700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com March 12, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, iWire365 dba SkyRecon365 (“SkyRecon365”), the operator of small Unman ned Aircraft Systems (“sUAS” ), seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Attached as Appendix B is a summary of this request.

The requested exemption would permit commercial operation of S kyRecon365 sUAS's, which weigh between 5 and 15 lbs. and performs precision aerial inspections or surveys that consist of still photographs and videography taken by onboard cameras. The sUAS's takes a series of high quality, still digital images and video that are used to produce precision references to structural integrity of the subject under study. Applications for these sUAS devices and associated functions include industrial plant mapping, real estate and property surveys, land surveys, construction prospecting, cinematic aerial photography and film, sports aerial photography and video, family functions and weddings, search and rescue, county surveying an d state mapping, municipal police aerial drone

video streaming, tall structure inspections including but not limited to wireless towers, storage silos,

e lectrical transmission towers, unoccupied and unmanned structures

. Use of the sUAS for aerial inspections and surveys reduce the need to utilize conventional manned aircraft, manned lifting devices or manned climbing for the same purpose and provides very high quality imagery at a fraction of the cost. These savings result in enhanced s afety, efficiency and productivity for the affected activities, as well as environmental benefits.

Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333

As described more fully below, the requested exemption would authorize commercial operations of aerial inspections or surveys using the sUAS's, which weigh less than 15 lbs. and are small in size. (see the attached O&M manuals for the DJI Phantom 2, DJI Phantom 3, DJI Inspire and DJI S900 ). The sUAS's will be operated under controlled conditions at low altitude in airspace that is limi ted in scope, as described more fully herein; it will have automated control features, as described below and in the O&M manuals. The sUAS also will be operated by an individual who has passed an FAA approved Private Pilots ground training exam, medical ce rtification and a required manufacturer’s training program for the sUAS. Finally, the airspace in which the sUAS will operate will be Class G airspace or airspace approved by the FAA in advance.

SkyRecon365 respectfully submits that because these small, unmanned aerial vehicles will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft or other manned means of inspections, the FAA can have confidence that the operations will

achieve at least a n equivalent level or greater level of safety. Approval of these exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requireme nts for the safe operation of such aircraft systems in the national airspace system.”700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com The name and address of the applicant are:

iWire365, LLC. dba SkyRecon365

Attention : William Michael Hadala, Jr.

Ph one : (972) 994

- 6650

Email: williammichael@iwire365. com Address: 700 North Glenville Drive, Suite 700 Richardson, Texas 75081

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(b);

1 4 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b).

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public

interest.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

SkyRecon365 submits that grant of this exemption application for use of the proposed UAS's in precision aerial inspections will advance the Congressional mandate in Section 333 of the Reform

Act to accelerate the introduction of UASs into the national airs pace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section

332 of the Reform Act. In makin g this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational cap ability;

• Operation of the sUAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).1

.

The Federal Aviation Act expressly grants the FAA the authority to issue exempti ons. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring comm ercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the

Administrator finds the exemption is in the public interest.

1. Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com approval, to supply conditions for the safe operation of the UAS. SkyRecon365 welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transiti oning to UASs for aerial inspections and survey photography. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the sUAS

A critical element of the exemption application involves evi dence of the airworthiness of the sUAS. 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. SkyRecon365 small UAS's will operate at low speed in a controlled environment, at least five miles from an airport and more than three miles from any cit y or densely populated area. An analysis of these criteria demonstrates that the UAS 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 airc raft (fixed wing or helicopter) operating with an

airworthiness certificate without the restrictions and conditions proposed.

Mandatory Operating Conditions (see O&M and Safety Lists)

Grant of the exemption to SkyRecon365 will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid c ongested or populated areas, which are depicted in yellow on VFR

charts.

• Operations to be conducted over private or controlled

- access property.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual F light Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM).

o Cylinder walls may be expanded by observer with ability to control aircraft.

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway cente rline measured from runway thresholds.

• All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com Operator Requirem ents

SkyRecon365 respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UASs, such as the DJI Phantom Vision 2, DJI Phantom Vision 3, Inspire and DJI S900 , are characterized by a high degree of control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth

above. Please see details in the attached O&M manuals.

