Texas	Aerial	Solutions,	FAA	Section	333	Exemption

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

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal

Aviation

Regulations	from:	14	CFR	21	subpart	H;	14	CFR 45.23(b);	14	CFR	61.113(a)	and	(b);	14	CFR	91.7(a);	14 CFR91.9(b)(2);	14	CFR	91.103;	14	CFR	91.109;	14	CFR	91.119(c);	14	CFR	91.121;	14	CFR	91.151(a);	14	CFR 91.203	(a)	and	(b);	14	CFR	91.405	(a);	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)(1)	and	(2);	14	CFR 91.417(a)	and	(b)

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14 CFR	Part	11, Texas	Aerial	Solutions ,	operator	of	an	Unmanned	Aircraft	System	(UAS),	hereby	applies	for an	exemption	from the	listed	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its UAS,	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.

Texas	Aeria l	Solutions has	tailored	its	operations	to	meet	the	requirements	established	by	the	FAA	in	its Grant	of	Exemption #12801, Olympic	Aerial	Solutions, and Regulatory Docket No. FAA

− 2015

− 2608,

Name	and	Contact	Information	of	Applicant:

Texas	Aerial	Solutions Contact:	Thomas	J	Sivley	II 4109	E	Bankhead	Hwy Hudson	Oaks,	TX		76087 tjsivley@texasaerialsolutions.com

Regulations	from	which	the	exemption	is	requested:

14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113	(a)	&	(b) 14	CFR	91.7	(a) 14	CFR	91.9	(b) (2)

14	CFR	91.103
14	CFR	91.109 14	CFR	91.119	(c)

14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a)	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)Texas	Aerial	Solutions,	FAA	Section	333	Exemption

2 Scope	of	Operations:

Commercial	operation	of	an	UAS,	as	descri bed	herein,	which	are	equipped	with	camera(s)	and	sensors, would	operate	in	the	following	manner:

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate, architecture,	land	surveying,	engineering	and	other	related	professional activities.

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	television,	public events,	cinematography	and	news	gathering

• Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the owners	or	local	g overnment	authority.

• Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.

• Aerial	video/photography	or	providing	live	video	feed	to	assist	with	s earch	and	rescue operations	in	cases	of	an	emergency	or	natural	disaster	when	local	authorities	or	government has	requested	it	by	contract	or	donation.

• The	ability	to	offer	training	to	persons	individually	or	belonging	to	both	private	and/or	public organi zations	that	have	interests	in	the	use	and	application	of	a	UAS	for	the	purpose	of	the	safe operation	of	a	UAS	to	enhance	the	safety	of	the	National	Airspace	System	(NAS)	as	well	as	for the	protection	of	the	persons	and	property.

• Oil	and	Gas plants and ne w /existing construction of	gas	plants	and	refineries

• Wind	Turbine Farm Inspection ,	Inspection	of	Blades	and	Generators

• Solar	Farm	Inspections

• Utility	Inspection

, Railroad infrastructure Inspection

, Pipeline	Inspection

, Oil

- Field	Inspection

• Petro/Chemical/ Manufacturing	Inspection

• Threat	Assessment	of	High	Security	Facilities	for	private	Military and	Security Contractors

As	detailed	below,	the	requested	exemption	would	permit	the	operation	of	a	UAS	under	controlled conditions	in	the	NAS	that	would	be	a)	lim ited	b)	controlled	c)	and	will	provide	safety	enhancements	to the	already	safe	operations	in	the	industry	presently	using	conventional	aircraft.	Approval	of	this exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA Administrator’s)	responsibilities	to	“....establish	requirements	for	the	safe	operation	of	such	aircraft systems	in	the	national	airspace	system.



### UAS	to	be	used

Texas	Aerial	Solutions will	operate	the	DJI	Phantom and	S series	of	remote	control	model

aircr aft.	Specifically	the	Phantom 3	Professional/Advanced ,	DJI	S900,	DJI	S1000 and DJI	Inspire

1

. (Note:	All	Phantom	models	are	based	upon	the	same	airframe	and	control	technology	with similar	specifications	and	performance.)Texas	Aerial	Solutions,	FAA	Section	333	Exemption

3 UAS	Model	Specifications

DJI
Phantom

3 DJI	S900 DJI	S1000 DJI	Inspire	1

Weight	(w/	Batt.	And	Props) 1280g 32kg 35 k g 2935g

Diagonal	Size	(Motor	to	Motor) 350mm 900mm 1045mm 581mm

Max	Ascent	Speed 5	m/s N/A N/A 5m/s
Max	Descent	Speed 4	m/x N?A N/A 4m/s
Max	Speed 16m/s 31	Knots 31	knots 22m/s
Operating	Temperature 0°C

