Page 1 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com February 9, 2016

U. S. Department of Transportation Docket Management System West Building Ground Floor

– Room W12

- 140 1200 New Jersey Ave nue SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 13 C.F.R. 61.133(a); 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);91.417 (a) & (b).

Dear Sir(s)/Madam(s):

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ( “ Reform
Act ” ) and 14 C.F.R. Part 11, Greenlando Consulting, L.L.C. (“ Gree nlando ”), seeks an exemption from the Federal Aviation Regulations (“ FARs ”) to operat e Small Unmanned Aircraft System (s) (“ UA ”) as outlined and discussed below.

Greenlando is committed to meticulously working through the exemption process in order to provide the FAA with an application which is not only thorough and comprehensive but demonstrates Greenlando’s professional approach to a very unique industry and Greenlando

ap preciates the opportunity to submit an exemption application for consideration.

Greenlando’s UAs perform precision aerial surveying, inspections, videography, and photography in order to provide services for the following, which shall include but not be limited to, real estate, agriculture, mining, cellular towers, oil and gas flare stacks, power lines, transmission towers, bridges, dams, general infrastructure inspection, other structures, and other forms of aerial data and imagery collection (“ purposes ” )

. The use of Greenlando’s UAs for the

purposes reduces the need to operate conventional aircraft typically needed to perform these types of operations and provides an economic benefit to the business consumer as the Greenlando UA provides higher quality imagery at a fraction of the cost of surveys using conventional aircraft. These savings result in not only enhanced efficiency and productivity for the affected activities
but added environmental and safety benefits to the public at large.Page 2 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com Greenlando ’s e xemption request will permit the operation of comparatively inexpensive
UAs in a controlled and limited airspace. Greenlando has created (and attached) confidential and detailed safety protocols and controls (“ Greenlando ’s Confidential Protocols and Controls
Exhibit ”) 1 to avoid and prevent public hazards as well as preventing interference with manned aircraft which could cause a hazard or catastrophe. This acts to enhance safety protocols unique to
Greenlando ’s lightweight UAs

. Greenlando records flight information gained through permitted flight operations which may be shared with the FAA through any required FAA reports to assist with the development of future FAA protocols and safety regulations.

For the purposes outline d above, and a s more fully described below

, Greenlando ’s requested exemption would authorize commercial operations

, using Greenlando ’s UAs

, which will be operated under controlled conditions at an altitude of no greater than four hundred (400) feet above g round level (“ AGL ”) in airspace that is limited in scope and will have sophisticated control
features

. As outlined below, the airspace in which Greenlando’s UAs will operate within will be
disclosed to the FAA in advance to flight operation

. Finally, Gre enlando’s UAs will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary
conventional aircraft which should reassure the FAA that these operations will achieve at least an equivalent level or greater level of safety. The types of aircraft Greenlando anticipates utilizing in order to provide the purposes includes: DJI Phantom 2 , DJI Phantom 3 Pro, DJI S

- 1000 + and DJI Inspire 1 Pro.

I n the interest of economic efficiency and public safety , Greenlando hereby respe ctfully applies for an exemption from the listed F ARs to allow commercial operations of Greenlando’s UAs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA. Approval of this exempti on would thereby enhance safety and fulfill the Secretary of Transportation’s ( “ Administrator ” ) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace syst em.”

As discussed above and more fully described below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive UAs under controlled conditions in airspace that is limited and predetermined

. Approval of this exemp tion would thereby enhance safety and fulfill the Administrator responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Please see Section 333(c) of
the Reform Act.

1 See Exhibit “1”

- Greenlando ’s Confidential Appendices

.Page 3 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com Additionally, the FAA has already granted previous exemptions which are essentially identical to the exemption being sought by Greenlando.

The name and address of the applicant is:

Greenlando Consulting, L.L.C.
Attn: Christopher D. Lee Managing Member
2140 Nairn Drive Winter Park, FL 32792
Phone: 407

- 341

- 0585 Email: chris@greenlandoconsulting.com

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 C

. F

. R

. Part 21 14 C.F.R. 45.23(b)
14 C

. F

. R

. 61.113(a) & (b) 13 C.F.R. 61.133(a) 14 C.F.R. 91.7(a)
14 C

. F

. R

. 91.9(b)(2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F. R. 91.119
14 C.F.R. 91.121
14 C

. F

. R

. 91.151(a)
14 C

. F

. R

. 91.203(a) & (b)
14 C

. F

. R

. 91.405(a)
14 C

. F

. R

. 91. 407(a)(1)
14 C

. F

. R

. 91. 409(a)(2)
14 C

. F

. R

. 91. 417(a) & (b)

This exemption application is ex pressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system ( NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAs do notPage 4 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com create a hazard to users of the NAS or the public or pose a threat to nati onal security in light of the following:

• The UA’s size, weight, speed, and operational capability;

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

• Operation of the UA s within visual line of sight (“ VLOS ”) of the operator.

Reform Act § 333 (a).

Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §3 33(c) (emphasis added). 2

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, that includes UA s, from the requirement that all civil aircraft must have a
current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this t itle if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f)

. See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Greenlando ’s UA s are rotorcraft weighing less than fifty

- five ( 5 5) pounds (25 Kg) including ener gy source(s), equipment and any payload. They operate, under normal conditions

at a ground speed of no more than eighty

- seven ( 87 ) knots (100 miles per hour) and have the capability to hover, and move in the vertical and ho rizontal plane simultaneously. T hey will operate only in line of sight and will operate as described in the Greenlando’s Flight Operations
Procedure Manua l (“ FOPM ”) which is included in the Exhibit “1” and is incorporated herein by
reference. Such operations will insure that the UA will “not create a hazard to users of the national airspace system or the public.” 3

2 Greenlando interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UA, if it
should be determined that the conditi ons set forth herein do not fulfill the statutory requirements for approval.

