August 15, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140 Electronically Submitted via

1200 New Jersey Ave., SE www.regulations.gov

Washington, DC 20590

Regarding: The Aspect Aero, Inc. Petition for Section 333 Exemption pursuant To Section 333 

of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations 

from 14 CFR Part 21; 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); 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and

14 CFR Part 11, Aspect Aero, Inc., operator of Small Unmanned Aircraft Systems (“sUAS”), hereby

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allowcommercial

operation of its sUAS, DJI Inspire 1, DJI Spreading Wings S800, and Blade 350QX3, so long as such

operations are conducted within and under the conditions outlined herein or as my be established 

by the FAA as required by Section333.

Commercial operation sUAS, as described herein, which are equipped with cameras and sensors,

would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

• Aerial video and/or photography for public and/or private use including television, public

events, cinematography and newsgathering.

• Aerial inspection/photography of residential/commercial structures under contract with

the owners or local government authority.

• Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

• The ability to offer training to persons individually or belonging to both private and/or

public organizations that have interests in the use and application of sUAS for the purpose of

the safe operation of sUAS to enhance the safety of the National Airspace System (NAS) as 

well as for the protection ofthe persons and property.

As described below, the requested exemption would permit the operation of sUAS under controlled

conditions in the NAS that would be 1) limited, 2) controlled, 3) predetermined and 4) will provide

safety enhancements to the already safe operations in the industry presently using conventional

aircraft.

The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS

may operate safely in the national airspace system (“NAS”) before completion of the FAA’s plan 
and rulemaking to integrate sUAS into the NAS. The Act directs the Secretary to consider which 

types of sUAS as a result of their size, weight, speed, operational capability, proximity to airports

and populated areas, and operation within visual line of sight do not create a hazard to users of 

the national airspace or a threat to national security. If the Secretary determines that such 

vehicles may operate safely in the NAS, the Secretary “shall establish requirements for the safe

operation of such aircraft.”1 Aspect Aero, Inc. request for exemption falls within the Section 333 

requirements.

Given the direction of Section 333 of the Reform Act, the strong equivalent level of safety

surrounding the proposed operations, and the significant public interest benefits including the 

provision of more efficient and safer means to collect Aerial Data, Aspect Aero, Inc. respectfully 

requests that the FAA grant the requested exemption.

The name and address of the applicant is:

Aspect Aero, Inc.

Attn: David Oglesbee

721 W Glade Rd

Hurst, TX 76054

682-597-0757

ASPECT AERO, INC. CORPROATE SUMMARY

Aspect Aero, Inc. is a developer of innovative methods for collecting aerial videography and 

monitoring services utilizing safety procedures and professional approach to aviation developed by 

over 50 years of aviation experience amongst the leadership including military operations, law 

enforcement operations, commercial operations and Part 141 training operations and management. 

The company is intent on driving professional aviation management and safety management 

systems into the sUAS industry.

ASPECT AERO, INC. AVIATION EXPERIENCE AND PRIOR EFFORTS

Aspect Aero, Inc. is managed and operated by aviation professionals utilizing a vast background

with aviation operations.

David Oglesbee, the president and co-owner of Aspect Aero Inc., is a current rotorcraft certified 

flight instructor, who holds commercial and instrument rotorcraft ratings along with commercial, 

instrument and multi-engine fixed wing ratings. Flight experience comes from performing duties as 

an army aviator, chief pilot for a law enforcement agency and instructor for a major helicopter 

manufacturer.

Adam Aldous, co-owner, is a current certified flight instructor and instrument examiner and holds 

commercial and instrument rotorcraft ratings. Flight experience comes from 16 years of Army 

Aviation experience and owning a professional helicopter flight training school since 2006.

Sheldon Cohen, co-owner, has 17 years of aerial commercial photo/video production within the 

 1 Reform Act § 333(b)
aviation industry and has been awarded numerous international awards for visual production in 

the aerospace industry. Sheldon has logged more than 1000 hours of aerial flight time in 

photo/video production from manned flying aircraft platforms.

Aspect Aero, Inc. understands that the FAA and its goals of safely integrating sUAS into the national 

airspace system. As operators of both rotorcraft and fixed wing aircraft, Aspect Aero, Inc. leadership

is in a unique position to bring that level to safety to sUAS operations. Aspect Aero, Inc. is requesting

this exemption be given full consideration by the FAA.

