Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 Maryland Sky Pics, Inc.

8627 Lawrence Hill Road Perry Hall, MD 21128

410-933-9393 joe@mdskypics.com

March 10, 2016

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

RE: Exemption Request Section 333 of th e FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C. F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407( a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Mode rnization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, MARY LAND SKY PICS INC (“the applicant”), developer and operator of Sm all Unmanned Aircraft Systems (“sUASs”) equipped to

conduct aerial photography for reside ntial and commercial real es tate properties for real estate professionals, provide aerial photography for other commercial applications such as construction and roofing companies and provide aerial video and photography to other professionals in need to services not practic al to land based equipment and hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and

under the conditions outlined herein or as ma y be established by the FAA as required by

Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned, and relativ ely inexpensive sUAS under controlled conditions in airspace that is 1) limited, 2) pr edetermined, 3) controlled as to access, and 4) would provide safety enhancements to the al ready safe operations in the infrastructure and business operations presently using conven tional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...estab lish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

MARYLAND SKY PICS INC Attn: Joseph Gladden

Ph: 410-933-9393Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 2 Email: joe@mdskypics.com Address: 8627 Lawrence Hill Road Perry Hall, MD 21128

Regulations from which the exemption is requested:

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

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exemption application is expressl y submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unm anned aircraft systems may operate safely in the national airspace system (NAS) befo re completion of the rulemaking required

under Section 332 of the Reform Act. In maki ng 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 capability;

 Operation of the UAS in close proximity to airports and pop ulated areas; and

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

Reform Act § 333 (a). Lastly, 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 th e FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes sUASs, from the requirement that all

civil aircraft must have a curre nt airworthiness certificate.

1 Maryland Sky Pics, Inc. interprets this provision to place the duty on the Ad ministrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 3 The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a ) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exempti on in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 US C §44704; 14 CFR §91.203 (a) (1).

Maryland Sky Pics Inc’s sUAS (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including payload. They operate under normal conditions at a speed of no more than 25 to 45 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. They will operate only in lin e of sight and will operate only within the

sterile area described in the Unmanned Aircra ft Systems Operations Manual, attached as Appendix 2 (hereinafter “the Manual”). Such operations insu re that the sUAS does “not create a hazard to users of the national airspace system or the public.” 2

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, Maryland Sky Pi cs, Inc. falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisione d that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also

due to the size of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security i ssue. Given the clear

direction in Section 333 of the Reform Ac t, the authority contained in the Federal Aviation Act, as amended; the strong equiva lent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emi ssions associated with allowing UASs for aerial photography, the granting of the requested exemptions is in the public interest. Accordingly, Maryland Sky Pics, Inc. resp ectfully requests that the FAA grant the requested exemption without delay.

Background Information

Maryland Sky Pics, Inc. is in the busine ss of aerial photography for real estate professionals and construction companies. Ma ryland Sky Pics, Inc.’s clients look to Maryland Sky Pics, Inc. for safe operations of sUAS. Maryland Sky Pics, Inc. has developed specific safe UAV operational pr ocedures. Increasingl y, the Maryland Sky Pics, Inc. has clients looking for sUAS serv ices for aerial photography that offers safer and cleaner methods of pr oviding this technology.

Operations performed by the Maryland Sky Pics will include:

Aerial photography of re sidential and commercial properties for sale Aerial photography of Construction sites Aerial photography of agricultural land Aerial photography of personal even ts such as weddings and parties

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

2 Reform Act Section 333 (b).Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 4 Maryland Sky Pics, Inc. propos es that the exemption request ed herein apply to civil

aircraft that have the characte ristics and that operate within the limitations listed herein. These limitations provide for at least an equi valent or even higher level of safety to operations under the current regulatory st ructure because the proposed operations represent a safety enhancement to the al ready safe aerial photography conducted with

conventional aircraft.

These limitations and conditions to which Ma ryland Sky Pics, Inc. agrees to be bound when conducting commercial operations under an FAA issued exemption 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 total flight time for each operati onal flight will be 30 minutes. Flights will be terminated at 25% battery power re serve should that occur prior to the 30

minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platfo rm from which flight is planned.

