Augus t 10, 2015

Exemption No. 12399 Regulatory Docket No. FAA

– 20 15

– 1042

Mr. Aaron Nettles Auxiliary Drones, LLC Lawton, OK 73505

Dear Mr. Nettles :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and lim itations of the exemption, including the date it ends.

By letter dated April 7, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Auxiliary Drones, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial surveying, remote sensing, filmmaking, photography, inspections, monitoring, and education

and research

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI S900

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the2

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Su bpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitio ner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public inte rest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Ex emption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Auxiliary Drones, LLC is granted an exemption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Auxiliary Drones, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S900 w hen weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permit ted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or
U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and

limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, 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 of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be5

operated under this exemption, including evasive and emergency maneuvers and

main taining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operat ions may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport sy mbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management mus t be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibi ted from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to co nduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification6

(N− Number) ma rkings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating 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. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensurin g the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property w ith permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTS B) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditi ons and limitations apply.7

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the f ollowing:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the lis t of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over wh ich filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in t he exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.8

This exemption term inates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresU.S. Department of Transportation April 7, 2015

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590



### Auxiliary Drones, LLC.

Section 333 Petition to Operate

Small Unmanned Aerial Systems

Prepared by:

Aaron Nettles

580

- 215

- 9555

aaron_nettles@yahoo.com

Petition Summary:

Pursuant to Section 333 of the FZZ Modernization and Reform Act of 2012, Pub. L. No. 112

- 95

(2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“FAA”) general

exemption authority under 49 U.S.C. section 44701(f), Aaron Nettles (“Petitioner”) hereby petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14

C.F.R. Part 27

(Airworthiness Standards: Normal Category Rotorcraft), 14 C.F.R sections 61.113(a)

- (b)

, 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a)

-

(b).

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of

small unmanned aircraft systems (“UAS”) meeting or exceed ing all of the operational and safety

requirements Congress has set forth in Section 333.Petitioner is an aviation technology company that plans to exploit the capabilities of Unmanned

Aerial Systems to offer a multitude of services, including:

--- Aerial surveying

--- Remote sensing

--- Telecommunications

--- Agriculture

--- Aerial filmmaking and photography

--- Energy systems inspections and asset management

--- Construction site inspections and monitoring

--- Wildlife and forestry monitoring

--- E ducational and research operations

--- Pipeline inspection and patrolling

Statutory Authority

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS.

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the (comprehe nsive) plan

and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334

of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides amechanism for “expedited operation authorization” if several factors are met. Petitioner meets

all requirements to permit FAA approval of commercial UAS operations.

3

The Petitioner Requests Relief from the Following:

Section 61.113(a) and (b) prescribes that

—

( a) no person who holds a private pilot certificate may act as a pilot in command of an

aircraft that is carrying passengers or property for compensation or hire; nor may that person,

for compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business or employment if:

1 The flight is only incidental to that business or employment; and

(2) 2. The aircraft does not carry passengers or property for compensation or hire.

Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning

a flight, become familiar with all available information concerning that flight, to include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed,

and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For an y flight, runway lengths at airports of intended use, and the following takeoff

and

landing distance information:(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual

containing takeoff and landing distance data is required, the takeoff and landing distance data

contained therein;

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other

reliable information appropriate to the aircraft, relating to aircraft performance under expected

values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An altitud e allowing, if a power unit fails, an emergency landing without

undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or

over any open air assembly of persons, an altitude of 1 ,000 feet above the highest

obstacle

within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be operated

closer than 500 feet to any person, vessel, vehicle, or structure.

d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is

conducted without hazard to persons or property on the surface

—

(1 ) A helicopter may be operated at less than the minimums prescribed in paragraph (b)

or (c) of this section, provided each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less

than the minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising

altitude by refere nce to an altimeter that is set “to the elevation of the departure airport or an

appropriate altimeter setting available before departure.”Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR

conditions unless (consider ing wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to

fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.

[emphasis added]

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that

aircraft inspected as prescribed in subpart E of the same part and shall, between required

inspections, except as provided in p aragraph (c) of the same section, have discrepancies

repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has

undergone maintenance, preventive maintenance, rebuild ing, or alteration unless it has been

approved for return to service by a person authorized under § 43.7 of the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless,

within the preceding 12 calend ar months, it has had an inspection for the issuance of an

airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that

—

(a) Each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved

inspections, as appropriate, for ea ch aircraft (including the airframe) and each engine,

propeller, rotor, and appliance of an aircraft. The records must include

—

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller

,

and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time bas is.

