Page **1** of **11**

V1 Media, LLC. Kenneth R. Topham III 3351 Walkers Ridge Rd. Dacula, Ga 30019 Ktopham84@gmail.com

FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12-140 Washington, DC 20590

**To whom it may concern:** I am writing pursuant to the FAA Modernization and Reform Act of 2012 ( Reform Act), and the procedures contained in 14 C.F.R. 11, to request th at, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Reg ulations (FARs) listed above so that V1 Media may operate its small unmanned aircraft lightweight unm anned aircraft system (UAS) commercially in airspace regulated by the Federal Aviation Administ ration (FAA); as long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. I am a FAA licensed private pilot with single engin e rating with over 145 hours and 16 years of work experience in the aviation industry. Additionally, I have been flying Unmanned Aircraft recreationall y since 1996. I have been a private pilot since 2001 and have a current 3rd class medical certificate. W ith my clear understanding of FAA rules, my awareness o f operational and restricted airspace, my experience as a pilot license holder (even though T he FAA is lowering the credential bar to include sp ort pilot certificates), and my attitude of safety firs t when it comes to flight operations, I believe I s hould be granted an exemption. My request for a waiver of the section is not for o perations for the purpose of “closed-set motion picture and television filming” but are identified below. My request is to operate Unmanned Aerial Systems (UAS) for commercial purposes. Specifically , to “record digital video data and other aerial photography data of real estate, insurance and gene ral aerial photography. Which will include residential, farms and land to assist an owner in t he promotion of their improved/unimproved parcel of land, and inspection of damaged property such as ro ofing systems and or timber survey, for ultimate disposition and sale or purchase or other promotion al purposes, such as a business wanting to promote its facilities using aerial images.” I am currently seeking exemption from: 14CFR 91.7(a ); 91.9(B)(2); 91.103; 9l.109; 91.119 (c); 91.121; 91.J 51(a)(l); 91.203(a)(b); 91.405(a); 91.407(a)( l); 9l.409(a)(l)and(2); 91.417(a)&(b); 45.23(b); Pa rt 21; 61.l 13(a)(b) “The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new FAA “Summary Grant” approach, announced April 9th, 2015 http://www.faa.gov/news/updates/?newsId=82485 that will help speed up Section 333 exemption approvals for many commercial UAS operators prior t o finalizing the small UAS proposed rules published this past February. It is my understanding that the FAA will still review each Section 333 petition individually. However, I am hoping that the agency will accept my particular petition, and include it inPage **2** of **11**

the next summary grant, and issue me an exemption o n the presumption that the FAA has “already granted a previous exemption similar to this reques t”. The new interim policy includes the granting of a C ertificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator wi th a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visua l line of sight (VLOS) of the pilots, and stay certai n distances away from airports or heliports such as 5 nautical miles (NM) from an airport having an opera tional control tower; or 3 NM from an airport with a published instrument flight procedure, but not an o perational tower; or 2 NM from an airport without a published instrument flight procedure or an operati onal tower; or 2 NM from a heliport with a publishe d instrument flight procedure. It is also understood that the “blanket” 200- foot COA allows flights anywhere in the country except restricted airspace and other areas, such as major cities, where the FA A prohibits UAS operations.

**UAS Description:** I am asking for an exemption for UAS up to 55 pound s because I will be using DJI Phantom Vision+ and/or DJI Phantom 2 Vision and/or DJI Phantom 3. T he differences in these are camera options not flight systems.

In the event a loss of communications occurs the cr aft will rise up vertically to a safe height before beginning an automatic return to home function. The control signal may be reconnected in flight and the pilot can take over safe operations again if co mmunication is reestablished. However in the case o f a GPS failure the craft will be able to be manually f lown to a safe landing by the pilot. The craft oper ates electrically, carries no flammable fuel, has an int egrated GPS pilot system, provides location informa tion along with height AGL, speed, battery life, has pro grammed no-fly zones for controlled airports, and provides direction of travel distance from the pilo t.

