Prepared byJosh Gray- SpinWidgets December 21, 2015
Attention: US Department ofTransportation Docket Operations**W.~st** Building Ground Floor, Room W12-140 Uh 

### 3 I 11l 1200 NewJersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 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); 91.409 (a) (2); 91.417 (a) 

### & (b)
Dear UAS Integration at Federal Aviation Administration,
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14CFR Part 11, SpinWidgets, a research developer and operatorofSmall Unmanned Aircraft Systems ("UASs") equipped to conduct aerial photographyfor industrial, Real State, agriculture, motion picture, and Television industryfor scripted closed set filming, hereby applies for an exemption from the listed
Federal Aviation Regulations ("FARs") to allow commercial operation of its UASs (Fixed-wing 

### & Multi-Rotor), so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.
As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements tothe already safe operations in the industrial, film, and television production community presently using conventional and unmanned aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the FAA Administrator's responsibilities to "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333 (c) ofthe Reform Act. The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8 Issue a Certificate of

# -------------------

Waiverfor industrial, agriculture, Real State, motion picture, and Television industry.
The name and address ofthe applicant is: SpinWidgets Attn: Josh Gray Phone: 928-202-6618 Email: admin@spinwidgets.com Address: 610 N. Main St, Cottonwood, AZ 86326
Locations for Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14CFR 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); 91.409 

### (a) (2); 91.417 (a) 

### & (b) are:
1. SpinWidgets Cottonwood, AZ Regulations from which the exemption is requested:
14 CFR Part 21 14CFR 45.23 (b) 14CFR 61.113 (a) 

### & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14CFR 91.103 14CFR 91.109 14CFR 91.119 14 CFR 91.121 14CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14CFR 409 (a) (2) 14 CFR 417 (a) 

### &(b) Privacy
All flights will occur over private and controlled access propertywith the property owner's priorconsent and knowledge. Image capture of people willrarely take place, but in the eventthey are, theywill have consented priorto being filmed or otherwise have agreed to be in the area where data collection will take place.
Airborne (Day 

### & Night)
With regard to airborne SpinWidgets adheres to all FAA regulations. Further SpinWidgets airborneteams operate underthe principals of: Safety First, QualityAssurance, Accountability, Reporting, and Training. When approved by the FAA it is SpinWidgets' mandate to treat all UAS operationsthe exact same as that ofconventional aircraft. Approval ofexemptions allowing commercial operations of UASs in the industrial, agriculture, Real State, motion picture, and Television industry will enhance safety by reducing risk. Conventional operations, usingjetor piston powered aircraft, operate at extremely low altitudesjustfeet from the subject being in extreme proximityto people and structures; and presentthe risks associated with vehicles that weigh in the neighborhood of 4,000ibs., carrying large amounts ofJet A or otherfuel {193 gallons forjet helicoptershown below). Such aircraft mustflyto and from location. In contrast, a UAS weighing fewerthan SSibs and powered by batteries eliminates virtually all ofthe risk given the substantial reduced mass and lack ofcombustible fuel carried on board.
The UAS is typicallytransported tothe location via auto orcargo van in a medium sized case and is neverflown to set. The UAS will carry no passengers or crew and, therefore, will not expose them tothe risks associated with manned aircraftflights.
The operation ofsmall UASs, weighting less than SSibs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supportingthe grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, and in a sterile environmentand, as a result, are far safer than ground than conventional operations conducted with turbine helicopters operating in close proximitytothe ground and people.The primary uses ofinterestfor SpinWidgets utilizing UASs are as follows: 

