September 24,2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition ofAerospace Imagery for an Exemp tion Pursuant to Section 333 of the FAA Modernization and Reform Act of20 12 Director: Flight Standards Service: Pursuant to Section 333 ofthe FAAModernization and Reform Act of 2012 ("Reform Act") and 14 C.F .R. Part 11, Aerospace Ima gery hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation ofsmall unmanned aerial vehicles 

### (i
. e., "small unmanned aircraft" or "UAS") for the purpose ofconducting aerial photography and videography for real estate, property and agriculture surveying, precision mapping, private and public building and infrastructure inspections. This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Aerospace Imagery documents. 1. Flight Operations Manual and; 2. Operations Manuals (Collect ively referred to as Operations Manuals") 3. User Guide and; 4
. Flight ManuaP (Collectively referred to as "Manufacturer's Manual"). Aerospace Imagery submits these supporting materials as confidential documents pursuant to 14 C.F.R. 

### § 11.35(b), as the materials contain confidential commercial and/or proprietary information that Aerospace Imagery has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom ofInformation Act , 5 U.S. C. 

### § 552 et. seq. For yo ur convenience, this Petition is organized as follows: 

### I. Description of Petitioner ll. Description of Proposed Operations

1 The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including , but not limited to : operations and fljght manuals, user guides , component maintenance manuals, pilot trairung manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation September 24,2015 Page2 

### A. Aerial Digital Photography and Videography for Mapping, Agriculture Inspection Services, Property Listings and Infrastructure Inspections 

### ID. Relevant Statutory Authority IV. Aerospace Imagery's Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act A Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals 

### V. Regulations From Which Exemption is Requested A. 14 C.P.R. Part 21, SubpartH- Airworthiness Certificates and 14 C. FR. 

### § 91.203(a)(1) B. 14 C.P.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.P.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.P.R. 

### § 91.405(a), 91.407(a)(I), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.P
.R. Part 61, 14 C.P.R. § 61.3 , 14 C.P.R. § 61.113: Private Pilot Pri vileges and Limitations F. 14 C .P.R.§ 91.7(a): Civil Aircraft Airworthiness G. 14 C
.P.R. § 91.9(b)(2): Civil A ircraft Flight Manual in the Aircraft and 14 C.P.R. 

### § 91.203(a) and (b): Canying Civil Aircraft Certification and Registration H. 14 C.P.R. § 91.103: Preflight Action I. 14 C.P.R. 

### § 91.1 09(a): Flight Instruction 

### J. 14 C.P.R.§ 91.119(c): Minimum Safe Altitudes 

### K. 14 C. F.R. § 91.121: Altimeter Settings L. 14 C.P
.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

### Vl. Drug and Alcohol Program Vll. Public Interest Vlll. Privacy IX. Federal Register Summary X. Conclusion I. DESCRIPTION OF PETITIONER Aerospace Imagery, based in Laguna Beach, CA provides aerial digital photography and videography for the real estate, construction and agriculture industries as well as property mapping and infrastructure inspections. The Company's Principal and ChiefPilot Steve Price has been flying UAV Quadcopters and other radio controlled aircraft as a hobby for more tban twenty years without incident, spending thousands of hours flying.U.S Department ofTransportation September 24 , 2015 Page 3 Upon the grant ofthe 333 E xemption the Aerospace Imagery will specialize in aerial digital photography and v ideography for the rea l estate , agriculture and construct ion industries. Its staff are well trained and exp erienced 

### in providing support as vis ual observers ( " VO") for the pil o t 

### in command ( " PIC " ) 

### in additi o n to any other neede d on site assistance. All ofthe equipment owned by Aerospace I magery i s ofthe highest quali ty gear and has been able to provide these services safely and without any claims or incident. Aerospace Imagery ' s goal is to advise the perspective client that Aerospace Imagery is following all the applicable state and federal rules to ensure the safety of the pub li c whi le providing the cl ient with a competitive and cost effective p rod uct. Aerospace Imagery seeks an exempt i on to allow aerial digital photography and videography for mapping, inspection services and 3D compositing
. The contact information for Petitioner is as fo llows: James Costa Aerospace Imagery 609 Sleepy Hollow Ln , Ste
. 19 Laguna Beach, CA 92651 Phone: 949
.201.5771 : E mail: aero spaceimagery @ gmail.com 

### ll
. D E SCR IPTIO N O F PROPOSE D OPE RA TION Aerospace Imagery seeks an exemption pursuant to Section 333 ofthe Reform Act to operate 

### Dll Phantom 3 Pro ; Dfl Inspire I ; Dfl EVO S800 ; and, Freefl.y Cinestar 8 ( referred to as AIUAS) (all under 55 lbs ) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on pr ivate property or approved location where Aerospace Imagery has received verifiable permission to operate from the landowner, controller or autho rized representative. The proposed UAS op erat ions will be conducted in accordance with the condi tions and lim i tations of this Petition for Exempt ion and Aerospace Imagery ' s Opera tions Manual s . As detailed in Aerospace Imagery's Operations Manua ls , aU UAS operations will be limited to daytime VFR conditions , within visual line-of-sight ("VLOS" ) of the operator, in uncontrolled airspace, and will occur at least 5 run away from an airport reference point. Moreover , Aerospace Imagery 's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operat ions , i ncluding GPS "geo-fencing" technologies. 