5. Minimum crew for each operation will consis t of the sUAS Pilot and the Visual

Observer.

6. The sUAS pilot-in-command (PIC) will ho ld either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold

a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puer to Rico, a territory, a possession, or the Federal government

7. If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on site , that person can also be designated as

PIC.

8. The sUAS will only operate within defi ned boundaries as outlined in Section 8.4

of the Manual.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each mission. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropr iate Flight Standards District Office (FSDO).

11. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 f eet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination, as requir ed by Section 8.4 of the Manual. With the advanced permission of the relevant FS DO, operations at cl oser range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed mission as required in Section 8.1 of the Manual. Items will

include:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS mission conducted under this petition of exemption;Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 5 c. Make, model, and serial or N-number of UAS to be used;

d. Name and certificate number of UA S PICs involved in the mission;

e. A statement that the operator has obtained permission from property

owners and/or local offici als to conduct the mission;

f. The list of those who gave permissi on made available to the inspector

upon request;

g. Signature of exemption-holde r or representative; and

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

13. Pilot and observer will have been trai ned in operation of UAS generally and received up-to-date information on the part icular UAS to be operated as required

in Sections 7.4 and 7.5 of the Manual.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral permission from the relevant property holders will be

obtained.

16. 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.

17. If the sUAS loses communications or lose s its GPS signal, the UAS will have the capability to return to a pre-determined location within the S ecurity Perimeter and

land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

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

Subpart H, entitled Airworthiness Cert ificates, establishes the procedural requirements for the issuance of airworthin ess certificates as required by FAR §91.203 (a) (1). Given the size and limite d operating area associated with the aircraft to be utilized by Maryland Sky Pics, Inc., an exemption from Part 21 Subpart H m eets the requirements of an equivalent level of safety under Pa rt 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 fr om the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of th e particular UAS. In all cases, an analysis

of these criteria demonstrates that the UAS operated without an airw orthiness certificate,

in the restricted environment and under the cond itions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no expl osive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and observer, pursuant to the Manual’s policies, and under and in compliance with local public safety requirement s, to provide security for the area ofMaryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 6 operation as is now done with conventi onal aerial photography. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with aerial phptogra phy, 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 ther e is no credible threat to national security posed by the UAS, 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 cap ital letter "N" and the registration number is displayed on limited, restrict ed or light-sport category aircraft or experimental or provis ionally certificated airc raft, 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 UAS will have no airworthine ss certificate, an exemption may be

needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of sa fety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilo t, observer and others working with the

sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167A.

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

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a pilot’s certificate operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and re stricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in th e Manual exceeds that provided by a single individual holding a commercial pilot’s certif icate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of riskMaryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 7 associated with commercial operations cont emplated by Part 61 when drafted, that allowing operations of the sUAS as requested by a pilot’s certificate as the PIC exceeds the present level of safety achie ved by 14 C.F.R. §61.113 (a) & (b).

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 airwor thiness certificate issued for the aircraft, should this exemption be granted, no FAA regul atory standard will exist for determining

airworthiness. Given the size of the aircraft and the requireme nts contained in the Manual for maintenance and use of safety checklists pr ior to each flight, as set forth in Sections 9.1 and 9.6, 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 Ma nual is not required by §21.5 of this chapter, unless there is av ailable in the aircraft a current approved airplane or Rotorcraft Flight Manual, appr oved 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 becau se there is no pilot on board, but because there is no room or capacity to car ry such an item on the aircraft.

The equivalent level of safe ty will be maintained by keeping the flight manual at the ground control point where the pilot flying th e sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in co mmand to take certain actions before flight to insure the safety of flight. As FAA approved rotorcra ft flight manuals will not be provided for the aircraft, an exemption will be needed. An equivalent level of safety will be provided as set forth in Sections 8 and 9 of the Manual. 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 fli ght instruction unless that aircraft has fully functioning dual controls.Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 8 sUASs and remotely piloted aircraft, by their design do not ha ve fully functional dual controls. Flight control is accomplis hed through the use of a control box that

communicates with the aircraft via ra dio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instru ction in experimental aircra ft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provi ded 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: Mini mum safe altitudes

Section 91.119 establishes sa fe 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 platfo rm from which operati on is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will, however, be operated in a restri cted area with a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained

consent.