### Visual inspections,Photo and Video of:
1. Gas and Oil Wells

2. Agriculture Land Mapping

3. ReaI Estate

4. Telecommunications Towers

5. Power lines

6. Structurallntegrity

7. Motion Picture

8. Television Industry

It is estimated thatthe use of UAS aircraft will reduce hazardous tower climbs Poles Wells etc, Aside from reducing the numberofphysical climbs, the utilization of UAS will dramatically lowerthe use ofcranes and lifts, which also pose dangerous conditions for build and repair personnel. In a numberofinstances, inspectorsjust need to get "eyes on" the towertop assemblies to lookfor specific deficiencies. With regard to power lines when climbers are sent in the power must be deferred. The use of UAS may allow these industriestofill in the data gaps where traditional aircraft are currently restricted.
It is anticipated thatthe airborne image capture process will be**·-------~·~~~~~~~~~~~~~~~-~~--------------**

accomplished in both day and night environments. Currently, conventional aircraft are flown in highly populated and/or urban areas, with turbine powered helicopters. The grant ofthis exemption request will provide improved safety in both day and night operations. To capture the highest quality of resolution the majorityofairborne data collections will take place duringthe 10:00am-4:00pm window.
There may be night operations conducted where infrared sensors will be deployed. Ifsuch operations are required the ground facilities and the subjecttower/Pole/Wells assemblies may require additional lighting so that visibility is as though itwas conducted during daylight hours.
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333 (a) through (c) ofthe Reform Act. This directs the FAA to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In makingthis determination, the FAA is required to determinewhich types of UASs do notcreate a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthe following:

.The UAS's size, weight, speed, and operational capability:

. Operation ofthe UAS in close proximityto airports and populated areas; and

. Operation ofthe UAS within Visual Line ofSight (VLOS) ofthe Operator (PIC) and Observers.
Reform Act §333 (a). Lastly, ifthe FAA determinesthatsuch vehicles "may operate safely in the national airspace system, the FAA shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333 (c) (emphasis added).
The Federal Aviation Act expressly grantsthe FAA the authorityto issue exemptions. This statutoryauthority by its terms includes exempting civil aircraft, as theterm is defined under §40101 ofthe Act, the mat includes UASs, from the requirementthat all civil aircraft must have acurrent airworthiness certificate. The Administratormay grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 of this title ifthe Administratorfinds the exemption in the public interest.
49 U.S.C. §44704; 14 CFR §91.203 (a) (1). Applicant interpretsthis provision to place ofthe dutyon the Administrator to notonly process applications for exemptions under section 333, butfor theAdministratorto craft conditions herein forthe safe operation ofthe UAS, ifitshould be determined thatthe conditions set forth herein do not fulfill the statutory requirements for approval. SpinWidgets' UASs are multi-rotorcraft and fixed-wing aircraft, weighing 55 orfewer lbs. including sensor payload. They operatetheir multi-rotorcraft, under normal conditions at a speed of no more than 50 knots and have the capabilityto hover, and move in thevertical and horizontal plane simultaneously. They operate theirfixed-wing aircraft, under normal conditions at a speed of no more than 50 knots and primarily have the flight characteristics oftraditional airplanes. They will manually operate only in VLOS and will operate onlywithin the sterile area described in the Confidential: Flight Operations Manual (FOM) attached as Exhibit 1 (hereinafter "the Manual").3 Adherence tothe Manual will insure thatthe UAS will"not create a hazard tothe national airspace system orthe public. Given the small size and weight ofthe UAS involved and the restricted sterile environmentwithin which theywill operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due tothe size ofthe UASs and the restricted areas in which the relevant UAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety, surrounding the proposed operations, and significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for inspection and survey operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA granttherequested exemption without delay.
The Flight Operation Manual is presented as an applicant confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary methods and information thatthe applicant has notand will notshare with others. The manual reflects learned experiences, methods, operating conditions, and procedures that are not available tothe public and are protected from release underthe Freedom of Information Act 5 USC 552 et.seq. Reform Act Section 333 (b) AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementtothe already safe Videography and Photography operations conducted with conventional aircraft. These limitations and condition to which SpinWidgets agrees to be bound when conducting commercial operations under an FAA issued exemption include:


### 1. The UAS will weigh less than 55 lbs Constructed by high reputation companies, single, Multicopter base on application.

2. Flights will be operated manually within visual line ofsight (VLOS) of the Operator (PIC) and Observers

3. Maximum total flight time for each operational flight will depend on battery charge, the average flight will be 30 +/-minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 30 +/-minute limit.