### A. Ae rial Di gita l Photography and Vid eogra phy for M a ppin g, Agriculture, Infras tru cture Ins pection S ervices a nd Property Lis tin gs Aerospace Imagery seeks to use sma ll AI

-UAS for the purpose of provi ding aerial digital photography and videography fo r surveying, mapping , inspection and li sting services for their client base
. Aerospace Imagery has purposefully tailored its operations to meet the requirements e stablished by the FAA in prior grants ofexemption authorizing commercial use ofUAS in the real estate industry , including:

• Trudeau , Realtor® (Exemption No
. 111 38) • Alon S icherman (Exemption No. 1 1728)U.S Department ofT r ansportation September 24,2015 Page4

• Sokoler Medly (Exemption No. 11341 ) • Jared Oleson (Exem ption No
. 12682) • Rick Doyle Photography (Exe mption No. 12681) • Raven Executive (Exemption No
. 1 2639) All UAS r eal estate p hotography and videography operations 

### will occur on private property or approved location i n a contro lled area away from spectators and persons not involv ed in the recording p rocess. In addition, the filming wi ll be conducted between dawn and dusk to en s ure maximum safety for the public and those involved in the manipulation and operat ion ofthe UAS ; VFR conditions , at altitudes below 400 ' above ground level ("AGL " ). As set forth below , Aerospace Imagery's operations provide an e quivalent level of safety which is superior to performing the same work u s ing conventional fixed-wing aircraft or helicopters. Small UAS real estate video production is also safer than traditional manned aircraft performing the same function
. Videographer-inspectors also frequently need to c limb rooftops, trees , or otherwise perform e l evat ed work, whi c h exposes them to the ri sk ofdangerous falls, electrocution or other work related injuries. T n addition, depending on the nature ofthe video neede d and inspection , proximity to equipment, and othe r mech anical hazards associated with industrial sites and construction facilities oft en involves a ri sk of exposure to hazardous conditions. The u se of A l-U AS mitigates these hazards and i s ultimate ly a much s af er and cost efficient method of performing these and mo st other types of inspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft 

### in lo w level operations present risks associated with vehicles weighing tens of thou sand s ofpounds ( including payload) a n d carrying large amounts offuel which inherently presents s ignificant fire hazards as well as ex po s ur e to other chemical contaminates. It is important to note the use of small UAS in thi s area will not only be safer a nd more cost effective to the perspective u ser or purchaser of the service , but the quality and expan se of acquired information will b e far more robust given the low cost associ ated with it s acquisition and other potential consumers an inexpensive product. UAS real estate video production is more reliab le , and allows for the coll ect ion, dissemination, and storage of vi sual and other sensory data wit h grea ter preci s ion and duration at a very low cost. Sma ll UASs will also be capable of accessi ng and inspecting areas that would otherwise be inaccessible or highly dangerous using convention al aircraft or other inspection methods
. 

### ill. RELEVANT STATUTORY AUTHORITY T hi s Petitio n for Exemption is s ubmitted purs uant to Section 333(a) throug h (c) ofthe FAA Modernization and Reform Act of2012 ( "Refonn Act "). Congress has directed the FAA "to safely accelerate the integrat ion of civi l unmanned aircraft systems into the national airspace system ." Pursuant to Section 333 of t he Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is s afe to do so based on the following considerations :
• The UAS's s ize, weight, speed and operational capability ; • Operation of the UAS in clo se proximity to airports and populat e d areas ; andU.S Department ofTransportation September 24 , 20 15 Page 5

• Operation of the UAS within the visual line of sight ofthe operator. Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S. 

### C. § 106(f) (defining the authority ofthe Administ rator) ; 49 U.S
. 

### C. § 4470l(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702

- 44716 , et seq .)
. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole , and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). IV. 

### AEROSPACE IMAGERY'S PROPOSED AI-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT The small AI-UAS operations proposed by Aerospace Imagery as noted above in thi s Petition for Exemption qualify for expedited approval pursuant to Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. 

### A. Approva l is Warranted Based on the 

### VAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The AI

-UAS utilized by Aerospace Imagery has been approved for use in prior Section 333 Grants ofExemption from the FAA. 2

• The AJ-UAS weighs less than 55 pounds, including payload
. • The AI -UAS will not be flown at a ground speed in excess of 50 knots. The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction
.
• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter , radio altimeter, or any combination thereof. This information will be transmitted to the pilot via telemetric data feed
. • The AI-UAS will have system redundancies and independent functiona lity to ensure the overall safety and predictability ofthe system. 

### Ifconnection to the remote control or ground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land without injury or damage.