**Additional Points:** It is my hope that you find that the enhanced safet y achieved using an unmanned aircraft with the specifications described by the petitioner which ca rries no passengers or crew, rather than a manned aircraft of significantly greater proportions, carr ying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled b y this exemption is in the public interest. **Flight Operations:** I am well aware of conducting safe flight operation s and planning flight paths that minimize any overflight of crowds. Flights will end when battery reserve reaches 25 percent. Operations will not oc cur under IFR conditions. In addition, preflight and po st-flight checklists and UAS examinations will help detect any abnormalities prior to flight and after flight. Any UAS unable to satisfy safety checklists will be removed from service until the issue can be resolve d. Granting this request would not adversely affect sa fety since operations would be in accordance with current UAS rules. Section 333 Compliance and Appro priateness: Based on the size of the craft, experience of the pilot, and operational goals, thi s request appears to be well suited for approval us ing the current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 (includin g new interim policies). Safety is of paramount importance to V1 Media. We e ndeavor to help integrate UAS into the NAS (national air space) by performing our services wit h the utmost concern for the safety of our operator s,Page **3** of **11**

the general public and property. To achieve this, V 1 Media, has instituted several flight parameters, conditions, guidelines and limitations to adhere to before, during and after flight operations - all o f which are outlined in the DJI User Manual Operators Manual. These conditions are based off of Part 333 exemptions that have already been approved by the F AA and have been integrated into our operations:

- The UAS will not exceed a ground speed of 50 knots.

- All operations will remain below 400’ AGL.

- The UAS will weigh less than 55 lbs.

- All operations will remain in VLOS.

- All operations will utilize a VO. This VO will alwa ys be able to communicate verbally with the PIC.

- The operator must follow the procedures as outlined in its operator's manual. (listed herein as Protocols & Procedures & DJI User's Manual and Oper ators Manual).

- Prior to each flight the PIC must inspect the UAS t o ensure it is in a condition for safe flight. Any UAS that has undergone maintenance or alteratio ns that would affect the UAS operation or flight characteristics must undergo a functional test flig ht in accordance with operators manual.

- The operator must follow the manufacturer's UAS air craft component, maintenance, overhaul, replacement, inspection and life limit requirements

.

- The PIC will must possess at least a private pilot certificate and at least a third-class medical certificate and also meet flight review requirement s specified in the 14 CFR 61.56.

- Prior to operations the PIC will undergo UAS specif ic training for type (multi-rotor), make and model aircraft and log hours appropriately. PIC wil l also maintain proficiency and currency (every 90 days) with UAS. Keeping with a manner con sistent with 14 CFR 6l.51(b).

- PIC & VO will have successfully completed a qualifi cation process, as outlined in the operator’s manual. Completion of this qualification process wi ll be documented.

- The UAS will not be operated directly over any pers on, except authorized and consenting flight personnel.

- The PIC & VO will ensure that no unauthorized perso ns are allowed within 200' (or a distance deemed safe and practical due to physical terrain c onstraints) of the flight area except those consenting flight personnel.

- If UAS loses communication or loses it GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with operator's manual.

- The UAS must abort the flight in the event of unpre dicted obstacles or emergencies in accordance with operators manual.

- The operator must obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operati ons.

- All operators will comply with all manufacturers Sa fety Bulletins.

- Before conducting operations, the radio frequency s pectrum used for operation and control of UAS will comply with Federal Communications Commiss ion (FCC).

- Prior to the planned operation (3 days) the operato r will contact the local Flight Standards District Office (FSDO) (that has jurisdiction of th e area) in writing and cover the plan of activities for the flight operation.

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground station during all operations.

- The UAS will remain clear and yield the right of wa y to all other manned operations and activities at all times.Page **4** of **11**

- All operations will be conducted under VFR (visual flight rules) and no night operations during night as defined in 14 CFR 91.151

- The UAS will not be operated by the PIC from any mo ving device or vehicle.

- The UAS will not be operated less than 500’ below o r less than 2,000’ horizontally from a cloud or when visibility is less than 3 statute miles fro m the PIC.

- The UAS will not operate in Class B, C, or D airspa ce without written approval from the FAA. The UAS will not operate within 5 nautical miles of the geographic center of a non-towered airport.

- Any incident, accident, or flight operation that tr ansgresses the lateral or vertical boundaries of the operational area as defined by the applicable C OA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours.