- 40°C

- 10°c	to	+40°c

- 10°c	to	+40°c 0°c	to	+40°c
Operation	Freq.	Band 2.4	ghz 2.4	ghz 2.4	ghz 2.4ghz

Battery 4500	mah 18,000	mah	LIPO 22,000	mah	Lipo 4500	mah

Phantom	3	Advanced/Pro fessional Manual http://download.dji

- innovations.com/downloads/phantom_3/jp/Phantom_3_Professional_User_Manual_v1.0_jp.pdf Inspire	1	Manual http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

DJI	S900 http://download.dji

- innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

DJI	S1000 http://download.dji

- inno vations.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf

National	Security

The	small	size	of	these	UAS	and	the	limited	scale	of	operations	in	conjunction	with	adherence	to	the Reform	Act’s	safety	requirements	present	no	national	security	issues.

Public	Interest

Services	utilizing	small	UAS	for	aerial	photography,	videography,	surveying,	mapping,	equipment inspections	and	auditing	provides	a	much	lower	cost	and	higher	level	of	safety	to	the	public	due	to	the
small	scale	of	aircraft	relative	to full

- scale aircraft	operations.

Operational	Safety

• The	UAS	will	not	be	operated	at	a	speed	exceeding	50	mph.

• The	UAS	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).

• The	UAS	will	be	operated	within	visual	line	of	si ght	(VLOS)	of	the	PIC	at	all	times.	This	requires the	PIC	to	be	able	to	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as specified	on	the	PIC’s	FAA

- issued	airman	medical	certificate	or	U.S.	driver’s	license.

• All	operations	must	uti lize	a	visual	observer	(VO).	The	UA	must	be	operated	within	the	visual	line of	sight	(VLOS)	of	the	PIC	and	VO	at	all	times.

• The	operator	is	responsible	for	maintaining	and	inspecting	the	UAS	to	ensure	that	it	is	in	a condition	for	safe	operation.Texas	Aerial	Solutions,	FAA	Section	333	Exemption

4 • Prior to	each	flight,	the	PIC	must	conduct	a	pre

- flight	inspection	and	determine	the	UAS	is	in	a condition	for	safe	flight.

• PIC	will	hold	either	an	airline	transport,	commercial,	private,	recreational,	or	sport	pilot
certificate.	The	PIC	will	also	hold	a	curr ent	FAA	airman	medical	certificate	or	a	valid	U.S.	driver’s license	issued	by	a	state,	the	District	of	Columbia,	Puerto	Rico,	a	territory,	a	possession,	or	the Federal	Government.	The	PIC	must	also	meet	the	flight	review	requirements	specified	in	14	CFR § 61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	her	pilot	certificate.

• No	operations	will	be	conducted	at	night,	as	defined	in	14	CFR	§	1.1.	All	operations	will	be conducted	under	visual	meteorological	conditions	(VMC).

• No	operations	will	be	c onducted	within	5	nautical	miles	of	an	airport	reference	point	(ARP)	as denoted	in	the	current	FAA	Airport/Facility	Directory	(AFD)	or	for	airports	not	denoted	with	an ARP,	the	center	of	the	airport	symbol	as	denoted	on	the	current	FAA

- published	aeronautic al chart,	unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained	or	otherwise permitted	by	a	COA	issued	to	the	exemption	holder.

• All	operations	shall	be	conducted	over	private	or	controlled

- access	property	with	permission from	the	proper ty	owner/controller	or	authorized	representative.	Permission	from	property owner/controller	or	authorized	representative	will	be	obtained	for	each	flight	to	be	conducted.

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

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	operating	area
associated	with	the	aircraft	to	be	utiliz ed	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	meets the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	Reform	Act.	The Federal	Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	the	Reform	Act	both	authoriz e	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 UAS.	In	all	cases,	an	analysis	of	the se	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	aircraft	(fixed	wing	or	rotorcraft)	operating	with an airworthiness	certificate	without	the	restrictions	and	conditions	proposed.

The	UAS	to	be	operated	hereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger, carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operate s	exclusively	within	a	secured	and designated	area.	Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly	controlled and	monitored	by	both	the	operator	and	under	the	requirements	and	in	compliance	with	local	public safety	requirement s.	These	safety	enhancements	provide	a	greater	degree	of	safety	to	the	public	and property	owners	than	conventional	operations	conducted	with	airworthiness	certificates	issued	under 14	C.F.R.	Part	21,	Subpart	H.