• The radio frequenc ies used for operations a nd control ofthe AJ

-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government

2 See e .g ., Grant ofExemption to Trudeau , Realtor® (Exemption No
. II 138) ; Grant ofExemption to Alon Sicherman (Exemption No. 11728); Grant ofEx emption to Sokoler Medly (E x emption N o . 11341 )
.U.S Department ofTransportation September 24, 20 15 Page6

oversight agency requirements. The operating frequency for the AI-UAS is 2
.4 GHz frequency bands. If the same operations were conducted using a helicopter , the aircraft's take-off weight would likely exceed 6 , 000 pounds depending on payload. The difference in weight between the AIUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property 

### in the event of an unintended accident or incident. 

### In addition, the risk to the onboard pilot and camera operator is eliminated. 

### B. Approval is 

### Warranted Based on the Operational Restrictions Set Forth in Aerospace Imagery's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected AI-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Aerospace Imagery ' s proposed operations, below is a summary ofoperational limitations and conditions that Aerospace Imagery will adhere to , and which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: 

### 1. The AI-UAS weighs less 

### than 55 pounds , with payload
. 2. All operations shall be conducted over private or controlled-access property with verifiable permission from the land owner /controller or authorized representative
. Permission from land owner /controller or authorized representative 

### will be obtained for each scheduled flight prior to operation. 3
. All UASs operated under the Grant ofExemption will be identified by seria l number , registered 

### in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 4
. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in Command ("PIC") ofthe AI-UAS , and one or more Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a private ,**recreationa~** or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory , a possession, or the Federal government. The PIC will also meet the flight review requirements specified 

### in 14 C
.F
.R 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate
. 6. The AI-UAS shall be operated within VLOS of the PIC and Observer at all times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate
. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times.U.S Department of Transportation September 24, 2015 Page?
8. Electronic messaging or texting will not be permitted during flight operations. 9
. The additional requirements identified in the Grant ofExemption shall be added to the Aerospace Imagery's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. 

### Ifa discrepancy exists between the conditions and limitations in the Grant ofExemption and Aerospace Imagery's Operations Manuals, the conditions and limitations in the Grant ofExemption shall take precedence and must be followed. Otherwise, Aerospace Imagery shall follow the procedures outlined in their Operations Manuals. 10
. Aerospace Imagery may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administrator upon request. Aerospace Imagery will also present an updated and revised Operations Manuals if it petitions for extension or amendment to its Grant ofExemption. 

### Ifan update or revision would affect the basis upon which the FAA grants the exemption, Aerospace Imagery will seek an amendment to its Grant ofExemption
. Aerospace Imagery will contact the FAA's UAS Integration Office (AFS-80) 

### ifquestions arise regarding updates or revisions to the operating documents. 11. Aerospace Imagery Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the AI-UAS is operating. 12. The PIC is prohibited from beginning a AI-UAS flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first intended point of landing, an.d assuming normal cruising speed, to fly after that for at least 1 0 minutes. 13. Maximum total flight time for each operational flight using the AI-UAS will be limited to 40 minutes or the amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. 

### Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner /controller of such vessels, vehicles or structures has granted permissionU.S Department ofTransportation September 24, 2015 Page 8 and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and ;
c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a)
. 16. The AI-UAS may not be operated less than 500 feet below or less than 2 , 000 feet horizontally from a cloud or when vis ibili ty is less than 3 statute miles from the PIC. 17. The AI-UAS may not operate within 5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport ' s management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Aerospace Imagery CO A. The letter of agreement with the airport management will be made available to the Administrator upon request. 18. Prior to each flight the PIC shall inspect the AI-UAS to confirm that it is in a condition safe for flight. The pre-flight inspection wiJI account for all discrepancies, e . g . inoperable components, items, or equipment , not already covered in the relevant sections of the operating documents as well as equipment updates. The PIC shall not operate any AI-UAS iftbe inspection reveals a condition that affects the safe operation of the AI-UAS until the necessary maintenance has been performed and the AI-UAS is found to be 

### in a condition for safe flight. The ground control station shall be included in the preflight inspection
. All maintenance and alternations must be properly documented in the UAS's records as required by Aerospace Imagery ' s Operations Manuals
. 19
. Aerospace Imagery will timely carry out its maintenance , inspections, and record keeping req uir ements in accordance with the Operations Manuals. Maintenance , inspection, and alterations will be fully noted in the AI-UAS records , including total time in service , description of work accomplished, date completed and the signature ofthe authorized person returning the AI-UAS to service. 20
. Any AI-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement o f a flight critical component) must timely undergo a functional test flight in accordance with Aerospace Imagery ' s Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and AI

-UAS record entry shall be included in the Aerospace Imagery's Operations Manuals. 21. The AI-UAS 

### will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety / Service Bulletins and product updates. 22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on Aerospace Imagery ' s Operations Manuals.U.S Department of Transportation September 24, 2015 Page 9 23. Aerospace Imagery will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or Authorization, otherwise known as a COA , prior to conducting any operations under this Grant ofExemption. A NOT AM will be issued as required by the CO A. All operations will be conducted 

### in accordance with airspace requirements in the ATO issued COA including class of airspace , altitude level and potential transponder requirements
. 24. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions , including local law enforcement, fire or other appropriate governmental agencies. 25
. 

