3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us 

# FAA Exemption Rulemaking Section 333 Of T he 

# FAA Reform Act and Part 11

INSPIRE 1

– sUAS - 2015

Prepared by 

## Edward A. Silva January 15, 20153691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page One Attention: United States Secretary of Transportation Mr. Anthony R Foxx 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Avia tion Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.1 09; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a) (2); 91.417 (a) & (b) Dear Mr. Secretary, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, AerialWorks, Inc., a research developer an d operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for industrial, motion picture, and television industry for scripted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulat ions (“FARs”) to allow commercial operation of its sUASs (Fixed

- wing & Multi

- Rotor), so long as such operations are conducted within an d under the conditions outlined herein or as may be established by the FAA as required by Section 333

. 1
As described mo re 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 enhance ments to the already safe operations in the industrial, film, and television production community presently using conventional and unmanned aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (th e 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.

_________________________________________________________ _______ 1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8

- Issue a Certificate of Waiver for Motion Picture and Television Filming.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Two The name and address of the applicant is: Aerial Works Incorporated Attn: Edward A. Silva Phone: 321

- 806

- 5872 Email: Edward.Silva@aerialworks.us Address: 3691 Gatlin Drive, Rockledge, FL 32955 Regulations from which the exemption is requested: 14 CFR P art 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 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)3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Three This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This 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; a nd

 Operation of the UAS within Visual Line of S ight (VLOS) of the Pilot and Observers

. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirem ents for the safe operation of such aircraft in the national airspace system.” Id. § 333 (c) (emphasis added)

.

2 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, that includes sUASs, from the requirement that all civil aircraft must have a curr ent airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation pr escribed 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. §44704; 14 CFR §91.203 (a) (1).

_________________________________________ _______________________ 2 Applicant interprets this provision to place of the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions herein for the safe operation of the UA S, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Four AerialWorks Incorporated’ sUASs are rotorcraft and fixed

- wing aircraft, weighing 55 or fewer lbs. includ ing sensor payload. They operate their rotorcraft, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They operate their fixed

- wing aircra ft , under n ormal conditions at a speed of no more than 50 knots and primarily have the flight characteristics of traditional airplanes. They will manually oper ate only in VLOS and will operate only within the sterile area described in the Confidential: Flight Operat ions Manual (F OM) attached as Exhibit 1 (hereinafter “the Manual” )

. 3 Adherence to the Manual will insure that the s UAS will “not create a hazard to the national airspace system or the public.” 4
Given the small size and weight of the sUAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within 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 restricted a reas in which the relevant sUAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the auth ority contained in the Federal Aviation Act, as amended ; the strong equivalent level of safety, surrounding the proposed operations, and significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

________________________________________________________________ 3 The Flight Operation M anu al is presented as a n applicant Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary methods and information that the applicant has no t and will not share with others. The manual reflects learned experiences, methods, operating conditions, and procedures that ar e not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et.seq. 4 Reform Ac t Section 333 (b)3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Five 

### 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 the limitations listed herein. T hese limitations provide for at least an equivalent or even higher level of safety to operations under the cu rrent regulator structure because the proposed operations represent a sa fety enhancement to the already safe movie and television filming operation s conducted with conventional aircraft. These limitations and condition to which AerialWorks agrees to be b ound when conducting commercial operations under an FAA issued exemption include:
1. The sUAS will weigh less than 55 lbs.
2. Flights will be operated manually within visual line of sight ( V LOS) of the Pilot and aircrew ( S potter / Observer, Camera / Sensor Operator)

. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve shou ld that occur prior to the 30 minute limit.
4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elev ated platform from which airborne data collection is planned.
5. Minimum two (2) man crew for each sUAS operation will co nsist of the Pilot and Spotter / Observer. In most cases the third aircrew member will serve as the Camera / Sensor Operator.
6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate and third class m edical. The Camera / Sensor Operator and Spotter (Observer) will hold at least a third class medical.
7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualificati ons, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC.
8. The sUAS will only operate within a confined “Sterile Area” as defined in the Manual. Section D of the Manual requires the establishment of a “Security P erimeter” for the flight operations areas.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Six
9. A pre

