II

I ! II HAGEN

j WILKA

j ARCHER

600 South Main Ave, Ste 1021 PO Box 9641 Sioux Falls, SO 57101-0964 Phone 60513341 0005 Fax 605133414814 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue S.E. Washington, DC 20590

E -Ma il: m a r k 1 i!) h wa l aw

.co m June 8, 2015 Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2);
14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2);

14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b);
14 C.F.R. 91.119(b) and (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409 and 14 C.F.R. 91.417 Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Hagen, Wilka & Archer, LLP on behalf ofNeedmore Towers, Inc. ("NTI"), an operator of Small Unmanned Aircraft Systems ("sUAS") equipped
to conduct aerial inspection of cellular towers, 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 may be established by the FAA as required by Section 333. The intended sUAS operations contemplated
by this petition are in the public interest because they: replace work that is Dangerous and Difficult and at the same time provide an equivalent
or greater level of safety than alternative manned aircraft operations. Approval of exemptions for NTI will allow commercial operations of the DJI S 1000 to examine cellular towers and structures in Class G airspace nationwide. The requested exemption should be granted because operation of small UASs, weighing approximately 24.25 lbs. (11kg.), inclusive of battery and payload, conducted
in the strict conditions outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed-wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity
to the ground, power lines, transmission HAGEN, WILKA
& ARCHER, LLP, Attorneys and Counselors Joel T .HAGEN % I Thomas

K .WILKA

' I John
F .ARCHER

I Jennifer

L. RILEY"

" I Jennifer

L. LARSEN

I Mark A .**EKSE**
**~**I Jaclyn
R .S .ABERSON

" ' I Joseph
M .WILTSE Also .1dmitted

i n :1 Oistlic1 of Co l umbi.1,

0 **Minn~ota,**'Iowa, TrlOfth Dakota

I '.\ of counsei[

.. Registcred Patt'nt AttomcyU.S. Department of Transportation June 8, 2015 Page2 towers, pipelines, and people. The sevenfactors Congress directed the FAAtoconsider when approving Section 333 exemption petitions- size, weight, speed

,operational capability, proximity
to airports, proximity
to populated areas,and operation within visual line of sight- each supportthe request.In particular

,the aircraft aresmall, and will operateatslow speeds, and close tothe ground in order tomore safely and efficiently conduct inspections that would otherwise involve

arisk of death tothe inspectors. The substantial increase of safety and decrease of risk tohuman life, coupled with the low risk useof sUASs toconduct these inspections, weighs heavily in favor or granting the exemption. Pursuantto14 C.F.R. 11.35, NTI requestsconfidential treatmentfor certain information provided with this requestfor exemption

.Specifically, NTIis submitting its proprietary user manual and training syllabus under separatecoverasExhibits 19and 20. It requeststhat the information contained
in those exhibits notbe made public because they aretrade secretswhose disclosure would harm NTI. They arevaluable commercial data thatisnot publically available and are protected from release under the Freedom oflnformation Act5 U.S.C. 552(b)(4). For youreasein reviewing this petition

,please refer tothe table of contentswhich begins onpage2.If wecan provide anyadditional information

toassist your understanding

orreview of this document, please do nothesitate tocontactusat605-334-0005

orvia e-mail at mark@hwalaw.com. Thank you

. Best regards

, MarkA.Ekse MAE:ch