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July 27, 2015 Ira McComic Managing Member UAS Flight Services LLC 2128 Heather Hill Lane Plano, TX 75075 U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590 Ref: Request for exemption under section 333 of the FAA Modernization and Reform Act Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act (FMRA) and 14 CFR Part 11, UAS Flight Services LL C hereby requests a grant of exemption from certain Federal Aviation Regulations fo r the purpose of employing Unmanned Aircraft S ys tems (UAS) for commercial on

- demand operations that include: • Agricultural data collection and monitoring • Wildlife and forestry

monitoring • Support of public entity operations • Search and rescue operat ions • Accident/incident survey and investigation • Aerial inspection, video, and photograph y of residential and commercial utility infrastructures • Maritime aerial operations • Security monitoring • Aerial inspection, video, and photograph y of residentia l and commercial propert y and structures • Aerial video, photography and filming, including cinematography • Training in the operation and applications of UAS **Aircraft to be employed in these operations** In compliance with the exemption, UAS Flight Servic es LLC will operate the following aircraft: DJ I Phantoms, DJIInspire 1, and 3DR Solo. **Name and contact information of petitioner:** UAS Flight Services LLCPage 2

2128 Heather Hill Lane Plano, TX 7507 Email: uasflightservices@gmail.com **Regulations from which t he 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) 14 CFR. 91.103 14 CFR. 91.109(a) 14 CF R. 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 407(a) (1) 14 CFR 409(a)(2) 14 CFR 417(a)(b) **Aircraft and Equivalent Level of Safety** Section 333 of the FMRA authorizes the FAA to assess which t ypes of unmanned aircraft sy stems may

be operated safel y in the national air space. The considerations included in that assessment are size, weight, speed, operational capability , proximity to airports and populated areas, and operation within visual line of sight. Furthermore, if the Secretary determines that certain unmanned aircraft s ys tems may operate safel y in the national airspace, the Secretary

shall establish requirements for the safe operation of such unmanned aircraft s ys tems in the national airspace.
As enumerated and described in the Conditions and L imitations below, the applicant proposes that the operatio n of its small UAS within these limits and under these conditions provide for the safe operation of those aircraft in the national airspace and provide at least an equivalent level of safety to operations conducted under existing regulations using larger a ircraft.
**Conditions and Limitations** The conditions and limitations to which the operator agrees to be bound when conducting commercial operations under an FAA issued exemption are: 1. Operations authorized by the grant of exemption will be limited to th e following Unmanned Aircraft (UA): DJIPhantoms, DJ I Inspire 1, and 3DR Solo, and whenPage 3

weighing less than 55 pounds including payload. These are UA models that have been previously

documented and approved for exemption. 2. For operations for the purpose of closed

- set motion picture and television filming, the conditions and limitations enumerated as 29.), 30.) and 31.) shall appl y. 3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). Either groundspeed or calibrated airspeed will be used to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL. 5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Command (PI C) at all times. The PIC will use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations shall utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The VO and PI C shall be able to communicate verbally at all times. Electronic messaging or texting will not be permitted during flight operations . The PI C will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C will ensure that the VO can perform the duties required of the VO. 7. The exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in the grant of exemption (“the operating documents”) will be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exi sts between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations in the exemption would take precedence and will be followed. Otherwise, the operator will follow the procedur es as outlined in its operating documents. The operator may update or revise its operating documents, in which case it will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or an y law e nforcement official upon request. The operator will also present updated and revised documents if it petitions for extension or amendment to its grant of exemption. I f the operator determines that any update or revision would affect the basis upon which th e FAA granted its exemption, then the operator will petition for an amendment to its grant of exemption. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critic al component, shall undergo a functional test flight prior to conducting further operations under the exemption. Functional test flights will only be conducted by

a PI C with a VO and will remain at leastPage 4

500 feet from other people. The functional test flig ht will be conducted in such a manner so as to not pose an undue hazard to persons and propert y. 9. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PI C will conduct a pre

