DroneFleet Company

123 Swopes Valley rd
Pine Grove PA 17963

FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12-140 Washington, DC 20590



### Re: Petition of DroneFleet Exemption Request Pursuant To Section 333 of the FAA
Reform Act of 2012

Dear Exemption Manager, 

### I. Description of Petitioner We are submitting our Petition for Exemption for Unmanned Aircraft Systems operations. DroneFleet Company, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre-planned, controlled area, photographic and surveying services, 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 Federal Aviation Administration (FAA) as required by§333. DroneFleet Company current operation of sUASs for commercial purposes has been halted to comply with recently enacted federal aviation regulations pertaining to sUASs. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive multi-rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on-site safety personnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations. DroneFleet has an experienced 11AS team encompassing a wide range of disciplines

and skill sets to offer safe and effective services to its customers.

The name and address of the applicant is: DroneFleet Company Address: 123 Swopes Valley rd Pine grove PA 17963

Attn: Michael Zimmerman Ph:+1- (717)-553-9510 Email: sales@air4marketing.comU.S. Department of Transportation

June 10.2015 Page 2 

### II. Types of Operations

A. Request to Use UASs for R&D and Training at Test Sites Owned or Controlled by DroneFleet DroneFleet seeks the following exemptions to conduct training and research and development at its own facilities and property. The test areas will not be open to the public and access will be restricted to DroneFleet employees or consultants engaged in flight tests, training, maintenance, or test-related work. The primary focus of DroneFleet R&D efforts is to evaluate how to best incorporate the UAS into Dronefleet Business procedures.



### B. Request to Use UASs for Business Marketing DroneFleet request for exemption focuses on its use of UAS for Marketing for 

### conduct aerial photography for the media, real estate, advertising industries, and any legal purpose using UAS in new application in this industry.

C. Request to Use UASs for Surveying Services DroneFleet also seeks exemption to perform surveying service for its commercial and residential property. In particular, inspections and evaluations of the roofs of large commercial structures, or where the roof has an especially steep pitch, provides unique challenges. Currently, most such roofs have to be inspected by physically sending a person onto the structure using ladders. These inspections are time consuming and carry a number of different risks, all of which can be mitigated or eliminated through the use of UAS. Also structures can be compromised, or access to portions of the property may be blocked due to flooding or debris. Sending a person in to inspect the upper portions of a damaged structure may not be practical or safe. These are the types of situations where UAS can provide a safe and effective alternative that not only permits an inspection, but can fully document the results 

### III. Relevant Statutory Authority This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following considerations:

• The UAS's size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.1 Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 

### See 

### 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from** 44701(a), (b) and§§ 44702- 44 716, 

### et seq.). A party requesting an exemption must explain the reasons why the exemption: 

### (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). 

### See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. DroneFleet's Proposed UAS Operations Meet the Requirements of Section 333 of

the Reform Act DroneFleet's proposed operations in this Petition for Exemption qualify for expeditedU.S. Department of 

### Transportation

June 10.2015 Page 3 approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant

factors are satisfied. 

### A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability DroneFleet will employ the Following DJI Phantom 2-3, DJI inspire.3DR Solo and SteadiDrone VADER quadcopter DJI S1000+ octocopter and any new airframe updates for the operations specified in this Petition for Exemption. This UAS has a maximum take

-off weight of less than 55 pounds. The flight speed will not exceed 55 miles per hour, and it will not be flown in controlled airspace or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely terminated with a reserve battery power of 25% of the battery's maximum charge.

I Id. at 333(b)(I). The UAS does not carry any flammable propellant or fuel. The UAS also has an integrated GPS system that calculates the UAS's position and height and relays that information via a secure connection to the operator. Additionally, the UAS contains a failsafe mode if its connection to the remote control is lost, and this system permits the UAS to return to a predetermined location and land without injury or damage. B Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual The DroneFleet Operations Manual and the UAS maintenance and flight manuals contain all of the procedures and limitations necessary to successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of DroneFleet's operations. below is a summary of operational limitations and conditions which will ensure an equivalent or higher level of safety for operations conducted under current regulatory guidelines:
1.The UAS weighs 55 pounds or less.

2. Flights will be operated within the visual line of sight of a pilot and an observer.
3. Maximum total flight time for each operational flight will be limited to the amount of time the UAS can be flown and still maintain a reserve battery power of no less than
25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not be conducted within navigable airspace.
5. Flights will be operated at a lateral distance of at least 150 feet from any persons, inhabited structures, vehicles or vessels that are not involved in the inspection unless permission has been received from the persons or property owners in advance.

6. Flights will be limited to a speed of 35 m.p.h. and vertical ascent will be limited to 15 m.p.h.

7. Minimum crew for each operation will consist of the UAS Pilot, one or more Visual Observers as necessary to safely conduct the mission, and a Sensor Operator, if the sensor requires human direction or control.
8. The observer designated for any operation will be in constant voice contact with the pilot.