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

of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property ow ner or local officials. Beca use of the advance notice to the property owner and participan ts in the mission, all affected individuals will be aware of the planned flight operat ions as set forth in Sectio n 6.2, 8.1, and 8.2 of the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less th an those presently presented with conventional aircraft operating at or below 500 AGL in the aeria l photography business. In addition, the lowaltitude 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 availabl e before departure.” As the sUAS may not have a barometric altimeter, but instead a G PS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and safety checklist, confirming the al titude of the launch site shown on the GPS

altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirement s for Flight in VFR ConditionsMaryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 9 Section 91.151 (a) prohibits an individual fr om 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 fo r 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 re quirement in 14 CF R §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the UAS’s proposed flight area and the loca tion of its proposed operations within a predetermined area, a longer time frame for flig ht in daylight or night VFR conditions is

reasonable.

Maryland Sky Pics, Inc. believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. S ee Exemption 10673 (allowing Lockheed Martin Corporation to operate without complian ce with FAR 91.151 (a)). 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 Sec tion 91.151(a) was intended to alleviate given the size and speed of the sm all UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will be granted.

Maryland Sky Pics, Inc. believes that an equivalent level of safety can be achieved by limiting flights to 20 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.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no pe rson may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current ai rworthiness 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 issued under §91.715 is di splayed at the cabin or cockpit entrance so that it is legi ble to passengers or crew.

The UAS 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.Maryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 10 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 immedi ate access to them, to the extent they are applicable to the sUAS. The FAA 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

These regulations require that an aircra ft operator or owner “shall have that aircraft inspected as prescrib ed 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 ch apter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not apply to the Maryland Sky Pics, Inc.. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual (See Sections 8.6 and 9). An equivalent level of safety will be

achieved because these small UASs are ve ry 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 UAS can land immediately an d will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating f light, perform required maintena nce, 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.

Pursuant to 14 C.F.R. Part 11, the follo wing summary is provided for publication in the Federal Register, should it be de termined that publication is needed:

Maryland Sky Pics, Inc. seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F. R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unma nned vehicle (55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commerci al operations of sUASs in the aerial photography business will enhance safety by reducing risk. Conventional aerial photography, using jet or piston power aircraft , operate at extremely low altitudes just feet from the infrastructure being inspecte d and in extreme proximity to people and structures; and present the risks associated w ith vehicles that wei gh in the neighborhood of 4,000lbs, carrying large amounts of jet A or ot her fuel. Such aircraft must fly to and from the work location. In contrast, a sUAS weighing fewer than 55 lbs. and powered byMaryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 11 batteries eliminates virtually all of that risk given the reduced mass and lack of

combustible fuel carried on board. The sUAS is carried to the worksite and not flown. The sUAS will carry no passengers or crew and, therefore, will no t expose them to the

risks associated with ma nned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equi valent level of safety supporting the grant of the exemptions requested herein, includ ing exempting Maryland Sky Pics, Inc. from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional ope rations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or contro lled access property with the property owner’s prior consent and knowledge. Aerial photography will be performed for people who have also consented for work to be performed or ot herwise have agreed to be in the area where UAS flight will take place.

Conclusion

Satisfaction of the criteria pr ovided in Section 333 of the Reform Act of 2012 – size, weight, speed, operating capabilities, proxi mity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Maryland Sky Pics, Inc.’s UAS in the ae rial photography business pursuant to the Manual appended hereto.

Sincerely,

Joseph W. Gladden

President Maryland Sky Pics, Inc.

Cc., Joseph W. GladdenMaryland	Sky	Pics,	Inc.	8627	Lawr ence	Hill	Road	Perry	Hall,	MD 21128 i Appendix 1

1.1 – DJI Phantom Inspire 1

See Attached Flig ht Manuals: DJI Inspire 1 Manual

1.2 – DJI Phantom 3 Professional

See Attached Flig ht Manuals:

DJI Phantom 3 Professional Manual

Appendix 2

Please see the attached: Maryland Sky Pics, Inc. sUAS Operating Manual Maryland Sky Pics, Inc. sUAS Pre-Flight Safety Checklist