Additional automated safety functions and safety enha ncing features of the sUAS's include the following:

• Auto

- pilot detection of lost GPS or of insufficient satellites initiates an immediate return to

aircraft take

- off location ("home")

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

• If the auto

- pilot detects a lost

- link to the GCS for longer than 30 seconds, landing procedure begins.

Given these safety features, SkyRecon365 proposes that operators of the sUAS should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:

• H ave successfully completed, at a minimum, FAA private pilot ground school instruction and passed the FAA Private Pilot written examinat ion or FAA

- recognized equivalents;

• H ave completed the manufacturer’s training or a minimum of 40 hours training program for operation of the sUAS's.

SkyRecon365 notes that the FAA has found that safety factors permitted operation of sUASs by operators wit h these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration,

Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen’s certificates. 49 USC §44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations of a sUAS's conducting precision aerial inspections or surveys.

Approval of the exemption allowing commercial operations of the sUAS for precision inspection and survey work will enhance safety by re ducing risk. Conventional aerial inspection and survey operations, using jet or piston

- powered aircraft present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. Other conventional manned climbing or manned lifts risk safety hazards associated with falls, electrical hazards, fuel
related hazards, and inhalation hazards associated with th e structures being inspected. In contrast, a sUAS weighing less than 15 lbs. and powered by batteries eliminates a portion of that risk given

the reduced mass and lack of combustible fuel carried on board a manned aircraft and the lack of

risks associated with manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights, manned lifts or climbing hazards.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com Additionally, no national sec urity issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the sUAS poses no threat to national security.

The operation of the sUAS, weighing less than 15 lbs., for precision inspections or surveys in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting SkyRecon365 from the requirements of Part 21.

The sUAS’s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation within

vis ual line of sight, and national security

— and its showing of an equivalent level of safety as it may relate to the requirement for FAA training, provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the sUAS in the commercial precision aerial inspection and survey business.

Very truly yours,

William Michael Hadala, Jr.

President & CEO iWire365, LLC. dba SkyRecon365

Enclosures:

Appendix A: Exemption Request and Equivalent Level of Safety Showings Under Applicable Rules Subject to Exemption

Appendix B: Operation and Maintenance Manuals: DJI Phantom Vision 2 O&M Manual , DJI Phantom Vision 3 O&M Manual, DJI Phantom Inspire O&M Manual, DJI S900 O&M Manual

Appendix C: Safety Checklists700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

SkyRecon365 requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAS's:

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

The regulation provides:

When marks include only the Ro man 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.

The sUAS's has no entrance to the cabin, cockpit, or pilot statio n 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 forward fuselage in compliance with § 45.29(f). The equivalent level of safety will be achi eved by having the sUAS marked on its forward fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV will see the identification of the sUAS as “Experimental.” The FAA has issued the following exemptions to this regul ation to SkyRecon365 , Exemption No. 10700, and to others, including Exemption Nos. 8738, 10167 and 10167A.

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

Subpart H, entitled Airworthiness Certificates, establishes the proc edural 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 SkyRecon365 , an exemption from Part 21 Subpart H meets the requi rements 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 c ertificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. Our small sUAS's will be operated at low speed in a controlled environment, at least five miles from an airport and more than three miles from any city or densely populated area. An analysis of these criteria demonstrates that the sUAS's 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 helicopter) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 15 lbs. fully loaded, carries ne ither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, purs uant to the Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is currently done on active construction sites. The FAA will have advance notice of all operations.

These safety enhancements, which already apply to civil aircraft operated in connection with construction sites, power plant sites and the like provide a greater degree of safety to the public and700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com property owners than conventional operations c onducted 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 UAS, due to its size, speed of operation, locatio n of operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two lbs.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Priv ileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the sUAS in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. SkyRecon365 respectfully prop oses that operator requirements should take into account the characteristics of the particular sUAS. SkyRecon365 sUAS has a high degree of control and various

built

- in technical capabilities that strictly limit the potential for operation outside of the op erating conditions set forth in the exemption application.

The sUAS has a navigation and control system comprised of a Ground Control Station (GCS) and

auto

- pilot system. All flights utilize precision GPS guidance. In the case of unplanned events, the

ope rator inputs evasive maneuvers from the control unit, and the control unit executes that maneuver. Operator interventions include diversion to the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to po int and hold; abort mission and land; and emergency power cut off and land (Flight Termination System).

