August 15, 2015

U.S. D e p a rtme n t of T r a n sport a t i on

Do c k e t Op e r a t i ons

W e st B ui l ding G r ound F l oor, Room W 1 2

- 140 **Ele c**  **t r**  **o n**  **ically Sub**  **m it**  **t e**  **d via** 

1200 N e w J e rs e y Av e

., S E **w w**  **w**

**. re**  **g u**  **latio n**  **s.gov**

W a shin g ton, DC 20590

R e g a rdi n g : The Aspect Aero, Inc. P e t i t i on f o r S e c t i on 333 E x e mp t ion pu r suant To Se c t i on 333

of the F A A R e fo r m A c t of 2012 a nd P a rt 11 of the F e d e r a l Aviation Re gulations

f rom 14 C F R P a rt 21; 61.23(a) and (c); 61.101(e)(4) and (5); 61.113 (a ) ; 61.315(a) ;

91.7(a); 91.119(c); 91.1 2 1; 91.151 (a) (1 ) ; 91.40 5 (a); 91.407 (a ) ( 1 ); 91.409 (a )( 1 )

a nd ( 2 ); 91.417 (a ) a nd (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 A ircraft Systems (“sUAS”), hereby

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

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 Section 333.

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 news gathering

.

• 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 of the persons and property.

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

condi tions 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 i ndustry presently using conventional

aircraft.

The R e fo r m A c t g i v e s the S ec r e t a r y of T r a nsport a t i on the a uthori t y to det e r m i ne if ce rt a in sUAS

m a y o p e r a t e sa fe l y in t he n a t i on a l airsp ac e s y stem ( “ N A S” ) b e fo r e c omp l e t i on of the F A A ’s plana nd r u lem a ki n g to i nte g r a te sU A S in t o the N AS. The A c t dir ec ts t he S ec r e t a r y to c onsid e r w hich

t y p e s of s U A S a s a re sult of th e i r si z e , w e i g ht, spe e d, op e r a t i on a l c a p a b i l i t y

, p ro x i m i t y to ai r ports

a nd populat e d a r ea s, a nd op e r a t i on with i n vi s u a l l ine of si g ht do not c r e a te a h a z a rd to use r s of

the n a t i on a l a ir s p ac e or a thr ea t t o n a t i on a l se c u ri t y

. I f the S ec r e ta r y d e te r m i n e s that such

v e hicl e s m a y op e r a te s a f e l y in t he N A S , the S e c r e t a r y “ shall e stablish r e quir e ments for the s a fe

o p e r a t i on of such a ir c r a ft. ” 1 Aspect Aero, Inc. re qu e st for e x e mp t ion f a l l s within the Se c t i on 333

re quir e ments.

Giv e n the di rec t i on of Se c t i on 333 of the Re f o r m A c t, t he stro n g e quival e n t l e v e l of s a f e t y

sur r oundi n g the p r opos e d op e r a t i o n s, and t h e si g nifi c a nt pub l ic inte r e st ben e fits including the

p r ovis i on o f mo r e e f fi c ient a nd s a fer means to collect Aerial Data , Aspect Aero, Inc. re sp e c tful l y

r e qu e sts that the FAA g r a nt t he re qu e s t e d e x e mp t ion.

**T h**  **e n**  **a m**  **e a**  **n d**  **a dd**  **re ss of**  **t h**  **e a**  **pp l**  **icant 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 sa fety 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, t he preside nt 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 indus try 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. und e rs t a nds th a t t he F AA 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 s UAS operations. Aspect Aero

, Inc. is r e qu e st i n g

th i s e x e mp t ion be g iven f ull c onsid e r a t i on b y t h e F A A.

Aspect Aero

, Inc. is completely familiar with op e r a ting in a h i g h l y r e g ulat e d env i ronm e nt. Aspect

Aero

, Inc. h a s a r obust re g ula t o r y c omp l ian c e c ul t u r e a nd a k ee n und e rs t a nding o f the i m port a n c e

o f e x tensive s ec u r i t y , planni n g , do c u ment a t i on a nd c ontrol of op e r a t i ons in the aviation

environment; a nd a s such Aspect Aero

, Inc. h a s the unique c a p a bi l i t y of d e v e lop i ng a nd e x e r c is i ng

the n ece s s a r y p r o ce du r e s for s a fe a nd e f fec t i ve o p e r a t i o ns of s U AS in the public domain

.