### Ifthe Al-UAS loses communication with the PIC, it will have the capability 

### to safely return to a pre-determined location within the operational area and land safely. 26. Contingency plans will be in place to safely terminate flight ifthere is a loss of communication between the PIC and the Observer. 27. The Al-UAS will have the capability to safely abort flight in the case of unpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver 's license issued within the United States
. 29. Prior to conducting operations for filming , the PIC will have accumulated and l ogged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar AI-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30
. Prior to conducting operations for filming , the PIC will have accumulated and logged , in a manner consistent with 14 CFR 

### § 61.51(b) , a minimum ofhours pursuant to 54 CFR 

### § 61.51(b) as UAS pilot operating the make and model ofAI-UAS to be uti l ized for operations under the exemption and three take-offs and three landing in the preceding 90 days
. 31. Operations s hall occur during daytime VFR Meteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The AI

-UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including , but not limited to, ultralight vehicles , parachute activities , parasailing activities , hang gliders, etc.). 33. AI-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited. 34. The UAS will not be operated from an elevated platform unless designed and engineered specifically for such purposes and be in compliance with the general restrictions imposed by the applicable regulations. Additionally no PIC will provideU.S Department of Tran sportation September 24, 20 1 5 Page 10 any film-fli ght operations while in motion from atop any elevated platform vehicle or device. 35. Before conducting operations , the radio frequency spectrum used for operation and control of the AI -U AS will comply with the Federal Communications Commission (FCC) or other a ppropriat e government o vers ight agency requirements. 

### V
. REGULATIONS FROM 

### WHICH EXEMPTION IS REQUESTED T he Federal Aviation Act expressly grants the FAA the authority to issue exemption s. This statutory authority, by its terms, includes exempting c ivil aircraft, as th e term is defmed under § 40101 ofthe Act, including UASs, from its s afety regulations and minimum standards when the Administrator decides a requested exemption i s in the public intere st.3 Aerospac e Imagery seeks an exemption from severa l interrelated prov isions of Title 14 ofthe Code ofFederal Regulations(" 14 C.F.R") Parts 2 1 , 45, 6 1 and 91 for purposes of cond u cting the requested operations using AI-UAS platforms note d above. Li sted belo w a r e: 

### (1) the specific sections of 14 C.F.R for w hich exemption i s sought, and (2) th e operating proced ures and safeguards that Petitioner has established which will ensure a level of safety b etter than or equal to the rules from which exemption i s sought. 4 

### UNMANNED AIRCRAFT SYSTEM 

### A. 14 C.F.R. P art 

### 21 , Subpart 

### H

- Airworthiness Certificates and 

### 14 C.F.R. 

### §91.203(a)(l) The F AA has stated that no exemption is needed from this section 

### if a fin ding is made under the Reform Act that the UAS selected provides an equ ivalent level of safety w he n compared to aircraft normall y used for the same application . The se criteria are met and in point of fact exceeded, and therefore n o exemption is n eeded
. 

### s If, however , the FAA d etermines that there are some charact eristics of the chosen UAS that fail to meet the requireme nts ofthe Reform Act, an exemption is requested. 

### Equivalent Level of Safety Aero space Imagery ' s use of the AI

-UAS i s safe when taking into account its size , weight, speed, and operational capabi li ty. As set forth in the description ofpropo sed opera tion s in Section IV (A) , the AI-UAS weighs less than 55 pound s, includin g pa y load and will not b e flown at a ground speed in excess of 50 knots. The AI-UAS is also equipped with sa fety features which will allow Petitioner to operate the AI

-UAS safely after experiencing certain in-flight

3 49 U.S. C. § 44 70 1 (t) (authorizing the grant ofex emption s from requirements of reguJ ati ons prescribed pursuant to Sections 44701 (a) and (b) and Sections 44702- 44716)
. 4 14 C
.F.R § 11
. 81 (e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety , or how the exemption would provide a level of safety at least equ al to that provided by the rule f rom which you seek exemption
. 5 See Grant of Exemption No
. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs . 13-14 , 22)
.U.S D epartment of Transportation Septem ber 24, 20 15 Pa ge 11 contingencies or failures as noted below. 6 7 Additionally, the AI-UAS carries neith er pilots nor passengers , carries no explo sive materials or flammable liquid fuels, or other elements identified b y Homeland Security as being prohibitive and operate exclusively within the parameters stated in Aerospace Imagery's Operations Man uals. Operations conducted under tbis exemption will be closely controlled and monitored by the PIC operator and will b e conducted in compliance with local public safety requirements , to provide security for the area of operation. Aer o s pace Imagery will al so pro vide the FAA with advance notice of all operations via NOTAMs as required by the applicable CO A. In all cases, operation ofthe AI- UAS under the proposed conditions will be at least as safe as , or safer than, conventional rotorcraft operating with an airworthiness certificate. Lastly, the AI

- UAS do not need a means to conununi
. cate with other aircra ft or ATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the AI-UAS. 8 In addition , no sen se-and-a voi d technology i s necessary for th e Al

-UASs because they will be opera ted at all times in VFR conditions and within VLOS of the PIC and Operator. 9 

### B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.P
.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To th e extent that Aero space Imagery 's small AI

-UAS would otherwi se require certification under Part 27, Petitioner seeks an exemption fro m Part 27 1s airwortbiness standa rds for the same reasons id entified in the request for exemption from 14 C.P.R. 