- flight briefing will be conducted in regard to the planned sUAS operation prior to each day’s production activities. It will be mandatory that all personnel who w ill 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 l ight of the requested exemption, with the appropriate Flight Standards District Office (FSDO).
11. The Operator will obtain the consent of all persons involved in the filming 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 deter mination, as required by Appendix A.3 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 (3) days before t he propose d shoot as required by Section E of the Manual.
13. Pilot, Camera Operator, and Spotter (Observer) will have been trained in operation of sUAS generally and received up

- to

- date information on the particular sUAS to be operated as required by Section J and Section 2. B of the Manual.
14. Spotter (Observer) and Pilot will at all times be able to communicate by voice, radio, and /or text.
15. Written and/or oral permission from the relevant property holders will be obtained.
16. All required permission s and perm its will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.
17. If the sUAS loses communications or loses its GPS signal, the UAS will have 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.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Seven 

### 14 CFR Part 21, Subpart H: Airw orthiness Certifi cates 14 CFR §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 w ith the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements 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 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 air worthiness certificate, 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 con ditions 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 civil aircraft, operations under this exemption will be tightly controlled and monitored by both the Operator, pursuant to safety requirements, and under the requirements and in compliance with local public safety requirements, to provide s ecurity for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television prod uction, provide a greater degree of safety to t h e 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 the re 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.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Eight 

### 14 CFR §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 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 the cabin, cockpit or pilot station on which the word “Experimental” can be place d. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on th e fuselage in compliance with § 45.29 (f). The equivalent level of safety will be provided by having the sUAV marked on its fuselage as requ ired by §45.29 (f) where the Pilot, Spotter (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 1016 7A. 

### 14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitat ions - Pilot in Command (PI C) 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 ca n achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries th e 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 t he requirements included in the Manual exceeds that provided by single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with commercial operations contemplated by Part 61 when drafted, that allowi ng operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Nine 

### 14 CFR § 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 determining airworthiness. Give n the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided. 

### 14 CFR § 91.9 (b) (2): Civil Ai rcraf t Flight Manual in the Aircraft Section 91.9 (b) (2) provides: No person ma y 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 such a flight manual on the aircra ft, 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 control point where the pilot fly ing 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 CFR §91.103: Preflight A ction This regulat ion requires each pilot in command to take certain actions before flight to in sure 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 pr ovided as set forth in Sections J and K 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.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Ten 

### 14 CFR §91.109: Flight I nstruction
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 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 flig ht training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that aircraft. 

### 14 CFR §91.119: Minim um Safe A ltitudes 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 o r altitudes pr escribed for helicopters by the FAA. As this exemption is for a sUAS that is a fixed

- wing or rotorcraft requests authority to operate at altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which filming is p lanned, an 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 ft. AGL. It will however be operated in restricted area with security p erimeter, 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, speed of the UAS as well as location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in Section K of the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presen ted with conventional aircraft operating at or below 500 ft. AGL in the movie industry. 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 co mply with Section 91.119.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Eleven



### 14 CFR § 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 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 of safety will be achieved by the op erator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

### 14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an indiv idual 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 point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR § 91.151, sUAS flight s would be limited to approximately 10 minutes 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 i s reasonable. Applicant believ es that an exemption from 14 C FR § 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 reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended t o alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Twelve Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate return the sUAS to its planned landing zone from anywhere in its limited operating area. Simi lar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.


### 14 CFR § 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 certificate required by paragraph (b) of this section or a special flig ht 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 o r to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the Pilot flying the sU AS 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 1070 0.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Thirteen 

### 14 CFR § 91.405 (a); 407 (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 required inspections, ex cept as provided in paragraph © of this section, have discrepancies repaired as prescribed in P art 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43

. Given that the se section 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 Man ual. (See Sections L and Q) An equivalent level of safety 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 of time. If mechanical issues arise the UA S can land immediately and will be operating from no higher than 400 ft. AGL. As provided in the Manual, the operator 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 aircraft in an airworthy condition to provide the equivalent level of safety.