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

- flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a cond ition that affects the safe operation of the UAS, the aircraft will not participate in an operation until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under the exemption will comply with all manufacturer safet y bulletins.
13. A PI C will hold either an airli ne transport, commercial, private, recreational, or sport pilot certificate. The PI C 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, Puerto Rico, a territory , a possessio n, or the Federal government. The PI C will 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. 14. The operator will not permit any PIC to operate unless the PI C demo nstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours and currency will be logged in a manner consistent with 14 CFR 61.51(b). It is anticipated that flights for the purposes of training the operator’s PI Cs and VOs (training, proficiency, and experience

- building) and determining th e PIC’s ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption will be permitted under the terms of the exemption. However, training operations will only

be conducted during dedicated training session s. During training, proficiency , and experience

- building flights, all persons not essential for flight operations will be considered nonparticipants, and the PI C will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 9 1.119. 15. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be performed.Page 5

16. The UA will not operate 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 s ymbol as denoted on the current FAA

published aerona

utical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by an FAA Certificate of Waiver or Authorization (COA) issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or an y law enforcement official upon request. 17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.
18. If the UAS loses communications or loses its GPS signal, the UA will return to a pre

determined location within the private or controlled

- access property

. 19. The PI C will abort the flight in the event of unpredicted obstacles or emergencies.
20. The PI C will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by th e manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO

- issued COA or other FAA approved COA. Itis understood that the exemption holder may app ly for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of an y existing ATO

- issued COA or other FAA approved COA. 22. All aircraft operated in accordance with the exemption will be identified by serial numb er, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.
23. Documents used b y the operator to ensure the safe operation and flight of the UAS an d an y documents required under 14 CFR 91.9 and 91.203 will be available to the PI C at the Ground Control Station of the UAS an y time the aircraft is operating. These documents will be made available to the Administrator or an y l aw enforcement official upon request. 24. The UA will remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS will not be operated b y the PIC from any moving device or vehicle. 26. All flight operations will be conducted at least 500 fe et from all nonparticipating persons, vessels, vehicles, and structures unless:Page 6

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that no nparticipating persons remain under such protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safet y of nonparticipating persons; and b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does n ot present an undue hazard.
It is understood that the PI C, VO, operator trainees or essential persons would not be considered nonparticipating persons under the exemption. 27. All operations will be conducted over private or controlled

- access property wi th permission from the property owner/controller or authorized representative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that tr ansgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA will be reported to the FAA’ s UAS Integration Office (AFS −80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. The requested exemption seeks permission to conduct operations for the purpose of closed

- set motion picture and television filming and production. For those operations, the following additional conditions and limitations will apply

. 29. The operator will have a motion picture and television operations manual (MPTOM) as documented in the grant of exemption. 30. At least 3 day s before aerial filming, the operator of the UAS will submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. It is understood that the 3

- day notification may

be waived with the concurrence of the FSDO. The plan of activities will include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under the grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N −Number of UAS to be used; e. Name and certificate number of UAS PI Cs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission shall be made available to the inspector upon request;Page 7

g. Signature of exemption holder or representative; and h. A description of the flight activity , including maps or diagrams of an y area, cit y, t own, county , and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 4 7, 61, and 91. **Extent of relief sought from 14 CFR** For its commercial operations, and in accordance with the Conditions and Limitations described above, UAS Flight Services LLC requests relief from the following rules of Title 14 of the Code of Federal R egulations (CFR). **14 CFR Part 21 Subpart H Airworthiness certificates: Airworthiness Certificates and 14 CFR Section 91.203(a) (1)**  14 CFR Part 21, Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as require d by 14 CFR. 91.203(a)(1). Given the small size of the UAS to be utilized and the Conditions and L imitations described above, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safet y under Part 11 and as required b y Secti on 333 of the FMRA with consideration of the “size, weight, speed, operational capability , and proximity to airports and populated areas, and visual line of sight” **14 CFR 45.23(b) Display of marks; general** This rule requires, for certain provisionally certificated aircraft, certain lettering to be display ed near the entrance to the aircraft’s cabin or cockpit. Even though the UAS will not have an airworthiness certificate, an exemption may be needed to this rule since these unmanned aircraft have no entran ce to the cabin, cockpit, or pilot station. Although the UAS will not have an airworthiness certificate, it will be registered with the FAA, and given the size of the aircraft, the UAS will display its registration number on the aircraft in the largest pra cticable lettering. **14 CFR 61.113 (a)(b) Private pilot privileges: Pilot in command** This rule limits private pilot privileges and, b y implication, lower level pilot privileges, to non - commercial operations. Unlike a conventional manned aircraft, a UAS is remotely controlled by