### R. Part 2 1, SubpartH, 

### supra. 

### C. 14 C.F.R. §§ 91.9(c) , 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

6 See e .g . , Grant ofExemption No. 1 11 84 to Low Country RC, Corp
. (FAA

- 2014

- 0803 at pg . 3): "The [DIT SlOOO] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an auto
pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, predictable , automated flight maneuver , and manual flight control functionality as a backup
. These safety features provide an equivalent level of safety compared to a manned aircraft performing a similar operation
. " 7 See e.g ., Grant of Exemption N o . 11184 to VDOS Global , LLC. (FAA-2014-0382 at pgs. 4-5): The AI-UAS can be operated entirely by a touch

- screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The AI

-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fl y over . The petitioner states further that the UAS has built- in intelligent fault handling which allows the AI-UAS to detect a system fault while in the air and automatically fly back to its takeoff location and land
. Faults that can be detected include: loss of communication; exceeding pre-set wind thresholds ; and low battery levels
. All flight operations are g lobal positioning system (GPS) controlled , making the system easy to navigate
. At any po

int if the operator is not expli citly commanding the system to move, the system automatically holds its GPS position
. The flight control system employs not only GPS positioning but a variety of sensors including sonar , barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded
. Also a flight termination link - to prevent a ' fly away ' or other potentially dangerous situation- is available to the operator." 8 S ee Grant ofExemption N o . ll062 to Astraeus Aerial (FAA-2014-0352 at pg. 13). 9

. IdU.S Department o f Transportation September 24, 201.5 Page 1.2 Aerospace Imagery seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. 

### §§ 91.9(c), 45
. 23(b) and 45.27(a)
.
• 14 C.P.R. 

### § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 4 5 of this chapter.

• 14 C.F.R. 

### § 45.23(b), Markings of the Aircraft, states: 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 l etters not less than 2 inches nor more than 6 inches high, the words "limited, " "restricted," "light

- sport, "experimental," or "provisional , " as applicable.

• 14 C.F.R. 

### § 45
.27(a), Rotorcraft, states: Each operator of a rotorcraft must di splay on that rotorcraft horizontally on both surfaces ofthe cabin , fuselage , boom, or tail the marks required by 

### § 45.23. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings 

### in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable. " 10 

### Equivalent Level of Safety All AI-UAS flown by Aerospace Imagery will bear N -number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11 

### D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2); 91.417(a) and (b): 

### Maintenance Inspections Aerospace Imagery seeks an exemption from the maintenance inspection requirements contained 

### in 14 C.F.R. 

### § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43
. See , e .g ., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed 

### in subpart E of this part and shall between required inspections
.. .have discrepancies repaired as prescribed in part 43 of this chapter"). An e xemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworth iness ce rtificat e, which the UASplatforms to be operated under this grant of exemption will not have. (Emphasis added) lO. FAA Docket No
. FAA-2014-0352
. 1 1. See, e .g. , FAA Docket No
. FAA-2014-0352, at 14
.U.S Department ofTransportation September 24 , 2015 Page 13 

### Equivalent Level of Safety An equivalent level of safety will be achieved or exceeded because maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Aerospace Imagery's Operations Manuals , the PIC will conduct a pre-flight inspection ofthe AI-UAS and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe AI-UAS and no flights will occur unless , and unti l, all flight critical components oftbe AI-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement of any flight-critical components. As required by Aerospace Imagery's Operations Manuals , the PIC who conducts the functional test flight will make an entry in the AI

-UAS aircraft records ofthe flight. Aerospace Imagery's Operations Manual also includes requirements to follow the manufacturer ' s UAS aircraft /component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionjcs and control surfaces (including ailerons/elevons), structures 

### & airframe, camera system, e lectrical systems (including batteries) , ground control station, hazard accessories, and spare parts. Further, Aerospace Imagery's Operations Manuals also include procedures to document and maintain a record ofthe AI-UAS ' s maintenance, preventative maintenance, alterations, status of replacement /overhaul component parts, and the total time in service ofthe AI-UAS used under this Grant of Exemption
. As a whole, the maintenance and inspection procedures required in Aerospace Imagery's Operations Manuals ensure that an equivalent or higher level of safety will be achieved. Pll.,QT

-IN-COMMAND OF THE UAS 

### E. 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations Aerospace Imagery seeks exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate
. The purpose ofPart 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC wiJI be operating , as well as requiring certifications if the private pilot is carrying passengers or cargo for hire
. 