********* Pursuant to 14 CFR Part 11, the following summary is p rovided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.1 03 (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) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in industrial, motion picture and television operations. 

### Priva cy All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Image capture of people will rarely take place, but in the event they are, they will have consented prior to being filmed or other wise have agreed to be in the area where data collection will take place.3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Fourteen Airborne Image Capture (Day & Night) With regard to airborne filming AerialWorks Incorporated ( “ AWI ” ) adheres to all FAA regulations. Fur ther AWI airborne teams operate under the principals of: Safety First, Quality Assurance, Accountability , Reporting, and Training . When approved by the FAA it is AWI’ mandate to treat all sUAS operati ons the exact same as that of conventional aircraft. Approval of exemptions allowing commercial operations of sUASs in the film industry will e nhance safety by reducing risk. Conventional film operations, using jet or piston powered aircraft, operate at extremely low altitudes just feet from the subject be ing filmed 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 f uel (193 gallons for jet helicopter shown below). Such airc raft must fly to and from film location. In contrast, a sUAS weighing fewer than 55lbs. (Inspire 1 travel case shown below) and powered by batteries eliminates virtually all of the risk given the substantial reduced mass and lack of combustible fuel carrie d on board. The sUAS is typically transported to the location via auto or cargo van in a medium sized case and is never flown to set . The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircr aft flights.

INSPRIRE 1

– SINGLE CASE W/ DUAL CONTROLLERS ASTAR 355 W/IR SENSOR MOUNTED ON TYLER SIDEMOUNT3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Fifteen The operation of small UASs, weighting less than 55lbs., conducted in the strict con ditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exemp ting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft o perate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than ground than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

DAMAGE ASSESSMENT - C ELLULAR TOWER POWER LINE - HIGH VOLTAGE SUB - STATION The primary market of interest for AWI utilizing sUASs is the visual inspections of telecommunications towers and secondary is power lines. To simulate sUAS aircraft flying at below 400 feet AWI has conducted manned aircraft data collections utilizing gyro

- stabilized systems (i.e., CineFlex, Wescam) with standard long telephoto lenses. In the cellular tower sector it is estimated the use of s UAS aircraft will reduce hazardous tower climbs by as much as forty percent (40%). Aside from reducing the number of physical climbs, the utilization of sUAS will dramatically lower the use of cranes and lifts, which also pose dangerous conditions for bui ld and repair personnel. In a number of instances, inspectors just need to get “eyes on” the tower top assemblies to look for specific deficiencies. With regard to power lines when climbers are sent in the power must be deferred. The use of sUAS may all ow these industries to fill in the data gaps where traditional aircraft are currently restricted. In addition AWI is conducting engineering research with local universities addressing a number of sUAS concerns (i.e., RF shielding, flight control range).3691 Gatlin Drive, Rockledge, FL 32955 O: 321 -806- 5872, F: 321 -978- 0330 www.aerialworks.us January 15, 2015 Page Sixteen It is anticipated that the airborne image capture process will be accomplished in both day and night environments. Currently, conventional aircraft are flown in highly populated and/or urban areas, with turbine powe red helicopters. The grant of this exemption request will provide improved safety in both day and night operations. To capture the highest quality of resolution the majority of airborne data collections will take place during the 10:00am

– 4: 00pm window. There may be night operations c onducted where infrared sensors will be deployed. If such ope rations are require d the ground facilities and the subject tower assemblies may require additional lighting so that visibility is as though it was conducted duri ng daylight hours. 

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

– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national sec urity

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS in the industrial, motion picture and television production industry pursuant to the Manual appended hereto. AWI i s eager ly standing by to support the FAA and sUAS community in its quest to establish proper regulations and protocols for the safe introduction of unmanned aircraft into the national airspace. Sincerely,

Edward A. Silva Chief Executive Officer Aeri alWorks, Incorporated