9. The UAS will operate in accordance with the requirements of its flight and
maintenance manuals.

10. Prior to the operation, a Mission Plan will be 

### created setting forth the limitations for the flight as well as contact and hazard information.
11.A NOTAM will be issued not more than 72 hours in advance of flight, but not less

### U.S. Department of Transportation

June 10,2015 Page 4 than 48 hours before flight.
12.A Certificate of Authorization will be obtained prior to flight.
13.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.

14.The operator will coordinate all flights with the appropriate Flight Standards District
Office.
15. If the UAS loses communication with the pilot, it will have the capability to return to a pre-determined location within the operational area and land.
16.Contingency plans will be in place to safely terminate flight if there is a loss of communication between the pilot and the observer.
17.The UAS will have the capability to abort flight in the case of unpredicted obstacles or emergencies.
18.Both the Pilot and Observer will have a current Class III Medical Certificate or Drivers
License REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal Aviation Act expressly grants the 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, including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 2 

### DroneFleet seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the

2 

### See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought.3 A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA2014-0352 at 13-14,22. If, however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested. Equivalent Level of Safety The UASs selected by DroneFleet is safe when taking into account their size, weight, speed, and operational capability. As set forth in Section II, Supra, the UAS weighs less than 55 pounds and will be flown at less than 100 miles per hour and completely outside controlled airspace. Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively within the parameters stated in the Operations Manual. Operations under this exemption will be closely controlled and monitored by the operator and will be conducted in compliance with local public safety requirements, to provide security for the area of operation. DroneFleet will also provide the FAA with advance notice of allU.S. Department of Transportation

June 10,2015 Page 5 operations via NOTAMS and coordination with the local FSDO. In all cases, the UAS operated under the proposed conditions, will be at least as safe as, or safer than conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations. The UAS does not need a means to communicate with other aircraft or A TC, because those capabilities will be possessed by the pilot and observer, who are not onboard. 

### See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, no sense and avoid technology is necessary on the UAS because it will be operated at all times by visual line-of-sight. 

### Id.

3 

### See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek exemption.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category
Rotorcraft 14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the Petitioner's UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F .R. Part 21, Subpart H,



### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements DroneFleet seeks an exemption from the aircraft marking and identification requirements contained in 14 C.P.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.P.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter.

• 14 C.P.R. § 45.23(b), Markings of the Aircraft, states: 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, "experimental," or "provisional," as applicable.

• 14 C.P.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage. boom, or tail the marks required by § 45.23. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R part 45, Subpart C if the markings are as large as practicable."
FAA Docket No. FAA-2014-0352. Equivalent Level of Safety DroneFleet will mark all aircraft with their N-Number in a prominent spot on the fuselage with markings that are as large as practicable. D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

### U.S. Department of Transportation

June 10,2015 Page 6 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

### Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may operate a U.S.-registered civil aircraft- (2) For which an Airplane or Rotorcraft Flight Manual is required by 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided 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 paragraph (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. DroneFleet does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PIC during flight. The Chief Counsel's Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations.

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

### DroneFleet seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner requests that the requirements for Section 91.7 be treated in accordance with Section V(A), supra. F. 14 C.F.R. § 91.103: Preflight Action 

### DroneFleet seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA -approved Flight manual is required. Equivalent Level of Safety 

### An equivalent level of safety will be provided by following the Aircraft Operations Manual and flight manual provided by the manufacturer. The PIC will take all required preflight actions- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas- before initiation of flight. The Operations Manual and manufacturer's flight manual will be kept at the ground station with the operator at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction 

### DroneFleet seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o person may operate a civil 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 functional dual controls. Instead, flight control isU.S. Department of Transportation

June 10,2015 Page 7 accomplished through the use of a device that communicates with the aircraft via radio
communications. Equivalent Level of Safety Given the size and speed of the UAS employed by DroneFleet, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight instruction. In addition, Petitioner will conduct flight training at its Research and Development test sites, which are located on its own property. These training flights will be conducted in a sterile area and will otherwise comply with the provisions in the Operations Manual for flights at the R&D facility. Accordingly, DroneFleet's proposed method of operation provides superior levels of safety.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes DroneFleet requests an exemption from the minimum safe altitude requirements of 14 C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. 

### See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." Equivalent Level of Safety Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An 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. In order to avoid any risk to aircraft, flight operations will be restricted to 400' AGL or below. As set forth in the Manuals, the UASs will be operated in a restricted area, away from persons or structures not involved in the operation.

I. 14 C.F.R. § 91.121: Altimeter Settings This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read

out. Equivalent Level of Safety The FAA has stated that an equivalent level of safety can be achieved if the UASs will be operated at 400' AGL or below and within visual line-of-sight in addition to GPS based altitude information relayed in real time to the operator. 

### See Grant of Exemption to Astraeus Aerial, Docket No. F AA-20I4-0352. As the attached Operations Manual indicates, the chosen UASs meets these requirements, and a zero altitude initiation point will be obtained prior to flight.