4. Flights will be operated at an altitude of no morethan 400 feet AGL or,not more than 200 feet above an elevated platform from which airborne data collection is planned.

5. Minimum two (2) man crew for each UAS operation will consist ofthe Operator (PIC) and Observers. In most cases the third aircrew member will serve as the Camera 

## I Sensor Operator.

6. The UAS Pilotwill be an FAA licensed airman with at least a private pilot's certificate and Class 2 (or higher) airmen medical certificate. The Camera 

## I Sensor Operator and Spotter (Observer) will hold at least a Class 2 (or higher) airmen medical certificate and TSA Security Screening.

7. The UAS Pilot will serve as Pilot in Command {PIC). The PIC will possess at least a private pilot certificate and at least a current Class 2 (or higher) airmen medical certificate to meetthe flight review requirement specified in 14 CFR § 61.56.

8. The UAS pilot (PIC) will have a COA priorto conducting any operations, the COA will be submitted in conjunction with this petition of exemption 333.

9. Priorto any operations conducted by SpinWidgets, the PIC will have accumulated and logged a minimum of200 flight cycles and 25 hours oftotal flight time with an UAS, and 10 hours in the UAS flight simulator, accordance with CFR § 61.51 (b).

10. Priorto operations the PIC will have a minimum offive hours as a UAS pilot operating and threetake-offs and landing in the preceding 90 days.11. The UAS will only operate within a confined "Sterile Area,. 610 N. Main St, Cottonwood, AZ 86326 928-202-6618 www.spinwidgets.com

12. SpinWidgets will develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alteration records, and status of replacement/overhaul component parts.

13. A pre-flight briefing will be conducted in regard tothe planned UAS operation priorto each day's production activities. Itwill be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be present forthis briefing.

14. The Operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office (FSDO).

15. The Operatorwill obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, With the advanced permission ofthe relevant FSDO, operations at closer range can be approved.

16. The Operatorwill submit awritten Plan ofActivities tothe FSDO three (3) days before the proposed shoot as required by the Manual.

17. Operator (PIC) and Observers will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required by the Manual.-···---------------------------------------

18. Spotter (Observer) and Pilot will at all times be able to communicate by voice, radio, and/ortext.

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

20. All required permission sand permitswill be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orotherappropriate governmental agencies.

21. Ifthe UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter and land.

22. The UAS will have the capabilityto abort aflight in case of unpredicted obstacles emergencies.

23. The UAS Will not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC.

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) {1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act {49 U.S.C. §44701 (f)) and Section 333 ofthe Reform Act both authorizethe FAA to exempt aircraftfrom the requirement capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysisofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed-wing or multi-rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed.
The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neithera Pilot nor Observers, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the Operator, pursuant to safety requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area ofoperation as is now done with conventional tools. The FAA will have advance notice ofall operations. These safety enhancements, which already applyto civil aircraft operated in connection with Videography and Photography production, provide agreater degree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials orflammable liquid fuels, and inabilityto carry a substantial external load.
14 CFR §45.23 (B): Marking oftheAircraftThe regulation requires:
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 tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted", 111ight-sport," "experimental," or 11provisional," as applicable.
Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which theword "Experimental" can be placed. Given the size ofthe sUAV, two-inch letteringwill be impossible. The word "Experimental"will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level ofsafety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the Operator (PIC) and Observers and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptionsto this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
14 CFR §61.113 (a) 

### & (b): Private Pilot Privileges and Limitations -Pilot in Command (PIC) Sections 61.113 (a) 

### &(b) limit private pilotsto non-commercial operations. Because the UAS will not carry a Pilot or Observers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operatingthe aircraftto have a private pilot's license rather than a commercial pilot's license to operatethis small UAS. Unlike aconventional aircraftthat carries the Operator (PIC) and Observers, the UAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level ofsafety provided by the requirements included in the Manual exceeds that provided by single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe UAS as requested with a private pilot as the PIC exceeds the present level ofsafety achieved by 14 CFR §61.113 (a) 