Aspect Aero, Inc. is completely familiar with operating in a highly regulated environment. Aspect 

Aero, Inc. has a robust regulatory compliance culture and a keen understanding of the importance

of extensive security, planning, documentation and control of operations in the aviation 

environment; and as such Aspect Aero, Inc. has the unique capability of developing and exercising

the necessary procedures for safe and effective operations of sUAS in the public domain.

Aspect Aero, Inc. maintains compliance with all laws and regulations that govern its operations. 

This 333-exemption request continues Aspect Aero, Inc. commitment of compliance in working

with the FAA to serve the public interest, maintain the integrity of the NAS, and will not be a threat 

to national security.

sUAS DESCRIPTION, SPECIFICATIONS & DESIGN, AND MAINTENANCE

DJI Inspire 1

• See Attached Users Manual

DJI Spreading Wings S800 

• See Attached Users Manual

Blade 350 QX3

• See Attached Users Manual

SAFETY AND OPERATIONS

Safety

1) The sUAS PIC shall possess at least a private pilot certificate and a 3rd class medical or U.S. 

driver’s license.

a) The PIC shall also meet the flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on their pilot certificate.

b) The PIC shall be trained in the operation of the specific Make and Model of the sUAS being

piloted.

c) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 

a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at 

least ten hours logged as a sUAS pilot with a similar sUAS type (multi-rotor). Prior

documented flight experience that was obtained in compliance with applicable regulations 

may satisfy this requirement.

d) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 
a minimum of five hours as sUAS pilot operating the make and model of sUAS to be utilized

for operations under the exemption and three takeoffs and three landings in the preceding 

90 days.

e) Training, proficiency, and experience-building flights can also be conducted under this grant 

of exemption to accomplish the required flight cycles and flight time.

f) During training, proficiency, and experience-building flights, all persons not essential for

flight operations are considered non-participants, and the PIC must operate the sUAS with 

appropriate distance from non-participants in accordance with 14 CFR § 91.119.

2) The PIC and Visual Observer (VO) will be designated prior to each flight.

3) The PIC and VO will always be within visual line of sight (VLOS) of each other and in direct

verbal communication at all times.

4) Safety Briefings will be conducted before each day’s activities to include, but not limited to:

a) Designated roles of PIC and VO

b) Risk Management and Mitigation

5) Prior to the sUAS flight(s), a team comprised of the PIC and VO will visually inspect the flight 

path and surrounding area and equipment to identify potential concerns.

6) sUAS safety checklist will be completed by the review team to ensure all areas of concern have

been identified and addressed. A flight will NOT be conducted if a concern cannot be resolved.

Operations

1) The sUAS shall not operate in Class B, C, or D airspace without written approval from the

FAA. The sUAS shall not operate within 5 nautical miles of the geographic center of a nontowered airport 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 NOTAM as required by the operator’s COA. This letter of agreement with 

the airport management shall be made available to the Administrator upon request.

2) The sUAS will only operate within the lateral boundaries of authorized property. Confined 

“Safe Zones” within those boundaries will be established for each flight. These zones will be

free of unnecessary hazards or risks and non-participating personnel.

3) The sUAS shall only operate within a pre-defined “Safe Zone” that shall be thoroughly

inspected by the PIC for buildings, overhangs, obstacles, wires, poles, people, vehicles, sun

angle, shadows, glare, reflective surfaces, clouds, smoke, and terrain among other potential 

hazards.

4) The PIC and VO shall brief specific safety contingencies for the area in which sUAS

operations will take place.

5) Flights shall be conducted under day visual meteorological conditions (VMC).

6) sUAS shall 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.

7) sUAS operations shall not be conducted during night, as defined in 14 CFR § 1.1.

8) Flights shall not be conducted under special visual flight rules (SVFR).

9) Flights shall not be operated at an altitude of more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in Aspect Aero, Inc. sUAS Operations Manual.

10) The PIC shall be prohibited from operating the sUAS from any moving device or vehicle.

11) The sUAS shall be operated within visual line of sight (VLOS) of the PIC.

a) The PIC shall maintain VLOS without the aid of telescopes, cameras or other devices.

b) The PIC will maintain VLOS with their own vision, which includes the use of eyeglasses 

or corrective lenses.