- Accidents will be reported to the National Transpor tation Safety Board (NTSB) per instructions contained on the NTSB website. The petitioner will outline in this document: 1. Request for exemptions by Part and Subpart 2. Petitioners protocols and procedures for operati ons 3. The Unmanned Aircraft System (UAS) 4. The Public Interest **Requests for Exemption by Part and Subpart 14 CFR 91.7(A) Airworthiness Certificate;**  Prohibits the operation of an aircraft without an a irworthiness certificate. Petitioner requests exemp tion based on previous exemption no. 11138. The FAA has ruled that this make and model of aircraft (UAS) does not require an airworthiness certificate. **14 CFR 91.9(B) (2) Aircraft Flight Manual** Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers aboard and gi ven the size of the UAS, this regulation is inapplicabl e. An equivalent level of safety will be achieved b y maintaining a manual at the flight operations cente r. The FAA has previously issued exemptions to this regulation no. 10700 and 32827. **14 CFR 91.103 Pre-flight;** No approved Aircraft Flight Manual on board the air craft. The petitioner asserts that an equivalent le vel of safety will be achieved by the PIC taking all pr e-flight actions set forth in the operating documen ts including weather, flight battery requirements, lan ding and take-off distances and aircraft performanc e data before initiation of each flight. **14 CFR 91.109 Flight Instruction;** There are no dual controls available for flight ins truction. 14 CFR 91.119 (C) Minimum Safe Altitudes; States that no person may operate an aircraft below the following altitudes: over other than congested areas, an altitude of 500' above the surface, excep t over open water or sparsely populated areas. In those cases, the aircraft may not be operated close r than 500' to any person, vessel, vehicle, or structure. The petitioner will not operate any UAS over an alt itude of 400' AGL. The majority of the operations proposed will operate between 0 to 200' AGL as this usually provides the best angle of capture for the type of photography and videography operations prop osed.Page **5** of **11**

The UAS utilized for this exemption is of exception ally light weight and is not capable of speeds over 30 knots. The UAS is equipped with GPS guided auto pil ot with a return home function in case loss of control by the PIC and is powered by sealed batteri es thereby reducing the chance of post impact fire to nearly zero.

There will be cases when the 500' distance from str uctures will need to be exempted. (Example: Aerial Video of a 2 story home roof to determine and or do cument extent of storm damage.) In this type of operation every assurance will be made to keep pers ons outside of a reasonable, safe, clear area of operations and will only be conducted with the expr ess permission of the property owner. See Protocols and Procedures Section. The petitioner will implement procedures and polici es to ensure that any person in the general vicinit y of operations will be aware of such operations and ensure that all non-essential personnel are cleared of the area of operations to the extent possible. The petitioner therefore requests relief in part from 1 4CFR 9 l .11 9(C) **14 CFR 91.121 Altimeter Settings;** The petitioner requests relief from 91.121 for the following reason. The UAS is equipped with GPS derived altitude capability, however due to the lim ited altitude requested in this exemption, the FAA has previously granted Exemption for these types of ope rations. Reference Exemption No. 11138 **14CFR 91.15l(a)(1) Fuel for Flight;** No person may begin a flight in an airplane under V FR conditions unless (considering wind and forecast weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds. (a)(l) During the da y to fly for at least 30 minutes. The petitioner requests relief from 91.15l (a) due to the fact that the UAS is equipped with a battery and percentage indicator system. The UAS has a flight c apability on full charge of approximately 25 minute s depending on camera usage and other variables. The petitioner has established that the maximum flight will be 15 minutes on a fully charged battery. This constitutes landing with approximately 25 percent fuel remaining. The petitioner believes that this f ollows the spirit and intent of the rule with a gre at margin of safety. No UAS operations will be conducted at night, as de fined by Federal Aviation Regulations. **14 CFR 91.203(a)(b) Carrying of civil aircraft Cert ifications and Registrations;**  Provides for the carrying of civil aircraft certifi cations and registrations. They are inapplicable fo r the same reasons described above. Operations manuals an d Safety Procedures will be maintained at the V1 Media home office with copies of same traveling wit h the PIC. **14 CFR 91.405(a) Maintenance required;** The petitioner requests relief in part from 91.405( a)(l) based on the Protocols and Procedures Section on Maintenance and Maintenance Records. Also reference Exemption No. ll138 **14 CFR 91.407(a)(l)** Operation after maintenance, preventive maintenance , rebuilding, or alteration; The petitioner request s relief from 91.407(a)(l) based on the Protocols and Procedures Section on Maintenance, Return to service after maintenance, and Maintenance records. Reference Exemption No. 11138Page **6** of **11**