a ground

- based operator. Because the UAS will not carry a pilot or passengers, the operational area is controlled and restricted, and all flights are planned and coordinated in advance, the risks associated with the use of the UAS ar e so diminished from the level of risk associated with commercial operations contemplated by Part 61 that allowing the UAS to be operated b y a person holding at least a sport pilotPage 8

certificate exceeds the present level of safety sought by 14 CFR 61.113(a) (b). Under this grant of exemption, UAS Flight Services LLC will require the Pilot in Command (PI C) to hold either an airline transport, commercial, private, recreational, or sport pilot certificate and a current 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. Furthermore, the PI C must also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the P IC is rated on his or her pilot certificate. **14 CFR 91.7(a) Civil aircraft airworthiness** This rule specifies that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the airc raft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Dail y pre - and post

- flight inspections will be accomplished in accordance with the manufacturer’s maintenance manual and guidance. During flight, the PI C will adhere to 14 CFR 91.7(b) and abort air operations immediately upon identification of an in

- flight emergency

or other unsafe condition. By complying with the procedures outlined by

the manufacturer’s maintenance manual as well as with 14 CFR 91. 7(b), a required level of safet y will be provided. **14 CFR 91.9(b) Civil aircraft flight manual, marking, and placard requirements** This rule prohibits operation of U.S.registered civil aircraft unless there is available in the aircraft a current, approve d Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or an y combination thereof. These UAS, given their size and configuration, do not have the ability or place to carry

such a flight manual in the aircraft, not only

be cause there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. A required level of safet y will be provided by keeping the flight manual within the immediate proximity of the UAS ground control station.
**14 CFR. 91.103: Preflight action**  This rule requires each pilot in command to take certain actions before flight to insure the safet y of flight. Because FAA an approved flight manual will not be provided for the aircraft, an exemption may be needed. The UAS o perator will take all actions including reviewing weather, flight battery requirements, launch paths and landing approaches, and aircraft pre

- flight check parameters and data before commencement of flight. **14 CFR 91.109(a) Flight Instruction** This rule pro vides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. UAS, by

their design, do not have fully functional dual controls. Flight co ntrol is accomplished through the use of the ground control station that communicates with the aircraft via radio signals. The design does not allow for dual controls during flight training and therefore the exemption to this rule is requested to train ope rators, build experience, and maintain proficiency . A required level of safet y is provided by thePage 9

fact that neither a pilot nor passengers will be carried in the aircraft and b y the size and speed of the aircraft. **14 CFR 91.119 (c) Minimum safe altitudes** This rule specifies that over other than congested areas, an aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the UAS will be operating at a maximum of 400 feet AGL for commercial operations, an exemption is needed for these operations. Given the size, weight, and lack of fuel, combined with the Conditions and L imitations listed above, the operation will be conducted with a greater level of safety

than exists with current manned aviation operations.
**14 CF R 91.121 Altimeter settings**  This rule 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 available before departure.” Because these UAS do not have a barometric altimeter, but rather a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be provided due to the GPS’s accuracy combined with the actions of the UAS operator in confirming the altitude of the launch/recovery site shown on the GPS altitude indicator before flight. **14 CFR 91.151(a) Fuel requirements for flight in VFR conditions** This rule prohibits a person from beginning “a flight in an airplane under VFR conditions unless (c onsidering 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 for at least 30 minutes; or (2) At night, to fl y after that fo r at least 45 minutes.” This rule is based on the capabilities of traditional aircraft, which typicall y have flight times of several hours; however, the battery