Given these safety features, SkyRecon365 proposes that operators of the sUAS should not be required to hold a commercial or private pilot certification . Instead, operators should be required to:

• H ave successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

- recognized equivalents;

• H ave completed manufacturer's training program or a minimum 40 hours training program for operation of the UAS.

SkyRecon365 notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs where the

m andatory operating conditions specified above are present. See Federal Aviation Administration,

Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§447 01(f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the sUAS without a private pilot’s certificate or a commercial pilot’s certif icate, under the

conditions set forth herein.

The risks associated with the operation of the sUAS (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operat ions or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy c ondition. Should the exemption be granted allowing commercial operation of the s UAS without an airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size of the aircraft and the requirements that have presumably already been met for the sUAS (for instance, the sUAS’s Operations and Maintanence Manual and Safety Manual and Checklist), an equivalent level of safety will be achieved by insuring compliance with the SkyRecon365 manuals prior to each flight.

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

The regulation provides:

No person may operate a U.S.

- registered civil aircraft

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5

(2) 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.

Given the size and configuration of the sUAS, it 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 achieved by keeping the flight man ual (see, e.g., User Guide, Exhibit 4) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 95 65, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement as the pi lot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual and safety Checklists. These a ctions will provide an equivalent level of safety.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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.

The sUAS is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircr aft via radio communications. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls fo r a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the sUAS

.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com 14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than con gested areas to 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.

As set forth herein, the sUA S will never operate at higher than 400 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey work must be accomplished at relatively low altitudes and at al titudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which

the sUAS's are built. Also, no flight will be taken without the permission of the landowner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the inspection or survey flights. Compared to aerial inspection and survey operations conducted with aircraft or rotorcraft weighing far more than 15 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low

- altitude operations of the UAS will maintain 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

SkyRecon365 requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for altimeter use below 18,000 feet mean sea level (“MSL”) in maintaining the cruising altitude or flight

level of the aircraft. SkyRecon365’s operation of the sUAS will not exceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight such as a manned aircraft will typically fly. The ground station has live feedback and GPS information about the sUAS, including but not limited to the heigh t of the sUAS, its forward velocity, and compass heading. The operator will be able to observe and control the maximum height of the sUAS. Additionally, the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety provided by Section 91.121 will be met.

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather condi tions) 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 sUAS batteries provide approximately 25 to 30 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those propo sed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

SkyRecon365 believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corpor ation to operate without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact t hat it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting sUAS flights to 20 minutes would greatly reduce their utility. In the unlikely event that the sUAS should run out of fuel, it would simply land.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com Given its weigh t and construction material, the risks are less than contemplated by the current regulation.

SkyRecon365 believes that an equivalent level of safety can be achieved by maintaining 10 minutes

of battery life , which, allowing 15 to 20 minutes of flight time , would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.

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

This regulation provides as follows:

(a) N o person ma y operate a civ il aircraft unless it has an appropriate and current airworthiness

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issu ed under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The sUAS's fully loaded weighs no more than 15 lbs. As such, there is no ability or place to carry certification and registration documents or to d isplay them on the sUAS. In addition, there is no pilot

on board the aircraft.

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. The FA A has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

Section 91.405(a) requires 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 discrep ancies repaired as prescribed in part 43 of this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate.

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the sUAS' s will be accomplished by the owner/operator pursuant to the manuals, such as Exhibit 3, provided by SkyRecon365 . An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restric ted predetermined areas and is not a complex mechanical devise. As provided in the attached Maintenance Manual and the Safety Checklist, the operator of sUAS will ensure that the sUAS is in working order prior to initiating flight, perform required mainten ance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com APPEND IX B

SUMMARY OF TRIMBLE SECTION 333 EXEMPTION REQUEST

SkyRecon365 hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the DJI Phantom Vision 2, DJI Phantom Vision 3, DJI Inspire, DJI S900

sUAS's in precision aerial inspection and survey work. An exemption is requested from the following regulations:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a);

14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b).700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com APPENDIX B



# Operation and Maintenance Manuals700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com APPENDIX C



# Safety Checklists