**14 CFR 91.409(a)(l)(2) Inspections;** The petitioner requests relief from 9l.409(a)(1)(2) based on the Protocols and Procedures Section on Inspections. Reference Exemption No. 11138 **14 CFR 91.417(a)(b) Maintenance records;** The petitioner requests relief from 91 .417(a)(b) b ased on the Protocols and Procedures Section on Maintenance records. **14 CFR 45.23(b) Marking of the Aircraft;** Applicable codes of Federal Regulation require airc raft to be marked according to certain specificatio ns. V1 Media UAS's are, by definition, unmanned. They t herefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place o n such small aircraft. Regardless, V1 Media will, if required, mark its UAS's in the largest possible le ttering by placing the ”N "number on its fuselage as requir ed by 14CFR 45.29 (f) so that the pilot, technician , spotter and others working with the UAV will see th e markings. The FAA has previously issued exemptions to this regulation through Exemption No 10167 and 10700 **14 CFR 21, Sub Part H Airworthiness Certificates;** Entitled Airworthiness Certificates, set forth requ irements for procurement of necessary airworthiness certificates in relation to FAR 91.203(a)(l). The s ize, weight and enclosed operational area of V1 Med ia UAS permits exemption from Part 21 because V1 Media UAS meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is author ized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both pieces of the legislation permit the FAA to exempt UAS from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuvera bility and proximity to areas such as airports and dense populations. V1 Media’s UAS meet or exceed ea ch of the elements. **14 CFR 61.l 13(a)(b) Private Pilot Privileges and L imitations PIC;**  Private pilots are limited to non-commercial operat ions. V1 Media can achieve an equivalent level of safety as achieved by current Regulations because V 1 Media UASs do not carry any pilots or passengers. Further, while helpful, a pilot license will not en sure remote control piloting skills, though V1 Medi a pilot vetting and training program will. Further, private pilot licensees will operate V1 Media UASs with th e same skill. Further the risk attendant to the opera tion of V1 Media UAS is far less than the risk leve ls inherent in the commercial activities outlined in C FR 61. Thus, allowing V1 Media to operate its UAS w ith a private pilot as the pilot in control will exceed current safety levels in relation to CFR 61.l 13(a )(b).Page **7** of **11**

**PROTOCOLS AND PROCEDURES FOR UAS OPERATIONS**

A. Preflight B. Area Security C. Limitations of Operations D. Airworthiness E. Maintenance and Records F. Pilot in Command Requirements G. Visual Observer and Requirements H. Reporting of Incidents and Accidents **A. Preflight Inspection of UAS** ( I ). Preflight of the Unmanned Aerial System will follow the instructions in the DJI instruction and User Manual. The Pilot in Command will certify that a pr eflight inspection has been accomplished with the date and time and signature in the UAS logbook. The preflight shall include the aircraft, transmitter, and batteries, motors, rotors, landing gear, camera and gimbal mount. As a part of the preflight the Pilot in Command will assure that weather conditions, area s ecurity, and any other information essential to saf e operation has been obtained. **B. Area Security** ( 1 ). The PIC of the UAS will ensure that the oper ational area for the purposes of UAS flight shall b e cleared of all nonessential persons at all times th e UAS is in flight. Additionally all nonessential p ersons shall be required to remain clear of the operations area by a minimum distance of 200' (or by as much as practical) during operations. PIC shall ensure that cones and clearly marked signs are posted at all ingress \ egress points to the operations areas. Th ese signs will be of white background with red lettering stating the following: "Unmanned aircraft operations underway. Please remain clear." (2). In the event of a breach by nonessential perso ns into the operations area during the flight of UA S, the PIC shall immediately terminate flight operatio ns until such time as the area can be cleared of th ese persons. (3). The UAS area of operation is defined as the ho rizontal flight path(s) of the UAS as well as the V ertical flight path and Maximum altitude to be reached. Add itionally, the area between the UASs current position and its Home location is also considered o perational area as it will proceed direct to its ho me location in the event of loss of ground control. **C. Limitations of Operations** (1) The UAS shall be operated i n Day time only, as defined by 14 CFR (2) UAS night operations are prohibited. (3) The UAS shall be operated by VLOS at all times (4) A Visual Observer shall be utilized at all time s and must maintain VLOS at all times. (5) The UAS shall remain within 1 000' horizontal d istance of the PIC at all times. (6) The UAS to be utilized is the DJI Inspire Unman ned Aircraft System. No other systems will be operated.Page **8** of **11**