Lastly,	application	of	these	same	criteria demonstrates	that	there	is	no	credible	threat	to	national security	posed	by	the	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.Texas	Aerial	Solutions,	FAA	Section	333	Exemption

5 14 C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft

The	regulation	requires: When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is	displayed	on limited,	restricted	or	light

- sport	category	aircraft	or	experimental	or	provisionally certificated	aircraft, the	operator	must	also	display	on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station, in	letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	"limited,"	"restricted,"	"light

sport,"	"experimenta l,"	or	"provisional,"	as	applicable. Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption	may	be	needed	as	the	UAS will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	“Experimental”	can	be placed.	Given	the	s ize	of	the	UAS,	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	safety	will	be	provided	by	having	the	UAS	marked	on	its	fuselage	as	required	by §45.29	(f )	where	the	pilot,	observer	and	others	working	with	the	UAS	will	see	the	identification	of	the

UAS	as “Experimental.”

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

Pursuant	to	14	CFR	61.113	(a)	&	(b),	no	pe rson	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in command	of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	V

- Tail	Aviation Inc.	may	achieve	an	equivalent	level	of	safety	as	achieved	by	current	Regulations	beca use	the	applicant’s UAS	do	not	carry	any	pilots	or	passengers	nor	property.	The	risks	attendant	to	the	operation	of	UAS	is
far	less	than	the	risk	levels	inherent	in	the	commercial	activities	outlined	in	14	CFR	61.	The	PIC	of	the
UAS	will	have	a	Commercial Pilot’s	License	along	with	a	current	Third	Class	or	higher	Medical	exceeding the	current	safety	levels	in	relation	to	14	CFR	61.113	(a)	&	(b).	I	feel	the	operation	and	limitations	set forth	in	the	FOM	will	equate	to	the	safe	operation	of	the	UAS.

14	C.F.R .	§91.7(a):	Civil	Aircraft	Airworthiness.

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	As there	will	be	no	airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	no FAA	regulatory	standard	will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	for maintenance	and	use	of	safety	check	lists	prior	to	each	flight	an	equivalent	level	of	safety	will	be provided.

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

Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.

- registered	civil	aircraft	...	(2)	For	which	an Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapter,	unless	there	is	available	in
the	airc raft	a	current	approved	airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material, markings,	and	placards,	or	any	combination	thereof.	The	UAS,	given	its	size	and	configuration	has	no ability	or	place	to carry	such	a	flight	manual	on	the	aircraft,	no t	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	beTexas	Aerial	Solutions,	FAA	Section	333	Exemption

6 maintained	by	keeping	the	flight	manual	at	the	ground	control	point	where	the	pilot	flying	the UAS	will
have	immediate	access	to	it.

14	C.F.R.	§	91.103:	Preflight	Action.

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be	prov ided	for	the	aircraft	an	exemption will	be	needed.	The	PIC	will	take	all	actions	as	stated	in	the	manufactures	operating	manuals.

14	C.F.R.	§91.109:	Flight	Instruction.

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manne d	free	balloon)	that is	being	used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	UAS	and remotely	piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual	controls.	Flight	control	is accomplished	through	the	us e	of	a	control	box	that	communicates	with	the	aircraft	via	radio communications.	The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	eq uivalent	level of	safety	is	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by the	small	size	and	low	speed	of	the	aircraft.

14	C.F.R.	§91.119:	Minimum	Safe	Altitudes.

Section	91.119	establishes	safe	altitud es	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	UAS	that	is	a	helicopter	and	the	exemption	requests	authority	to	operate	at	altitudes	up	to	400 AGL,	or	not	more	than	200	above	an	elevated	platform	from	which	filming	is	planned,	an	exemption may	be	needed	to	allow	such	operations.	As	s et	forth	herein,	the	UAS	will	never	operate	at	higher	than 400	AGL	with	the	exception	that	in	circumstances	where	the	UAS	is	used	to	survey	or	photograph	a structure	whose	height	exceeds	400	feet	AGL,	the	UAS	will	not	be	operated	more	than	200	feet	above

t he	highest	point	on	the	structure.	It	will	however	be	operated	in	a	restricted	area	with	security perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	without	their	pre