Aspect Aero

, Inc. maintains c omp l ian c e with a ll la w s and re g u lations that g ov e rn its operations.

This 333

- exemption r e qu e st c ont i nu e s Aspect Aero

, Inc. c om m i t ment of c omp l ian c e in wo r ki n g

w i t h the F AA to s e r v e the publ i c in t e r e s t , maintain the in t e g ri t y of the N A S

, a nd will not be a thr ea t

t o n a t i on a l se c u r i t y

.

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 sU A S P I C shall pos s e ss at le a st a p r i v a te pilot ce rtifi c a te and a 3 rd class medical or U.S.

driver’s license

. a) The P I C shall also m e e t t he f l i g ht r e view r e quir e m e nts s p ec ified in 14 C F R § 61.56 in an

a i r c r a ft in which t h e P I C is r a t e d on their pi l ot c e rtifi ca te.

b) The P I C shall be t r a ined in t he op e r a t i on of the s p ec ific M a k e a nd Model of the s U AS bei n g

pi l ote d

. c) The P I C must h a ve a c c u mu l a ted a nd logged, in a mann e r c onsistent with 14 C F R § 61.51 ( b )

,

a m i ni m um of 200 f l i g ht c y c les a nd 2 5 ho u rs of t o tal t i me a s a sU A S r otor c r a ft pilot and a t

le a st t e n hou r s logg e d a s a sUAS pi l ot wi t h a si m i la r sUAS t y p e (mu l t i

- roto r ). Prior

do c ument e d fli g ht e x p e ri e n c e t h a t w a s obt a ined in compl i a n c e with applic a ble re g ulations

m a y sa t is f y th i s r e quir e men t

. d) The P I C must h a ve a c c u mu l a ted a nd logged, in a mann e r c onsistent with 14 C F R § 61.51 ( b )

,a m i ni m um of f ive hou r s as sUAS pi l ot o p e r a t i ng the make a nd model of s U A S to be uti l i z e d

for op e r a t i ons un d e r the e x e mp t ion and th re e tak e o f f s a nd th r e e landin g s in t he p r ece di n g

90 d a y s.

e) T ra in i n g

, p ro f ici e n c y

, a n d e x p e ri e n c e

- bui l di n g f l i g hts c a n a lso be c ondu c ted und e r this g ra nt

of e x e mp t ion t o acc omp l ish t he r e quir e d fl i g ht c y c l e s and f l i g h t t i m e

. f) Du r ing t r a in i n g

, p ro f ici e n c y

, a nd e x p e ri e n ce

- bui l ding fli g hts, all p e rsons not e s s e nt i a l for

f l i g ht ope ra t i o ns a r e c onsid e r e d no n

- p a rticip a nts, and the P I C must op e r a te the sUAS with

app r opri a te d is t a n c e f rom no n

- p a rtici p a nts i n acc o r d a n c e with 14 C F R § 91.119.

2) The P I C a nd Visual Observer (V O) will be designated prior to each flight

.

3) The P I C a nd V O will a lw a y s b e with i n visual line of si g ht ( V L O S ) of e ac h other a nd in d i re c t

v e rb a l c om m unic a t i on a t all t i m e s

.

4) S a f e t y B r i e fi n g s will be c ondu c ted b e f o re e ac h d a y ’ s ac t i vi t ies to in c lude, but not l i m i ted t o :

a) D e si g n a ted r oles o f P I C a nd V O

b) Risk M a n a g e ment a nd M i t i g a t i on

5) P rior to t he sU A S fli g ht ( s), a te a m comp r i s e d of t he P I C and V O will vi s u a l l y inspe c t t he fli g ht

pa t h a nd sur r ounding a rea a nd e q u ip m e nt t o identi f y potential c on c e rns.

6) sU A S s a f e t y c h ec kl i st will be c omp l e ted b y the r e view te a m t o e nsure a ll a r e a s o f c on c e r n h a ve

b e e n identifi e d a n d a ddr e ssed. A f li g ht wi l l NOT be c ond u c ted if a c o n c e rn c a nnot be re solved.

