section 333 (b).UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 4

and will be the only person piloting the aircraft although a trained observer will always be present. The applicant’s c lients look to the applicant for safe o perations of sUAS. The applicant has developed specific safe UAV operational p rocedures. Increasingly, the applicant has clients looking for sUAS services for Airborne Photographic, Video, Inspection and Sensor Data Collection services

. The appli cant’s knowledge , specialized training, and experience of sUAS and their operation is a benefit to the applicant’s clients and should be considered a valuable asset to the safe operation of sUASs

.

Operations performed by the applicant include :

 Video and still photography

 Three dimensional Mapping /Imaging

 Airborne Sensor Data Collection

 Utility Inspection

 Railroad Inspection

 Pipeline Inspection

 Oil

- Field Inspection

 Petro/Chemical/Manufacturing Inspection

 Construction Site Inspection

 Agriculture Inspection

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with in the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe Airb orne Photographic, Video, Inspection and Sensor

Data Collection services conducted with conventional aircraft.

The aircraft to b e used are the DJI Inspire 1, D JI Inspire Pro + RA W

, D JI Phantom 3

, D JI Ph antom 4, and Event38 E384.

These limitations and conditions to which the applicant ag rees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes (rotor craft) and 60 minutes (fixed wing) . Flights will be terminated at 25% battery power reserve should that occur prior t o the 30 minute (rotorcraft) and 6 0 minute (fixed wing) limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more

than 200 feet above an elevated platform from which flight is planned.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 5

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual

Observer

.

6. The sUAS pilot

- in

- command (PIC) will have the following specific qualifications :

 Received FAA approved Private Pilot ground training and

passed FAA approved testing that meets 14 CFR 61.105

- Aeronautical knowledge.

 Possess a minimum of 14 years of professional sUAS piloting experience

 Amassed a minimum of 1 000 hours flying sUAS.

 Has acted as sUAS PIC under FAA granted Certificate Of

Authorization/s.

 Has acted as sUAS PIC, ground crew, and observer instructor for FAA COAs and employer/customer sUAS.

 Has created sUAS flight and ground operations safety guideli nes, documentation, and maintenance procedures for employer/customer sUAS.

 Has been approved and acted as a civilian sUAS PIC under the United States Department of Defense Test Range safety regulations for Aberdeen Test Center, White Sands Missile Range, F ort Pickett, Fort Hunter Liggett, Red Stone Arsenal, AFRL Eglin AFB,and Dugway Proving Grounds.

 Has operated a sUAS from a tower controlled international airport with full coordination of the Costa Rican Aviation authority for a NASA sponsored demonstratio n.

 Has experience interacting with Air Traffic Control (ATC), Terminal Radar Approach Control Facilities (TRACON), Common traffic advisory frequency (CTAF) and Military Range Safety Control as sUAS PIC.

 Has acted as sUAS PIC under NATO and Italian Milita ry UAS safety guidelines.

 Has piloted manned aircraft in a student capacity.

 Possesses 20/20 vision

 Has a valid driver’s license

 No medical condition/s which could affect sUAS flight performance.

 Have of experience with military and commercial sUAS program management, design, construction, and production. Including (4) commercially available sUAS professional products.

 Has been granted United States Department of Defense security clearance/ s.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 6  Will strictly adhere to the applicant’s sUAS Operating Man ual (see attached)

7. If a sUAS pilot o ther than the PIC described in item 6 , who is a Pilot Certificate

Holder and meets the sUAS PIC qualifications including knowledge of the applicant’s operation’s manual , is also present on site , that person can also be designated as PIC.

8. The s UAS will only operate within defined boundaries as outlined in Section 8.4

of the Manual.

9. A briefing will be conducted in regard to the planned sUAS operations prior to

each mission. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711

- 1, or its equivalent, as modified in light

of the requested exemption, with the appropriate Flight Standards District Of fice (FSDO)

. 11. The operator will obtain the consent of all persons involved in the mission and

ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required by Section 8.4 of the Manual. With the

advanced permission of the relevant FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days

before the proposed mission as required in Section 8.1 of the Manual. Items will

include:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS mission conducted under this petition of exemption;

c. Make, model, and serial or N

- number of UAS to be used;

d. Name and certificate number of UAS PICs involved in the mission ;

e. A statement that the operator has obtained permission from property

owners and/or local officials to condu ct the mission ; f. The list of those who gave permission made available to the inspector

upon request;

g. Signature of exemption

- holder or representative; and

h. A description of the flight activity, including maps or diagrams of any

area, city, town, county, and/or state over which 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 of the Manual.

14. Observer and pilot wi ll at all times be able to communicate by voice

. 15. Written and/or oral permission from the relevant property holders will be

obtained.

16. All required permissions and permits will be obtained from territorial, state,

county or city jurisdictions, including loca l law enforcement, fire, or other appropriate governmental agencies.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 7

17. If the sUAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre

- determined location within the Security Perimeter and

land.