### In this case , while the AI-UAS will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant ofExemption to Astraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Ce
. rtificate and Class 

### ffi Medical Certificate
. 12 The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved
. 

### Equivalent Level of Safety

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).U.S Department ofTransportat ion September 24, 2015 Page 14 The restrictions Aerospace Imagery has placed on its AI-UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. Aerospace Imagery will operate on private property away from persons and property not involved in the operation. Aerospace Imagery will also obtain an ATO issued COA prior to conducting any operations under this Grant of Exemption
. A ll operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude Level and potential transponder requirements. A NOTAM will also be issued as required by the applicable COA. In addition to these flight restrictions, Aerospace Imagery will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects ofAI-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in AI-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf of Aerospace Imagery . The pilot qualification, training, and currency requirements 

### in the Operations Manuals ensure that Aerospace Imagery pilots are competent and proficient in the AI-UAS they are operating. Aerospace Ima gery's training and qualification requirements are consistent with those contained 

### in prior FAA Section 333 Grants ofExemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety to the public. 

### OPERATING PARAMETERS OF THE UAS F. 

### 14 C.F.R. 

### § 91.7(a): Civil Aircraft Airworthiness Inasmuch as there 

### will be no airworthiness certificate issued for the UASs, Aerospace Imagery seeks an exemption from 14 C.F
.R. 

### § 91.7(a), which requires that a civil aircraft be 

### in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. 

### § 91.7(a) to the extent that the requirements ofPart 21 are waived or found inapplicabJe. 13 Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with Section V (A), supra. 

### G. 14 C.F.R. 

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

### § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration Title 14 C.F.R. 

### § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R § 91.9(b) (2) : (b) No person may operate a U.S.-registered civil aircraft- (2) F or which an Airplane or Rotorcraft Flight Manual is 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. Pursuant to 14 C.F.R. 

### § 91.203(a) and (b):

13 See Id
. at 13-14 , 22
.U.S Department of Transportation September 24, 20 15 Page 15 (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 (a) ofthis 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. Given the small size and configuration of the AI-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the AI-UAS because there is simply no room and the AI-UAS has no cabin or cockpit. As a way to comply with the code Aerospace Imagery will maintain the documents with the PIC and make them available for inspection. 

### Equivalen t Level of Safety In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean 

### E. Griffith, Attorney, AGC-220, i.t was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met 

### ifthe pilot ofthe unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies , the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS. 

### H. 14 C
. F.R. 

### § 91.103: P r efligh t Action Aerospace Imagery seeks an exemption from 14 C.P.R. 

### § 91
. 103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will be fami liar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.


### Equivalent Level of Safety An equivalent level of safety will be provided by following the Aerospace Imagery ' s Operations Manuals and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or inoperable components in accordance with the Aerospace Imagery's Operations Manuals, including checklists covering Pre

-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency landing areas- before initiation offlight. Aerospace Imagery's Operations Manuals and the Manufacturer's Manual will

1 4 Memorandum from Mark Bury , FAA Assistant Chief Counsel for International Law , Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8 , 2014) ; see also DocketNo
. FAA-2014-0352 at 16-18
.U.S Department ofTransportation September 24, 2015 Page 16 be kept at the ground control station and will be accessib le to the PIC at all times while operating the UAS. 

### I. 14 C
. F. R. 

### § 91.109(a): Fl igh t Instruc tion Aerospace Imagery seeks an exempt ion from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o person may operate a civil aircraft (except a manned free ball oon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that communicates with the aircraft v ia radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. 

### § 91.109(a). 

### Equival ent Level of Safety Given the size and speed ofthe UASs that Aerospace Imagery intends to use, an equivalent level of safe training can still be performed without dual control s because no pilot or passengers are aboard the UAS, and as required by the Aerospace Imagery's Operations Manuals, all persons will be a safe distance away 

### in the event that the UAS experiences any difficulties during flight instruction
. Moreover, as required by the Aerospace Imagery's Operations Manuals , all flight training will be conducted 

### in controlled and sterile environment. As a whole, the safety procedures provided for 

### in Aerospace Imagery ' s Operations Manuals ensure that the proposed UAS operations provide an equivalent or higher level of safety than that provided by the flight instruction regulations. 

### J. 1 4 C.F.R. 

### § 91.119(c) : Mini mum Safe Al titudes Aerospace Imagery requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119(c). 1 5 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure 

### in non-congested areas. See 14 C.F.R. 

### § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

### An exemption is required because the proposed AI-UAS operation will normally need to occur below 400 feet AGL. In circumstances where the AI-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the AI

-UAS will not be operated more than 100 feet above the highest point on the structure , and within 50 feet horizontally ofthe structure. Additionally , due the nature ofthe proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the AI-UAS. 

