U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

5 October 2015 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations 

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, Joshua 10:8 Inc, seeks an exemption from 

Federal Aviation Regulations ("FARs") detailed below for the Walkera Scout X4, 

Walkera QR X350 Pro, and DJI Inspire 1. 

The requested exemption would support an application for a commercial Certificate 

of Authorization {COA} to use the system to support aerial surveying, aerial 

photography, Agriculture, wildlife and forestry monitoring, wild land firefighting 

support, patrolling, aerial Inspections, real estate surveying, crew member training, 

and mapping operations. By approving these exemptions, the FAA will -support 

various industries, benefit the environment and build a new profession, all of which 

are in the public interest. 

Each UAS weighs less than 55 lbs. fully loaded, will be operated at a speed no more 

than 87 knots, carry neither a pilot nor passenger, carry no explosive materials or 

flammable liquids, and operate exclusively within an approved COA airspace. All UA 

Systems use a radio frequency spectrum for operation and control that complies 

with Federal Communications Commission ("FCC"} requirements and has integrated 

safety features as described within user manuals for each UAS. The UAS are 

equipped with redundant safety mechanisms allowing them to operate safely after 
experiencing certain in-flight failures. If a lost-link event occurs, including the loss of 

ground communications and/or the loss of a GPS signal, the UAS have the ability to 

perform a pre-coordinated, predictable, automated flight maneuver and return to a 

predetermined. location within a designated security parameter for landing. The 

UAS further have the ability to abort a flight in the event of unpredicted obstacles 

or emergencies. 

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a 

ground-based Visual Observer (VO} in accordance with FAA Order 8900.1, vol. 16 

"U nmanned Aircraft Systems" with the following additional restrictions: 

./ All operations will be conducted lAW the Air Traffic Organization (ATO} 

Certificate of Waiver or Authorization (COA} . 

./ All UAS operations will remain clear of manned aviation operations and 

activities at all times . 

./ All operations will occur at altitudes no more than 400' AGL 

./ Operations will be operated over private property with the permission of the 

land owner . 

./ The UAS will not be operated by a PIC from any moving device . 

./ The aircraft will not be operated within 5 NM of an airport or heliport unless 

prior coordination with ATC or airport management is made . 

./ Operations will be limited to day, visual meteorological conditions . 

./ Aircraft will remain within Visual Line of Sight of the PIC and VO at all times . 

./ While the aircraft is airborne, the VO will be positioned within voice distance 

to the PIC 

The PIC and VO will meet the requirements outlined in FAA Order 8900.1, volume 

16, chapter 4. The PIC will hold at least a recreational or sport pilot certificate. 

Additionally, the PIC will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training. Due to the 

simplicity of the system, we do not anticipate the need for a supplemental pilot. 

We submit that the combination of the aircraft's light weight, historically 

demonstrated flight performance, fully qualified fl ight crew, and strict operation 

under the guidelines established in 8900.1~ the FAA can have confiden~e that the 

operation will have an equivalent or greater level of safety of manned aircraft 

performing the same mission. 
The name and contact information of the applicant are: 

Joshua 10:8 Inc 

Attn: Jorge Osp_ina 

Ph: 281-902-8994 

Email: .._s_pina@jos~ua~08 co It_ ~andresl919@rotrra I. com 

The regulations from which the exemption is requested are as follows: 

./ 14 CFR Part 21 

./ 14 CFR 91.203 

./ 14 CFR 45.23, 45.29 

./ 14 CFR 91.9 

./ 14 CFR 61.113, 61.133 

./ 14 CFR 91.109, 91.119 

./ 14 CFR 91.121, 91.151 

./ 14 CFR Subpart E (91.401- 91.417) 

./ 14 CFR 91.103(b) 

We 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 you require additional information or clarification. 

Sincerely, 

~ 

---- ~~ 

Chief Pilot, Joshua 10:8 Inc. 

Appendices: 

A. Exemption Request and Equivalent Level of Safety 

B. Privacy Issues 

C. Safety Assessment 

D. User Manuals 

E. Training Program