18. The sUAS will have the capability to abort a flight 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 for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requiremen ts of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certif icate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certi ficate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed

.

The sUAS to be operated hereunder is less than 55 lbs. 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 other c ivil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and observer , pursuant to the Manual’s policies , and under and in compliance with local public safety requirements, to provide security for the are a of operation as is now done with conventional Airborne Photographic, Video, Inspection

and Sensor Data Collection services

. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection

with Airborne Photographic, Video, Inspection and Sensor Data Collection services

, provide a greater degree of safety 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 of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry

a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or l ight

- sport category aircraft or experimental or provisionally certificated aircraft, the operator mustUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 8 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 lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety 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 of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167A.

Sections 44703 and 44711 of Title 49 of the United States Code (49 USC) : Airman Certificate Requirement s

Pilot certification requirements for petitions for exemp tion under Section 333 are

evaluated on a case

- by

- case basis. There are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and control of the sUAS/s as described in this application does not depend on the type of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, the key factors needed by the PIC are knowledge of the airspace within which the operation will take place and how that airspace fits into the Na tional Airspace System (NAS). That knowledge can be and is gained primarily through ground school and not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a commercial or private pilot’s certificate. Those c ertificates demonstrate knowledge of the factors and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial vehicle, operating at 400 AGL or lower, within strictly controlled pre

- approved airspace. Besides knowledge of airspace regulations, dexterity in the control and operation of the sUAS acquired fro m actual operation of the aircraft is the most important factor in establishing an equivalent level of safety. If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are (1) where the aircraft will be flown, (2) the s ize of the aircraft relative to what is being used today to accomplish the same mission, and (3) what precautions will be taken to ensure the safety of those in the area of operation.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 9

For the safe operation of the sUAS described in this document the appl icant propose s that the PIC meet the following qualifications:

 R eceived FAA approved Private Pilot ground training and passed FAA approved testing that meets 14 CFR 61.105

- Aeronautical knowledge.

 Possess a minimum of 1 4 years of professional sUAS piloting experience

 A massed a minimum of 1000 hours flying sUAS.

 Has a cted as sUAS PIC under FAA granted Certificate Of Authorizations.

 Has a cted as sUAS PIC, ground crew, and observer instructor for FA A COAs and employer/customer sUAS.

 Has c reated s UAS flight and ground operations safety guidelines, documentation, and maintenance procedures for employer/customer

sUAS.

 Has b een approved and acted as a civilian sUAS PIC under the United

States Department of Defense Test Range safety regulations for Abe rdeen Test Center, White Sands Missile Range, Fort Pickett, Fort Hunter Liggett, Red Stone Arsenal, AFRL Eglin AFB,and Dugway Proving

Grounds.

 Has o perated a sUAS from a tower controlled international airport with

full coordination of the Costa Rican Aviat ion authority for a NASA sponsored demonstration.

 Has experience interacting with Air Traffic Control (ATC)

, Terminal Radar Approach Control Facilities (TRACON)

, Common traffic advisory frequency (CTAF ) and Military Range Safety Control as sUAS PIC

.

 Has a cted as sUAS PIC under NATO and Italian Military UAS safety guidelines.

 Has p iloted manned aircraft in a student capacity.

 P ossess es 20/20 vision

 Has a valid driver ’ s license

 N o medical condition /s which could affect sUAS flight performance.

 Have of experience with military and commercial sUAS program management, design, construction, and production. Including (4) commercially available sUAS professional products.

 Has been granted prior United States Department of Defense security

clearance/ s.

 Will st rictly adhere to the applicant’s sUAS Operating Manual (see attached)

Should there be a mishap, the sUAS being flown pose significantly less of a threat than the helicopters and fixed wing aircraft now being employed because they are a fraction of

the siz e, carry no flammable fuel, do not carry crew or passengers, and pose an

infinitesimal risk to others. This is in stark contrast to conventional aircraft that are flown to the site, carry explosive fuel, carry passengers and crew, and operate in a much lar ger

area. From a practical standpoint, there are relatively few licensed (Private, Sport) aircraft pilots who are also qualified to fly the type of sUAS that are utilized for AirborneUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 10

Photographic, Video, Inspection and Sensor Data Collection o perations. T here are even fewer commercial pilots that can fly these sUAS

– to the point that to do both is considered rare. Assuming that it is unlikely for a company to find a pilo t that has both qualifications, that company would either have to source a qualified s UAS pilot to train

and obtain a commercial or private certificate, or find a commercial certificated pilot who would be willing to learn to fly a sUAS to the competency level required for professional

use. Based on the size and income of the applicant’s bu siness, the requirement of an

Airman’s certificate or the hiring of a person possessing an airman’s certificate is cost prohibitive and