- obtained

consent. The	equivalent	level	of	safety	will	be	achieved	g iven	the	size,	weight,	speed	of	the	UAS	as	well	as	the location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of	the	property	owner	or local	officials.	Because	of	the	advance	notice	to	the	property	owner	and	participants	in	any	opera tional activity,	all	affected	individuals	will	be	aware	of	the	planned	flight	operations.	Compared	to	flight operations	with	aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	55lbs.	proposed	herein	and the	lack	of	flammable	fuel,	any	risk	associat ed	with	these	operations	is	far	less	than	those	presently presented	with	conventional	aircraft	operating	at	or	below	500	AGL.	In	addition,	the	low

- altitude operations	of	the	UAS	will	ensure	separation	between	these	UAS	operations	and	the	operations	of

conv entional	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	d eparture	airport	or	an	appropriate	altimeter	setting available	before	departure.”	As	the	UAS	may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitudeTexas	Aerial	Solutions,	FAA	Section	333	Exemption

7 read	out,	an	exemption	may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the	operato r, pursuant	to	the	safety	check	list	and	live	flight	data	monitoring,	confirming	the	altitude	of	the	launch site	shown	on	the	GPS	altitude	indicator	before	flight. 14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Section	91.151	(a) prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	under	VFR	conditions unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of intended	landing,	and,	assuming	normal	cruising	speed

– (1)	Dur ing	the	day,	to	fly	after	that	for	at	least 30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.” The	battery	powering	the	UAS	provides	approximately	30	minutes	of	powered	flight.	To	meet	the	30 minute	reserve	requirement	in	14	CFR	§91. 151,	UAS	flights	would	be	limited	to	approximately	10 minutes	in	length.	Given	the	limitations	on	the	UAS’s	proposed	flight	area	and	the	location	of	its proposed	operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in	daylight	or	twilight VFR	conditions	is	reasonable.	Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within the	scope	of	prior	exemptions.	Operating	the	UAS,	in	a	tightly	controlled	area	where	only	people	and property	owners	or	official	representatives	who	hav e	signed	waivers	will	be	allowed,	with	less	than	30 minutes	of	reserve	fuel,	does	not	engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to alleviate	given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	UAS	flights	to	10	minutes

wo uld	greatly	reduce	the	utility	for	which	the	exemption	will	be	granted.	Applicant	believes	that	an equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	minutes	or	25%	of	battery	power

— whichever	happens	first.	This	restriction	would	be	more than	adequate	to	return	the	UAS	to	its	planned landing	zone	from	anywhere	in	its	limited	operating	area.

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

The	regulation	provides	in	pertinent	part: (a)	Except	as	pr ovided	in	§	91.715,	no	person	may	operate	a	civil	aircraft	unless	it	has	within	it	the following:	(1)	An	appropriate	and	current	airworthiness	certificate.	.	.	. (b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by	p aragraph	(a) of	this	section	or	a	special	flight	authorization	issued	under	§91.715	is	displayed	at	the	cabin	or	cockpit entrance	so	that	it	is	legible	to	passengers	or	crew. The	UAS	fully	loaded	weighs	no	more	than	55	lbs.	and	is	operated	without	an	onbo ard	pilot.	As	such, there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to	display	them	on	the

UAS. An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground	control	point where	the	pilot	flying the	UAS	will	have	immediate	access	to	them;	to	the	extent	they	are	applicable	to
the	UAS.

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

These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	t hat	aircraft	inspected	as prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter...,”	and others	shall	inspect	o r	maintain	the	aircraft	in	compliance	with	Part	43.	Given	that	these	section	and Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	not	apply	to	the applicant. The	operator	pursuant	to	the	flight	manual	and	operating	hand book	will	accomplish

maintenance .	An	equivalent	level	of	safety	will	be	achieved	because	the	UAS	is	very	limited	in	size	and will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	a	limited	period	of	time.	If	mechanicalTexas	Aerial	Solutions,	FAA	Section	333	Exemption

8 issues	arise	the	UAS	ca n	land	immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	The operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	the	operat or	is	the	person	most familiar	with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	provide	the equivalent	level	of	safety.	An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and inspections	will	be	perfor med	in	accordance	with	the	UAS	Manufacturer's	User	Manual.	As	provided	in the	FOM,	the	operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight	and	perform required	maintenance	needed.

This	application	for	exemption	respectfully	su bmitted	by:

Texas	Aerial	Solutions 4109	E.	Bankhead	Hwy. Hudson	Oaks,	TX		76087

817

- 565

- 6376 tjsivley@texasaerialsolutions.com

Thomas	J	Sivley Owner,