(7) The UAS will have an altitude restriction of 40 0ft AGL. (8) The UAS will not be operated at a speed exceedi ng 30 Knots. (9) Operations Documents will be accessible to the PIC at all times and must be accessible during UAS operations and made available to the Administrator on request. (10) PIC must inspect and ensure that UAS and groun d control station is in airworthy condition prior t o each operation; if determined un-airworthy, all ope rations will be suspended until such time as necessary maintenance has been performed and the UA S is determined to be in a safe condition for flight. (11) An operational flight test is required after a ny maintenance or alterations that may affect UAS operation or flight. (12) UAS maintenance must follow manufactures aircr aft and component, maintenance overhaul, and replacement, inspection, and life limit requirement s. (13) The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Maintenanc e and inspection, and alterations must be noted in the aircraft records including total flight hour s, description of work performed, and the signature of the authorized person returning the UAS to service. (14) UAS must comply with all Manufacturers' Safety Bulletins. (15) An authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspection s. (16) UAS must by operated by a PIC possessing at le ast a Private Pilot Certificate, with most appropri ate Class and Category and at least a current Third Cla ss Medical. (17) PIC must meet the flight review requirements o f 14 CFR 61.56 in an aircraft in which the PIC is rated. (18)Prior to operations for which exemption is requ ested the PIC must have accumulated and logged ,in a manner consistent with 14 CFR 61.5l(b), a minimum of 25 hours of total time as a UAS rotorcraft pilo t including at least 10 hours of UAS multi-rotor. (19) Prior to operations the PIC must have accumula ted and logged a minimum of 5 hours as a UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and landings in the preceding 90 days to meet currency requirements. (20) PIC is required to operate the UAS in accordan ce with 14CFR 91.119. (21) No UAS operation within 5 nautical miles of a controlled airport reference point as denoted on a current FAA chart. (22) No operations are allowed in the surface areas of Class B, C, and D airspace or in restricted air space. (23) No operations are allowed if the return home f unction and\or auto pilot are, or are suspected to be malfunctioning. (24) UAS shall not be operated from a moving platfo rm of any type.Page **9** of **11**

(25) No operations shall be conducted without an ap propriate Certificate of Authority issued by the Administrator. (26) A Visual Observer shall be utilized at all tim es when operating the UAS. (27) Should the PIC or Visual Observer detect that a manned aircraft is being operated in close proxim ity to the operations area, the UAS shall give right of way to the manned aircraft, and the PIC shall ceas e operations and land until such time as the manned a ircraft has cleared the area. (28) UAS will not be operated any closer than 100' to any structure without the express permission of the structure I building I property owner. (29) The UAS will be limited to 18 minutes of fligh t or 25% of battery power, whichever occurs first.

**D. UAS Airworthiness** (1). The PIC shall ensure that the UAS is in an air worthy condition before each flight. Airworthiness shall be determined by a preflight inspection in accordan ce with DJI operating documents and any and all applicable Federal Aviation Regulations, and any ad ditional requirements as defined by the Administrator. PIC shall document each preflight in spection by date, Aircraft total Flight time to dat e, any discrepancies noted ,and signature and certific ate number. Any discrepancy noted shall be addressed before UAS operation.