(iv) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which the aircraft

and its appliances are maintained.

(v) The current status of applicable airworthiness directive s (AD) and

safety directives including, for each, the method of compliance, the AD or safety

directive number and revision date. If the AD or safety directive involves recurring

action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors, propellers,

and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1 ) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to serviceUnmanned Aircraft System

The petitioner states that the unmanned aircraft (UA) to be operated under this request is less

than 55 lbs. fully loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor

passenger, carries no explos ive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the POH. The craft is the S900 six

- rotor manufactured by

DJI. The VTOL hexarotor

- type design has six motors, GPS, full autonomous autopilot

capabilities, telemetry and manual ground control.

In addition, the craft has integrated safety features built into the design of the UAS, as described

in the POH, to ensure the safety of persons and property within and surrounding the limited

operating area. The petiti oner further describes that, in the event the UAS loses

communications or its GPS signal, the UA will have the capability to return to a pre

- determined

location within the Security Perimeter and land. It will also have the capability to abort a flight in

t he event of unpredicted obstacles or emergencies.

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part

47, and have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart

C. Markings will be as large as practicable.

Pre

- flight Inspection, Maintenance

Before each flight the PIC will perform a series of pre

- flight and takeoff checks as defined by the

POH supplied. After each 60 minutes of airtime, the craft will undergo a thorough inspect ion of

all aircraft components, including, but not limited to:

a. Actuators / Servos

b. Motors, wiring and connectors

c. Propellers, smooth, no chips

d. Electronic speed controller, wiring and connectors

e. Batteries, wiring and connectors

f. Remote comman d and controlg. Ground control station

UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in

daytime VFR flight conditions and all operations will be conducted with the assistanc e of a

second spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet AGL.

Altitude is accurately measured by GPS. The petitioner further states that an operator will

ensure that only consenting production personnel will be allo wed within 100 feet of the UA

operation, and UAS will be kept at least 100’ from any inhabited structure. Generally the

petitioner’s UAS will be operated in rural or suburban areas that will permit significantly larger

safety zones.

Flight Standards District Offices (FSDOs) will be notified as required prior to operations to

describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic

Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting

any operations under this grant of exemption. In fulfilling its requirements under the COA,

Petitioner will be required to request a NOTAM not more than 72 hours in advance, but not less

than 48 hours prior to the operation

Petitioner’s UAS wi ll remain clear and yield the right of way to all manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, and hangliders). Petitioner will not conduct UAS operations w ithin 5

nautical miles of the geographic center of a non

- towered airport unless a letter of agreement

with that airport’s management is obtained and the operation is conducted in accordance with a

Notice to Airmen (“NOTAM”).

Pilot in Command (PIC)The p ilot in command will Aaron Nettles, he received his airman’s private certificate in 2014 and has logged over 300 hours in a multitude of aircraft.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply with

the othe r applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the

PIC will take all actions including reviewing weather, flight battery requirements, aircraft

performance data, and landing and takeoff distances before initiation of a flight. The PIC will

also account for all relevant site

- specific conditions in their preflight procedures. Risks

presented by sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and

initiate a return

- to

- home sequence if nee ded.

Radio Frequencies

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle

control in unlicensed frequency bands. All devices used will comply with FCC usage and

emissions regulations.

Safety and Benefits of the UAS

The petitioner will be using the UAS in a variety of applications that generally require expensive

full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad

benefits over the use of full

- sized manned aircraft for elec tric power line inspection, oil/gas

pipeline inspection, advanced agriculture, film and still photography, just to name a few.

Replacing significantly larger manned aircraft carrying crew and flammable fuelwith small UAS

carrying no passengers or crew crea tes a much greater margin of safety for the pilots and crew.

By granting Petitioner’s requested exemptions, the FAA will help drive development of safe and

successful commercial UAS operations and will advance the public knowledge base for suchoperations. Petitioner is committed to promoting the UAS research efforts of policymakers

including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS

operations and serving as a resource for future UAS research operations. Thus, the FAA has

good ca use to grant this Petition.

Conclusion

For the foregoing reasons, the exemptions requested herein should be granted and Petitioner

should be permitted to conduct small UAS operations in accordance with its manuals and all

other operating parameters deemed necessary and appropriate by the FAA.