12) The sUAS shall remain clear and yield the right of way to manned operations and activities 

at all times (including, but not limited to, ultra-light vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

13)Aspect Aero, Inc. will require the PIC and Visual Observer (VO) to have successfully 

completed a qualification process, as outlined in the Aspect Aero, Inc. sUAS Operations

Manual.

14) The PIC’s primary responsibility while in flight is the safe operation of the sUAS.
REGULATIONS FROM WHICH EXEMPTION REQUESTED

14 CFR Part 21 subpart H

14 CFR 61.23(a) & (c)

14 CFR 61.101(e)(4) & (5)

14 CFR 61.113 (a)

14 CFR 61.315(a)

14 CFR 91.7 (a)

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)(1)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) & (2)

14 CFR 91.417 (a) & (b)

Aspect Aero, Inc. sUAS are multi-rotor craft weighing no more than 55lbs including payload.

Under normal conditions they operate at speeds of no more than 50kts and have the ability 

to hover and move along a vertical and horizontal plane simultaneously. They will operate 

in line of sight and will operate within a closed off and predetermined area owned 

and/operated by the property representative.

Given the small size of the sUAS and the controlled environment provided the proposed

operations would adhere to the Reform Act’s safety requirements. The approval of this 

application presents no national security issues. Regarding the level of safety surrounding

the proposed operations and the public benefit, reduction in environmental impacts,

including but not limited to reduced emissions and noise, the grant of the requested

exemption is in the public interest. Accordingly, the applicant requests that the FAA grant

the requested exemption with minimumdelay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because

operations will further enhance the safety of the persons and/or property using

conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when

conducting commercial operations under the FAA issued exemption as set forth in the Flight

Operations Manual (FOM) include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be

terminated at 25% battery power reserve or 30 minutes of flight time whichever 

occurs first.

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level

(AGL) and not more than 200 feet above an elevated platform from which filming is

planned.
5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer

(VO) and may include but not limited to a Camera Operator.

6. The sUAS pilot will be a designated Pilot in Command (PIC) and hold a current Third

or higher Class Medical Certificate or a valid state driver’s license. If the PIC feels 

another operator to be qualified with the necessary skills to be PIC & possess a Third

or higher Class Medical or a valid state driver’s license, that person may be

designated PIC provided they have a minimum of 20 hours of flight time with the

sUAS.

7. A briefing will be performed regarding the planned sUAS operations prior to each

day’s flight consisting of all the days’ production activities.

8. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the

requested exemption, with the appropriate local Flight Standards District Office

(FSDO) no more than 72 hours but no less than 48 hours from planned operation.

9. The operator will obtain verbal/written consent of all persons involved with the

planned operation and ensure that only consenting persons will be allowed within

100 feet of the flight operation, and the radius may be reduced to 30 feet based upon 

an equivalent level of safety determination, as required under the FOM. With the 

advanced permission of the FSDO, operations at closer range may be approved.

10. The PIC and VO will have been trained in operation of sUAS and receive up-to-date

information for the particular sUAS to be operated.

11. Written and/or verbal permission and permits will be obtained from territorial,

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies.

12. If the sUAS loses communications or loses GPS signal, the sUAS will have the

capability to return to a pre-determined location within a designated location and 

land autonomously.

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies.

EXEMPTIONS AND EQUIVALENT LEVEL OF SAFETY

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a)(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for

the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size 

and limited operating area associated with the aircraft to be utilized by the Applicant, an

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the

requirement for an airworthiness certificate, upon consideration of the size, weight, speed,

operational capability, and proximity to airports and populated areas of the particular sUAS.

In all cases, an analysis of these criteria demonstrates that the sUAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions

proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot
nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations

under this exemption will be tightly controlled and monitored by both the operator and 

under the requirements and in compliance with local public safety requirements. The FAA

will have advance notice of all operations. These safety enhancements provide a greater

degree of safety to the public and property owners than conventional operations conducted

with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application 

of these same criteria demonstrates that there is no credible threat to national security

posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels,and inability to carry a substantial externalload.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport,"

"experimental," or "provisional," as applicable. Even though the sUAS will have no

airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to

the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the 

size of the sUAS, two- inch lettering will be impossible. The word “Experimental” will be 

placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be

provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the 

pilot, observer and others working with the sUAS will see the identification of the sUAS as

“Experimental.”