### E quivalent Level of Safety

15 Relief from§ 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event of a failure
. Petitioner's proposed UAS operations will not occur over congested areas , and therefore an exemption from § 91
. 119(b) will not be necessary. See e .g. , Grant ofExemption No. 11157 to Slugwear , Inc ., dbaLike on a tree Aerial (FAA-2014

- 0534 at 15).U.S Department ofTransportation September 24, 2015 Page 17 Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel with the above noted UASs , any risk associated with these operations is far less than those which presently exist with conventional aircraft
. 

### An equivalent level of safety will be achieved given the size, weight, and speed of the AI-UAS, as well as the controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below , or when inspecting a U.S. structure whose height exceeds 400 feetAGL, within 100 feet above the highest point on that structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals, the AI-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person is in a position where be or she is shielded from the AI-UAS and any possible debris resulting from its failure. As required by the Operations Manuals , flights will be terminated if a nonparticipating person within 500 feet ofthe AI-UAS leaves a shielded position
. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner /controller timely has granted pennission and the PIC has made a safety assessment of the risk ofoperating closer to those objects and , operations near the PIC or Observer will not present an undue hazard per§ 91.119(a). Adherence to these restrictions in Aerospace Imagery 's Operations Manuals will ensure operations can be conducted without compromising public safety. t6 

### K. 14 C.F
.R. 

### § 91.121: Altimeter SettiDgs Aerospace Imagery seeks an exemption from 14 C .F. R. § 91.121 , which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter , but rather a GPS altitude read out. 

### Equivalent Level of Safety The FAA has stated that an equivalent level of safety to the requirements of 14 C.P.R. §91.121 can be achieved 

### in circumstances where: (1) the UASs will be operated below 400 feet AGL or below 17
, (2) within VLOS, (3) where GPS based altitude information is relayed 

### in real time to the operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS. 1 s

1 6See e.g., Grant ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19) : "If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident , then the UA may operate closer than 500 feet to persons afforded such protection
. The operator must also ensure that nonparticipating persons remain under such protection
. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately
. When considering bow to immediately cease operations , the primary concern is the safety of those nonparticipating persons . In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner /controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment of the risk of operating closer to those objects and determines that it does not present an undue hazard
. " 17 If the height of the structure being inspected exceeds 400 feet AGL , the UAS will not be operated more than 100 feet above the highest point on the structure . 18 See Grant ofExemptionNo
. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation September 24,2015 Page 18 The AI-UAS that Aerospace Imagery intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Aeros pace Imagery ' s Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation
. Like prior FAA Sect ion 333 Grants ofExemption, the AI-UASs Aerospace Imagery intends to use , and the safety mitigation procedures contained in the Operations Manuals , both ensure that an equivalent level of s afety or greater level will be achieved, and a Grant of Exemption to the requirements of§ 191
. 121 i s therefore appropriate
. 

### L. 

### 14 C .F.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions Aeros pace Imagery request s an exemption from 14 C.F.R. § 9 1.151 ( a)'s fuel requirements for flight in VFR conditions. Section 91
. 151 states : (a) No person may begin a flight in an airp lane under VFR condition s unless (considering w:ind and forecast weather conditions) there is enough fuel to fly to the frrst point of intended landing and, assuming normal cruising speed

- ( 1) During the day, to fly after that for at least 30**minutes ~**  or (2) At night, to fly after that for at least 45 minutes. Here , the technological limitations on UAS battery power means that no meaningful flight operations can be condu cted whi le still maintaining a 30-minute battery reserve. An exemption from the fue l requirements of 14 C.F.R. § 91. 1 5 1 (a) is therefore required. Moreover , it is not Aerospace Imagery's intention to fly the AI

-UAS at night. 

### Equivalent Level of Safety In the Grant ofExemption to VDOS (Exemption No. 11112), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a AI

-UAS flight unless (consi dering wind and forecast weather conditions) there was enough power to fly to the first intended point oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the AI

-UAS provide approximately 50 minutes ofpowered flight (w:ith payload) and provided battery level and batt ery time remaining in minutes and seconds to the PIC
. 1 9 The FAA also considered the fact the AI-UAS operating manual states : " start every flight w:ith a fully charged battery in the aerial vehicle", and that in the event that the Al -U AS should run lo w on power , the PIC will be alerted and can safely land the- AI

-UAS a s soon as possible. Like the VDOS Grant ofExemption, Aerospace Imagery's use ofthe AI

-UAS , combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level of safety can be achieved and in fact exceeded
. Similarly, in the Grant ofExemption to Alan Purwin (Exempt ion No. 11161) , the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a flight with the UA unless (considering wind and fo recast weather conditions) , there was enou gh power to safely fly at

1 9
. Grant of Ex emption No . 1 1112 to VDOS Global , LLC (FAA-2014

- 0382 at 10)
.U.S Department of Transportation September 24,2015 Page 19 normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. Aerospace Imagery will adhere to this limitation for its AI

- UAS flights. The AI-UAS includes a low battery warning system and the amount of battery reserve power remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from the AI-UAS to a ground-based-on-screen display. 2o As required by Aerospace Imagery's Operations Manuals, the PIC will promptly fly the AI-UAS back to the home launch location or pre-determined abort location where it may safely land , while still maintaining a minimum of 25% reserve battery power . Aerospace Imagery submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that flights only be conducted w ithin a secure, isolated area, using a UAS weighing less than 55 pounds, and within VLOS ofthe PIC and Observer(s), ensure that the proposed operation will provide an equiva lent or higher level of safety to the public to that provided by the regulations from which exemption is sought. 

