U.S. 

### Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 5 October 2015

Re : Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe 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 ofwhich 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 with in 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 afterexperiencing certain in-flight failures. Ifa lost-link event occurs, including the loss of ground communications and/or the loss ofa 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 ofWaiver 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 ofthe 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 ofthe 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 in itial training. Due to the simplicity ofthe 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 ofthe 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 ofthis 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 ifyou require additional information or clarification. Sincerely,



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# ~ Chief Pilot, Joshua 10:8 Inc. Append ices: A
. E xemption Request and Eq uivalent L evel of Safety B. Privacy Issues C. Safety Assessment D. Use r M anuals E. Training Program