Operations

1) The sU A S shall not op e r a te in Class B , C, or D a i rsp ac e without w r i t ten a ppro va l f r om t he

F A A. The sUAS shall not op e r a te w i t hin 5 nautic a l m i les of the g e o g r a phic c e nter of a no n

tow e r e d a i rpo r t as d e noted on a c u r r e nt F A A

- publ i shed a e ron a ut i ca l c h a rt unless a l e t t e r of

a g r ee ment with that a irpo r t’s man a g e me n t i s obt a ined, a nd the op e r a t i on is c ondu c ted in

acc o r d a n c e with a N O T AM a s r e qui r e d b y the o p e r a tor ’ s C O A. T h is l e t t e r of a g re e ment with

t he a i r port m a n a g e ment sh a ll b e made a v a i l a ble to the Admin i str a tor up o n r e q u e st.

2) The sU A S will on l y op er a te w i t hin t he lat e r a l bo u nd a ri e s of authorized p r op e r t y

. C onfin e d

“ S a f e Z on e s” with i n those bound a ri e s will be e stablished for ea c h fli g ht. T h e se z on e s w i ll be

f r e e o f un ne c e ssa r y h a z a rds or r isks a nd no n

- p a rti c ipating p e rsonn e l.

3) The sU A S shall on l y o p e r a te w i t hin a p re

- d e fin e d “ S a fe Z o n e ” that shall be thorou g h l y

insp e c ted b y the P I C for bui l din g s, ov e rh a n g s, obst ac les, w ir e s, pol e s, p e ople, v e hicl e s, sun

a n g le, sh a dows, g la r e , r e fl e c t i ve sur f a ce s, c louds, smok e

, a nd te r r a in a m ong other potential

h a z a rds.

4) The P I C a nd V O shall brief sp e c ific s a f e t y contingencies f o r the a rea in which sU A S

op e r a t i ons will t a ke pla c e

.

5) F l i g hts s h a ll be c ondu c t e d und e r d a y vi s u a l m e te o rolo g i c a l condit i ons ( V M C ).

6) sUA S s h a l l not b e op e r a t e d l e s s th a n 500 f ee t b e low or le s s th a n 2,000 f ee t h o r iz ont a lly f roma c l o ud or w h e n v i s ibil i ty is l e s s th a n 3 s t a t u te mi l e s f rom the P I C.

7) sUA S op e r a tions s h a l l not be c ond u c t e d dur i ng ni g h t, a s d e f in e d in 14 C F R § 1.1.

8) F l i g hts s h a ll not b e c on d u c ted und e r s p ec ial vi s u a l fli g ht rules (SV F R).

9) F l i g hts shall not be o p e r a ted a t an a l t i t ude of more than 400 fee t abo v e g round l e v e l ( A G L ),

a s i ndic a ted b y the p r o ce du r e s spe c ified in Aspect Aero, Inc. sU A S Op e r a t i ons Manu a l.

10) The P I C shall be p rohibit e d f r om ope r a t i ng t h e s U AS fr om a n y mov i ng d e vice or v e hicl e

.

11) The sU A S shall be op e ra ted w i t hin v i s u a l l ine of si g ht ( V L OS) o f the P I C

.

a) The P I C shall maintain V L OS wi t hout t he a id of t e les c o p e s, ca me r a s or other d e vic e s.

b) The P I C will maintain V L OS wi t h their own vis i o n, whi c h includ e s the use of e y e g l a sses

or c o r r e c t i ve lens e s.

12) The sU A S shall r e main c le a r a nd y ield the r i g ht of w a y to m a nn e d op e r a t i ons a nd a c t i vi t ies

a t all t i m e s (in c lud i n g

, b ut not l i m i ted to, ul t r a

- l i g ht vehi c les, p a ra c hute ac t i vi t ies,

p a r a s a i l ing a c t i vi t ies, h a ng g l i d e rs, e tc. )

.

13) Aspect Aero , Inc. will re quire the P I C a nd Visual Obs e rv e r (V O) to have su c ce ssful l y

c omp l e ted a q u a l i fi c a t i on p r o ce ss, as outlined in t h e Aspect Aero , Inc. sU A S Op e r a t ions

M a n u a l.

14) The P I C’s p rima r y r e sp o nsib i l i t y while in f l i g ht is t he sa f e o p e r a t i on of the sU A S

.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 t he 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 minimum delay.

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 s ize

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 pilotnor 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 a nd

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 external load.

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 fuselag e 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 Aircraft Airworthiness.

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 the Aircraft.

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 will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

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: Flight Instruction.

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 Safe Altitudes.

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 s tructure 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

o perations without their pre

- obtained consent.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 i ndividuals 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 VFR Conditions

.

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

fra me 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 and Registration

The regulation provides in pertinent part:

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 i nitiating 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 of safety.

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.

ATTACHIT/rENIS



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