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (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. Our sUAS do not carry any pilots or passengers nor property therefore I am seeking an

exemption to 14 CFR 61.113(a).

Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks

attendant to the operation of sUAS is far less than the risk levels inherent in the commercial

activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will

equate to the safe operation of the sUAS.

14 C.F.R. §91.7(a): Civil AircraftAirworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft for maintenance and use of safety checklists prior to each flight

an equivalent level of safety will be provided.
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) 

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight

Manual, approved manual material, markings, and placards, or any combination thereof. The

sUAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or

capacity to carry such an item on the aircraft. The equivalent level of safety will be

maintained by keeping the flight manual at the ground control point where the pilot flying 

the sUAS willhave immediate access to it.

14 C.F.R. § 91.103: PreflightAction.

This regulation requires each pilot in command to take certain actions before flight to insure

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the

aircraft an exemption will be needed. The PIC will take all actions including reviewing

weather, flight battery requirements, landing and takeoff distances and aircraft performance

data before initiation of flight.

14 C.F.R. §91.109: FlightInstruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates

with the aircraft via radio communications. The FAA has approved exemptions for flight

training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. The equivalent level of safety provided by the fact that

neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the

aircraft.

14 C.F.R. §91.119: Minimum SafeAltitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescribed for

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200

above an elevated platform from which filming is planned, an exemption may be needed to 

allow such operations. As set forth herein, the sUAS will never operate at higher than 400

AGL with the exception that in circumstances where the sUAS is used to survey or 

photograph a structure whose height exceeds 400 feet AGL, the sUAS will not be operated 

more than 100' above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtainedconsent.
The equivalent level of safety will be achieved given the size, weight, and speed of the sUAS 

as well as the location where it is operated. No flight will be taken without the permission of 

the property owner or local officials. Because of the advance notice to the property owner

and participants in the filming activity, all affected individuals will be aware of the planned 

flight operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations

of the sUAS will ensure separation between these small- UAS operations and the operations

of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an

appropriate altimeter setting available before departure.” As the sUAS may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An

equivalent level of safety will be achieved by the operator, pursuant to the safety check list

and live flight data monitoring, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFRConditions.

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During

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

minutes.

The battery powering the sUAS provides approximately 30 minutes of powered flight. To 

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited 

to approximately 10 minutes in length. Given the limitations on the sUAS’s proposed flight

area and the location of its proposed operations within a predetermined area, a longer time 

frame for flight in daylight or twilight VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior

exemptions. Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with 

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally,

limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption 

will be granted. Applicant believes that an equivalent level of safety can be achieved by

limiting flights to 30 minutes or 25% of battery power— whichever happens first. This

restriction would be more than adequate to return the sUAS to its planned landing zone

from anywhere in its limited operating area.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification andRegistration

The regulation provides in pertinentpart:

Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it

the following:

An appropriate and current airworthiness certificate. . . .

No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this 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.

The sUAS fully loaded weighs no more than 55 lbs. and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents or

to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the

extent they are applicable to the sUAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections,

except as provided in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook. An equivalent level of safety

will be achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical issues

arise the sUAS can land immediately and will be operating from no higher than 400 feet 

AGL. The operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover,

the operator is the person most familiar with the aircraft and best suited to maintain the

aircraft in an airworthy condition to provide the equivalent level ofsafety.

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the sUAS Manufacturer's Manual, as referenced in the 

Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that 

the sUAS is in working order prior to initiating flight and perform required maintenance

needed.
CIONCLUS'C,/N

Satisfaction of criteria provided in Section 333 ofthe Reform Act of 2012 provide more than

adequate iustification for the grant of the requested exemptions allowing the commelrial

operation ofthe applicant's sUAS.

The point ofcontact for this Petition for Section 333 Exemption pursuant To Section 333

ofthe FAA Reform Act and for any quesdons related to this matter is the below signatory

at (682') 597 -O757 or via email at dave@oglesbeegrouo.com'

Sincerely,

D"*l O/"J'*-

David Oglesbee

President

Aspect Aero, lnc.

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