**E. UAS Maintenance and Records** (l). The operator shall maintain aircraft maintenan ce logbooks. Each V AS shall have its own and separate maintenance log book. DJI documents, handb ooks, user manuals, supplements, Safety Bulletins, etc., shall be the only approved documen ts for performing repairs, maintenance, inspections , overhauls, or replacement of life limited component s. A record of each preflight inspection will additionally be recorded in these logbooks. The pre flight inspection must be conducted by the PIC for that operation. Preflight sign-off shall include at least the following information: date of operation , Aircraft Total time , aircraft serial or operating number, PIC signature and certificate number. Example: Preflight inspection completed, No defects noted. 1-1-15, AC FIT 50.l hours, VAS number 1, (2). Any required maintenance, inspection, alterati on or repair must be completed by an approved person. At the completion of this work the approved person must make an entry in the aircraft log book that at least includes: Date, Aircraft serial or op erating number, brief description of the discrepanc y, inspection, alteration or repair, the reference mat erial used as guidance for the repair, statement approving the aircraft for return to service, and s ignature of person who completed the work. Example: 1-1-15 UAS #XXX, 50. hours, replaced numbe r 3 rotor with new rotor, in accordance with DJI Inspire User Manual. Flight or ops check completed. Aircraft is approved for return to service. PIC signature and certificate number. (3).Maintenance records shall be kept with the UAS at all times and shall be made available to any authorized agency or the Administrator upon request

. **F. Pilot in Command Requirements** (1).The Pilot in Command shall hold at least a Priv ate Pilot Certificate and a current Third Class Med ical whenever conducting operations. Operator prefers th at the Certificate be in the most appropriate Class and Category to the UAS being operated.Page **10** of **11**

(2). The Pilot in Command shall have accumulated an d logged a minimum of 200 flight cycles and 25 hours of rotorcraft UAS flight time before performi ng any operation for which exemption is requested. (3). The Pilot in Command shall have at least 5 hou rs in make and model before performing any operation for which exemption has been requested. (4).The Pilot in Command shall perform a pre-flight inspection before each flight is conducted, (5).The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptio ns of the exemptions requested by the operator. In tho se cases the Pilot in Command shall adhere to company operating standards or Federal Aviation Adm inistration Limitations placed upon exemptions, whichever is more stringent. (6). The Pilot in Command will not operate the UAS without a Visual Observer present. (7). The Pilot in Command must have 3 takeoff and l andings within the preceding 90 days. (8). The Pilot in Command must maintain a record of flight information to establish currency and that he or she meets the requirements of this section. (9). The Pilot in Command will utilize eye protecti on in the event that sun glare would reduce YLOS operations. G. Visual Observers: Responsibilities and Requireme nts (1). A Visual Observer shall be used during any and all operations of the UAS System. (2). The Visual Observer shall maintain verbal comm unication with the PIC at all times during UAS operation. (3). The Visual Observer shall maintain Visual Cont act with the UAS at all times. In the event that Vi sual Contact is lost the VO will notify the PIC who will immediately cease operations and land the aircraft

. (4). The Visual Observer shall also help the PIC ma intain area of operations security and ensure that all non-essential persons remain clear of the area of o perations. In the event of a breach by unauthorized person(s) the VO shall notify the PIC and operation s will cease immediately. (5).The Visual Observer shall also assist the PIC i n looking for manned aircraft traffic near the oper ations area. If manned aircraft traffic is observed near t he operations area, the VO will notify the PIC who will immediately cease operations and land the UAS. (6). The VO will utilize eye protection in the even t that sun glare would reduce VLOS operations. **H. Reporting of Incidents and or Accidents** Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA w ill be reported within 24 hours to: FAA UAS Integration Office (AFS-80) Accidents: National Tra nsportation Safety Board ( www.ntsb.gov .)Page **11** of **11**

**The Public Interest** The request for this exemption is in the Public Int erest as it is safe to assume that there are many consumer applications for the services that can be provided by UAS. It is clear that the Congress of t he United States, the business sector, and the consume r want to integrate UAS into the NAS and utilize their unique and cost effective capabilities. It is also in the Public Interest that many of the low l evel flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant and environmentally friendly unmanned air craft that can operate at a fraction of the cost to both the operator and consumer. These aircraft can be operated without risk of loss to life or limb, a nd without significant financial impact to the operato r or any person or property on the ground in the ev ent of the loss of an aircraft. Utilizing these UAS wil l create a safer more productive work environment, reduce environmental pollution and have a positive impact on the local community which is in the Publi c Interest. Finally, the petitioner believes that gra nting this exemption would help to further by Administrative process the integration of UAS syste ms and the possibility to help create additional regulations and guidance to be used as these system s become more widely utilized. Please forward any comments or questions you may ha ve to ktopham84@gmail.com

.

Sincerely,

V1 Media Kenneth R. Topham III, President