- powered UAS utilized for these commercial operations have flight times ty picall y of no more than 30 minutes. Operating the UAS in a rigidl y controlled area where onl y people and property owners or official representatives have given permission for these operations does not engender the type of risks that Section 91.151(a) was intended to alleviate, especiall y given the size and speed of the UAS. Additionally, limiting UAS flights to extreme minimum flight times would greatl y reduce the utility for which the exemption would be granted. A required level of safet y will be achieved by limiting flights to the manufacturer’s flight endurance specifications and b y imposing a minimum reserve of battery life to force a controlled landing safel y without exceeding the manufacturers’ maximum flight endurance specifications. This restriction would be more than ade quate to return the UAS to its planned launch/recovery

site from any

where within its limited operating area. **14 CFR 91.203 (a)(b) Civil aircraft: Certificates required** This rule provides in pertinent part: “(a) Except as provided in Section 91.715, no per son 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 b y paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that itPage 10

is legible to passengers or crew.” Because these UAS have no cabin or cockpit and, weighing no more than 55 lbs fully loaded, are of a size that i t is impractical for them to carry certification and registration documents, a required level of safety will be achieved by keeping any

such documents applicable to the UAS in the immediate proximity of the ground control station. **14 CFR 91.405(a), 91.407 (a)(1), 91.409(a)(2) and 91.417(a)(b) Maintenance**  **inspections** These rules require 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 p aragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...,” and that others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply onl y to aircraft with an a irworthiness certificate, these sections will not apply to the applicant. The operator will perform the maintenance in accordance with the UAS’s flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS are limite d in size, will carry

small payloads, and operate onl y in observed, controlled areas for limited periods of time. If mechanical issues arise, the UAS will be operating from a height of no more than 400 feet AGL and can land immediately. The operator will ensure that the UAS is in working order prior to initiating flight and perform required operator maintenance. Major maintenance events beyond basic operator maintenance shall be recorded in the UAS equipment record jacket. Moreover, the UAS 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 safet y. **Summary for Publication in the Federal Register** The following summary

is provided for publication in the Federal Register should it be determined that publication is required: Pursuant to Section 333 of the FAA Modernization and Reform Act (FMRA) and 14 CFR Part 11, UAS Flight Services LL C requests a grant of exemption from certain Federal Aviation Regulatio ns for the purpose of employing Unmanned Aircraft Systems (UAS) for commercial on

- demand operations. Applicant seeks exemption from the following rules: 14 CFR.21, subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a)(b); 91.7(a); 91.9(b); 91.103; 91.109(a); 91.119 (c); 91.121; 91.151(a); 91.203(a)(b); 91.405 (a); 91.407 (a)(1); 91.409(a)(2); 91.409(a)(2) and 91.417(a)(b).
**Public Interest and Benefit** The services provided b y UAS Flight Services LLC, many normall y provided in manned aircraft, may

be provided with in creased safet y and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or replace the use of manned aircraft as a result of safet y or economic considerations in certain applications where extended operational r ange and extended time aloft are not a factor. The proposed UAS operations will pose no threat to the public given its small size and lack ofPage 11

combustible fuel when compared to larger manned aircraft, minimize potential ecological affects or damage, and pro mote economic growth by providing services to individuals or organizations requiring aerial inspection and survey , data collection and monitoring, search and rescue, videograph y, cinematograph y or photograph y, and imaging data. Additionally , the growth o f the UAS industry is precipitating the growth of an increasing number of UAS enthusiasts who have little or scant formal knowledge or training regarding UAS operations and the potential danger of those operations within the national airspace. While it is unclear what pilot certification requirements will ultimately appl y to UAS operations for commercial purposes under the final rulemaking process, there is an increasingl y pressing need for training regarding the applicable federal aviation regulations for UAS operations and the flight characteristics of unmanned aircraft. Training in the operation and applications of UAS for compensation provides economic incentive to accomplish the public goal of integrating both recreational and commercial UAS into the national airspace while promoting safety and the public awareness of current regulations affecting UAS operations. **Privacy** All operations will be conducted in accordance with applicable laws regarding privacy

. Commercial film and TV filming events will be of people who have consented to being filmed or otherwise have agreed to be in the area where filming will take place.
**Conclusion** The operations by

UAS Flight Services LLC using unmanned aircraft s ys tems under the requested exemption can provide aerial s ervices with less risk of accident, injury , and loss of propert y than many of the same aerial operations performed b y m anned aircraft. Additionally , training in UAS operations for compensation promotes the safe and responsible integration of UAS within the national airspace. Satisfaction of the criteria provided in Section 333 of the FAA Modernization and Reform Act

— size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national s ecurity

— provide adequate justification for the grant of the requested exemption allowing commercial operations by UAS Flight Services LLC. Respectfully ,

Ira McComic Managing Member UAS Flight Services LLC