, as described above does not increase safety when compared to the proposed sUAS PIC qualifications

.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equiva lent level of safety of current operations by the applicant operati ng the aircraft based on the proposed s UAS PIC qualifications . This information is described above in the section titled “AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY” item 6 and

in the section titled “ SECTIONS 44703 AND 4 4711 OF TITLE 49 OF THE UNITED STATES CODE (49 USC) : AIRMAN CERTIFICATE REQUIREMENTS ”

. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely

controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a co mmercial pilot’s certificate operating a

conventional aircraft. The risks associated with the operation of the sUAS are so

diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operation s of the sUAS as requested by the applicant exceeds the present level of safety 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 airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for dete rmining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety checklists prior to each fligh t, as set forth in Sections

9.1 and 9.6 , an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 11 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 of this 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 su ch a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at

the ground c ontrol point where the pilot flying 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, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 9 1.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft

, an exemption will be needed. An equivalent level of safety will be provided as set forth in Sections 8 and 9 of the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances

, and aircraft performance data before initiation of flight.

14 C.F .R. §91.109: Flight instruction

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 ful ly functioning dual controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for fl ight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers wil l be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes 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 altitu des up to 400 AGL, or not more than 200 above an elevated platform from which operation is planned, anUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 12

exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 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 of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notic e to the property owner and participants in the mission , all affected individuals will be aware of the planned flight operations as set forth in Section 6 .2

, 8 .1, and 8.2 of the Manual. Compared to flight operations wi th aircraft or rotorcraft weigh ing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the Airborne Photographic, Video, Inspection and

Sensor Data Collection services capacity . In addition, the low

- altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available b efore 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 of safety will be achieved by the operat or, pursuant to the Manual and safety check list, confirming the altitude of the 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 u nless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that f or at least 30 minutes; or (2) a t night, to fly

after that for at least 45 minutes.”

The battery powering t he sUAS provides approximately 30 minutes (rotorcraft)

and 6 0 minutes (fixed wing) of powered flight. To meet the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approx imately 10 minutes (rotorcraft) and 3 0 minutes (fixed wing) 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.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 13 Applicant believes that an exemption from 14 CFR §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 or official 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 91.151(a) was int ended to alleviate given the size and speed of the small UAS. Additiona lly, limiting sUAS flights

based on 30 minutes reserve would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety c an be achieved by limiting flights to 2 0 minutes (rotorcraft) and 60 minutes (fixed wing) or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limi ted operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (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 it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness

c ertificate required by paragraph (a) of this section or a special flight

authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground cont rol point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 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 Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between requiredUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 14

inspections, except as provided in paragraph (c) of this section, have discrepancies repaire d as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section s and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as

referenced in the Manual (See Sections 8.6 and 9 )

. An equivalent level of safety will be

achieved because these small UASs are very limi ted in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the oper ator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the

aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety.

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. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commercial operations of sUASs in the Airborne Photographic, Video, Inspection and Senso r Data Collection services and will

enhance safet y by reducing risk. Conventional Airborne Photographic, Video, Inspection

and Sensor Data Collection services , using jet or piston power aircraft, operate at extremely low altitudes just feet from the infrastructure being inspected and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs

, carrying large amounts of jet A or other fuel

. Such aircraft must fly to and from t he work location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the

reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the

worksite and not flown. The sU AS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.UAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 15 The operation of small UASs, weigh ing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equi valent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, a nd in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property w ith the property owner’s prior consent and knowledge. Airborne Photographic, Video, Inspection and Sensor Data

Collection services will be performed for people who have also consented for work to be performed or otherwise have agreed to be in the area where UAS flight will take place.

Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and populated ar eas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS in the Airborne Photographic, Video, Inspection and Se nsor Data

Collection services and capacity pursuant to the Manual appended hereto.

Sincerely,

Michael Tranchitella

CEO UAV

- Assistance LLCUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 i

Appendix 1

1.1

– DJI Inspire 1

D u e t o thei r file siz e
, all Ma nua l s an d a ll techn ical inf o rmati on c an be fo und at : http://www.dji.com/product/inspire

- 1/download

1.2

– DJI Inspire 1 Pro and RA W

Due to their file size, all Manuals and all technical information can be found at: http://www.dji.com/product/inspire

- 1

- pro

- and

- raw/info#downloads

1.3

– DJI Phantom 3 and 4

D u e t o thei r file siz e
, all Ma nua l s an d a ll techn ical inf o rmati on c an be fo und at : http://www.dji.com/product/phantom

- 3

- pro/info#downloads http://www.dji.com/product/phantom

- 4/info#downloadsUAV

- Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 ii

1. 4

– Event38 E384

See Attached Flight Manual:

E384 Manual

Appendix 2

Please see the atta ched:

sUAS Operating Manual

sUAS Pre

- Flight Safety Checklist