### & (b).
14 CFR §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 forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determiningairworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists and a preflight inspection, all maintenance and alterations will be properly documented in the aircraft records priorto each flight, an equivalent level ofsafety will be provided.14 CFR §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 Multi-rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft acurrent approved Airplane or Multi-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 aflight manual on the aircraft, notonly because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft.
The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. The FAA has issued the following exemptionstothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A 10602, 32827, and 10700
14 CFR §91.103: PreflightAction
This regulation requires each pilot in command totake certain actions before flight to insure the safety offlight. As FAA approved multi-rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafetywill be provided in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.
14 CFR §91.109: Flight Instruction Section 91.103 provides that no person may operate acivil aircraft (except a manned free balloon} that is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs and remotely piloted aircraft, by their design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions forflight training withoutfully functional dual controls for anumberofaircraft and forflight instruction in experimental aircraft. See Exemptions Nos. 5778K 

### & 9862A. The equivalent level ofsafety provided by the fact that aircraft.
14 CFR §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a UAS that is afixed-wing or multi-rotorcraft requests authorityto operate at altitudes up to 400ft. AGL, or not more than 200ft. above an elevated platform from which filming inspections is planned, an exemption may be needed to allow such operations. As set forth herein, except forthe limited conditions stated in the Manual, the UAS will never operate at higherthan 400ft. AGL. Itwill however be operated in restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as location where it is operated. No flight will be taken withoutthe permission ofthe propertyowner or local officials. Because of the advance notice tothe property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations as set forth in the Manual. Compared toflight operations with aircraft or multi-rotorcraftweighing far more than the maximum 55 lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500ft. AGL in this industry. In addition, the low-altitude operations ofthe UAS will ensure separation between these small UAS operations and the operations ofconventional aircraftthat must complywith Section 91.119.
14 CFR §91.121: AltimeterSettings
This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set 11

...

### to the elevation ofthe departure airport or an appropriate altimetersetting available beforedeparture." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved by the operator, pursuant tothe Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.
14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

/ Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flytothe first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes."
The battery poweringthe UAS provides approximately40 minutes of powered flight. To meetthe 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 ofits proposed operations within a predetermined area, a longer time frame forflight in daylight or nightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in atightly controlled area where only people and propertyowners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utilityforwhich the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or25% ofbattery power whichever happens first. This restriction would be more than adequate return the UAS to its planned landing zone from anywhere in its limited operating area. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification andRegistration The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate acivil aircraft unless it has within itthe following: (1} An appropriate and current airworthiness certificate

... (b) No person may operpte a civil aircraft unless the airworthiness certificate required by paragraph (b) ofthis section or aspecial flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew.

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 orto displaythem on the UAS.
An equivalent level ofsafetywill be achieved by keeping these documents at the ground control point where the Pilot flying the UAS will have immediate access tothem, tothe extentthey are applicable tothe UAS.
14 CFR §91.405 (a); 407 (a) (2); 417 (a) 

### & (b): Maintenance Inspections
These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph © ofthis section, have discrepancies repaired as prescribed in Part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applytothe applicant. Maintenance will be accomplished by the operator pursuanttothe flight manual and operating handbook as referenced in the Manufactures Manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediatelyand will be operatingfrom no higherthan 400ft. AGL. As provided in the Manual, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is theperson mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthycondition to provide the equivalent level ofsafety.
Pursuantto 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an 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) (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) and 91.417 {a) 

### & {b) to operate commercially asmall unmanned vehicle {551bs or less) in industrial area and industrial operations. Summary Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 -size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS in the industrial, Videography and Photography production industry pursuant tothe Manual appended hereto. SpinWidgets is eagerly standing by to supportthe FAA and UAS community in its questto establish proper regulations and protocols forthe safe introduction of unmanned aircraft intothe national airspace. Sincerely, 

### Josh Gray
Founder and Owner SpinWidgets 928.202.6618