### VI. DRUG AND ALCOHOL PROGRAM Aerospace Imagery will have policies in place to ensure that no person may participate in AlUAS flight operations if they are under the influence of alcohol or any drug. 

### Vll. PUBLIC INTEREST The public int erest wilJ be served by granting Aerospace Imagery's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act-the FAA Administrator's assessment ofwhether certain UAS may operate safely in the NAS before completion of the statutorily required rulemaking. The proposed AI-UAS operations in this Petition for Exemption significantly improves the safety and reduces risk ofharm, phys ical injury and property damage to the public at large, the property owners from whom permission was granted for use by Petitioner and abutting properties, staff ofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the lo cal vicinity. Traditional methods ofproviding surveillance and modeling services requires location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk of serious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors / surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, cul turally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used in the end product. The use of small UASs can eliminate these hazards and ultimately create a much safer method of performing these types of inspections creating a safer environment for the public as well as Aerospace Imagery employees.

20. The Al-UAS ground control station displays , the UAS position, navigation route, tail number, altitude, heading, north seeking arrow , range to targets, calculated target position , date/time, and sensor heading and orientation relative to the UAS
.U.S Department ofTransportation September 24 , 2015 Page20 The use of small UAS also enhances safety and reduces risk to the surrounding public because , unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore , 

### in the unlikely event of an accident, Aerospace Imagery's small battery powered AI-UAS presents significantly less danger to persons on the ground when compared to operations by conventional manned aircraft.2 1 As Petitioner's AJ

-UAS are batte
. ry powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality wi ll naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAA in prior Section 333 Grants ofExemption to filmmakers , UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree of flexibility , which supplements the current capabilities offered by manned aircraft. 22 The quality ofthe finished product is enhanced and provides a greater fmished product demand which will aid the current UAS industry and provide additionaljobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility of production ; therefore , given the lower cost, owner /operators and others in the relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC ' s . 

### VDI. PRlVACY AJJ AJ-UAS operations will be conducted 

### in accordance with applicable federal , state, and local laws regarding privacy. All operations shall be conducted over private or controlled-access property with permission from the land owner /controller or authorized representative. Permission from land owner /controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY 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: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal Regulations: Part 21 , Subpart H ; Part 27 ; 45.23(b) ; 45.27(a) ; 61.113 ; 91.7(a ); 91.9(b)(2) ; 91.9(c) ; 91.103 ; 91.109(a) ; 91.119(c); 91.121 ; 91.151(a); 91.203 (a) & (b) ; 91.405(a); 91.407(a) (1) ; 91.409(a) (1) 

### & (2) ; 91.417 (a ) 

### & (b).

21 See Grant ofExemption No. 11158 to Team 5 , LLC (FAA-2014-0783 at 12) : "Manned helicopters conducting aerial filming can weigh 6 , 000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary . The petitioner ' s UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft
. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accide nt. Risk to an onboard pilot and crew during an incident or ac ciden t i s eliminated with the use of a UA for the aerial fUming operation
. " 22 See e .g ., Grant ofExemption N o . 11178 to Picture Factory, Inc. (FAA-2 014-0794 at 18)
.U.S Department ofTransportation September 24 , 2015 Page 21 The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft , rotorcraft, or other methods. 

### X. CONCLUSION Aerospace Imagery 's Petition for Exemp tion satisfies the criteria articulated 

### in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas ; operation within VLOS and national security
. The proposed Al-UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration ofthe foregoing , this Petition for Exemption provides the FAA with more than adequate justification for granting the requested exemptions allowing Aerospace Imagery to use small AI-UAS s in the recorded production of its product. We thank you for your prompt consideration of our requested exemptions. Respectfully Submitted,

# -7**~~**

James Costa Aeros pace Imagery 609 Sleepy Hollow Ln, Ste. 19 Laguna Beach, CA 92651 Phone: 949.201.5771 Email: aerospaceimagery @ gmail
.com (The following attached items contain proprietary and commercial information exempt from disclosure under the Freedom ofInformation Act, 5 U.S. C. § 522 et seq. , and should be held 

### in a separate ftle pursuant to 14 C
.F.R. 

### § 11.35(b))
. Attachments: 1
. General Operations Manual 2
. PIC Operating Manual 3
. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8
. Preflight Checklist 9. Post Flight Checklist 10
. Equipment Checklist 

### ll. UAS Manufacturer's Manuals a . User ManualsU.S Department ofT ran sportation September 24 , 2015 Page 22
b
. UAS Maintenance Manuals