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR
Conditions DroneFleet requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VPR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly toU.S. Department of Transportation

June 10,2015 Page 8 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 fly after that for at least 45 minutes. Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. DroneFleet proposes that all flights comply with this requirement by mandating that the aircraft be safely landed with no less than 25% of battery life remaining. Equivalent Level of Safety

The P AA has stated that an equivalent level of safety is provided if the UAS flight is terminated with at least 25% reserve battery power still available. See Grant of Exemption to Astraeus Aerial, Docket No. PAA-2014-0352. The Operations Manual conforms to this limit, providing an equivalent level of safety.

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections DroneFleet seeks an exemption from the maintenance inspection requirements contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See,

e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter"). 

### An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS will not have. Equivalent Level of Safety 

### An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Operations Manual. As provided in the Operations Manual, flights will not be conducted unless a flight operations checklist is performed that includes all of the aircraft's components. The Operations Manual also sets requirements for maintenance log books and record keeping as well as routine and post-flight maintenance. The Manual sets requirements for appropriate
maintenance intervals.

L. 14 CFR Part 61, 14 CFR 61.3, 14 CFR § 61.113: Private Pilot Privileges And
Limitations Petitioner seeks exemption from 14 CFR Part 61, including 14 CFR § 61.3 to the extent that these regulations require a UAS operator to have a private pilot's certificate. The purpose of Part 61 is to ensure the skill and competency of any PIC matches the airspace in which the PIC will be operating. Petitioner has concerns that the training and education of persons obtaining a private or commercial pilots license is not an adequate match for UAS operation in low altitude environments, particularly given the vast differences in the control and flight profiles between conventional aircraft and UAS. Accordingly, Petitioner believes that a requirement for a private pilot's license is unnecessary. In addition, DroneFleet seeks exemption from 14 C.F .R § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and which would also require a second class medical certificate. The purpose of this section is to ensure the skill and competency of any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part of a commercial operation, it carries neitherU.S. Department of Transportation

June 10,2015 Page 9 passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring a the PIC to have a commercial pilot certificate and class II medical certificate or Drivers License. Equivalent Level of Safety Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. Accordingly, as set forth in the Operations Manual, Erie Insurance will require all PIC to have completed FAA authorized ground school instruction and also to have 250 hours of logged flight time in a UAS of the same class as will be used for Flight Operations (i.e. quadcopter, fixed wing, etc.). In addition, DroneFleet will require all PIC to have logged at least 50 hours of flight time in the specific UAS used for the Flight Operation. Finally, in order to meet the stated national security goal outlined by Congress in the 2012 FAA Reform Act. DroneFleet will require all PIC to pass a criminal background check at the time of hiring. In addition to the training and experience requirements, DroneFleet has placed restrictions on its Flight Operations to ensure an extra margin of safety. The UAS will operate in a sterile area away from persons and property not involved in the operation. It will be flown
based on VLOS at 400' AGL or below. A NOTAM will be issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO. In the event that the FAA determines that a waiver of 14 CFR § 61.3 is inappropriate, DroneFleet requests that the Exception from 14 CFR § 61.113 still be granted. The training and currency standards set forth by DroneFleet 

### in the attached Operations Manual are more than adequate to provide the extra margin of safety to allow a private pilot to act as a pilot for compensation or hire

VI. Drug and Alcohol Program DroneFleet has policies in place to ensure that no person may act as a PIC, observer, or sensor operator if they are under the influence of alcohol or any drug.

VII. Public Interest The public interest will be served by granting DroneFleet Petition for Exemption. Congress has established a national policy that favors early integration of UAS into the NAS in controlled, safe working environments such as those proposed in this Petition. In addition, the public also has an interest in reducing the hazards associated with alternate methods of conducting similar inspection operations. Currently inspections are conducted using inspection teams physically climbing onto structures using ladders. By using a UAS, an inspector will be able to reduce his or her exposure to physical hazards by conducting the inspection while remaining safely on the ground. Additionally. 

### DroneFleet client base are typically small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection other Public Interest aerial video graph for geographical awareness, Business Marketing, and real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost-prohibitive. Granting this exemption to the petitioner would allow us to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small size and lack ofU.S. Department of Transportation

June 

### 10,2015 Page 10 combustible fuel when compared to larger manned aircraft. The petitioner also states that the U.S. operation of his UAS will minimize ecological damage and promote economic growth by providing information to companies. by photographic, video graphic or lidar based surveying. These programs prevent accidents and injuries, and there is a strong public interest in making these programs more effective through the use ofUASs.



### VIII. Privacy All flights will be conducted in accordance with any federal, state or local laws regarding privacy. In addition, DroneFleet will adopt a series of standards to protect the privacy rights of persons impacted by the UAS operations.



### IX. Federal Register Summary Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: DroneFleet seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 4523(b); 14 CFR Part 61, 14 CFR 61.3, 14 CFR § 113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 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). The exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent work with conventional aircraft, rotorcraft, or other methods.



### X. CONCLUSION DroneFleet Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight and national security. Additionally, the Petition provides more than adequate justification for the grant of the requested exemptions to permit DroneFleet to operate the selected UAS for the operations specified
herein. Granting the exemption will benefit the public interest as a whole in several ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger, and (2) improving the quality of services and decreasing operating costs compared with

normal aircraft

Sincerely,

M

-mei Zimmerman

DroneFleet