3 Reform Act Section 333 (b).Page 5 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com Given the small size of the UA s involved, Greenlando falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA m ust, by exemption, allow commercial operations of UA s to commence immediately. Also due to the size
of the UAs and the restricted areas in which the relevant UA s will operate, approval of the application presents no national security issue. Given the clea r direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reducti on in environmental impacts, including reduced emissions associated with allowing UA s for aerial photography operations, the grant of the requested exemptions is in the public interest. Additionally, there is economic efficiency created with the use of Gr eenlando’s UAs as the typical cost to perform aerial photography with helicopters and airplanes heavily multiplies the cost to business consumers and government agencies, including law enforcement, for the services which are to be provided by Greenlando.

THE EXTENT AND BASIS OF THE RELIEF SOUGHT BY GREENLANDO

Greenlando submit s this application in accordance with the Reform Act, 112 P.L. 95 §§
331

- 334, seeking relief from any currently applicable FARs operating that presently prevents
Greenlando from con templated commercial video

- graphic, photographic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in t he public’s interest to do so. Greenlando’s ultralight weight UA s meet the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of Greenlando’s ultralight weight UA s is expressly contemplated by the Reform Act. Greenlando would like to
operate its ultralight weight UA s prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UA aerial
video graphy and photography. The Reform Act guides the Administrator in determining the types
of UA s that may operate safely in our national airspace system. These c onsiderations include : weight, size, speed and overall capabilities of the UA s ; w hether the UA s will be operated near airports or heavily populated areas and ; w hether the UA s will be operated by line of sight. 4 Each
of these items is favorable to the grant of an exemption to Greenlando. Gree nlando’s U A s utilize four (4) counter

- rotating propellers for balance, control and stability. Greenlando’s UA s are equipped with GPS and auto return safety technology. Greenlando’s UAs weigh less than fifty

five ( 5 5) pounds (25 Kg) including camera and gim bal assembly

.

4 112 P.L. 95 § 333 (a)

.Page 6 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com Greenlando puts safety first when considering any UA flight. Greenlando’s small UAs are designed to hover in place via GPS and operate in less than a 24 knot (27 mph) wind. In order to
increase safety plus stability and limit harm and financi al loss of property, Greenlando will not fly
its UAs in winds exceeding 15 knots (17 mph)

. Greenlando’s established safety systems include a
GPS mode that allows its UAs to hover in place when radio controls are released. Greenlando ’s
UAs utilize DJI controls which are safe, reliable and stable in order to prevent accidents and being
a hazard to others. When pilot communication is lost , Greenlando’s UAs are designed to return
then slowly descend to the point of takeoff. Greenlando does not operate its UAs near airports,
h ospitals , police heliports or news channel heliports. Greenlando does not operate its UAs in areas where general public is within fifty (50) to one hundred ( 100) yards depending on location,
conditions and weather. Greenla ndo’s pilots and observers are constantly on alert for any manned aircraft and prepared to immediately abort and land the UA at the nearest and safest ground point
in the event a m anned aircraft approach es or the Greenlando pilot or observer suspects a man ned aircraft may approach the operating area of a Greenlando UA. Greenlando’s UA s are capable of vertical and horizontal operations, and are flown only within my line of sight of the pilot

. Greenlando’s UAs utilize battery power rather than combustible fu els

. Greenlando do es not operate its UA s below the manufacture r’s recommend ed minimum charge levels for operation preferring to remain well within a safe operating range to insure adequate communication between
radio control and the UA s to eliminate poten tial for crash es , loss of control or hazard. Fully charged

r eserve batteries are on hand to insure replacement for a sufficient ly safe level of operation. Greenlando operates conservatively and does believe in taking risk s that may cause a crash or that

co uld create hazard to the public

, property and manned aircraft

. Greenlando’s pilots have logged numerous practice flights in order to simulate flights for future commercial use to gain familiarization with the characteristics of this specific UA ’s performance under different weather
conditions.

Greenlando is extremely cautious when operating of its UAs a nd will not “create a hazard to users of the national airspace system or the public.” 5 Given the small size and weight of Greenlando’s UAs, they fall well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UA s into the national airspace system.
Greenlando’s UAs , u tilized in hobby flight, has a demonstrable safety record and do not pose any threat to the general public or national security.

5 112 P.L. 95 § 333 (b).Page 7 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com GREENLANDO ’S REQUEST WILL BENEFIT THE PUBLIC AT LARGE

Aerial imagery, videography and photography has been around for a long time through the
use of manned fixed wing aircraft and helicop ters. The challenge for businesses and consumers is that the expense related to manned imagery, videography and photography is cost prohibitive. Typically, on ly large businesses and high net worth landowners are able to absorb such an

enormous expense. Th is d epriv es non

- luxury landowners and small revenue companies from enjoying the benefit of this valuable t ool. Manned aircraft pose a clear threat to the general public through potential catastrophic crash es that may occur. There are many documented events where a manned aircraft has crashed into populated areas with the size and combustibility of these manned aircraft causing large property damage, human injuries and loss of life. Greenlando’s UAs pose no such threat since size and lack of combustib le fuel alleviates any of these potential threat to the public.

With the passage of the Reform Act, Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UA s into the national airspace system . The grant of the exemption request by Greenlando furthers the public interest by making this cost effective alternative available to companies and average landowners. Greenlando’s ultralight UA s are battery powered and create no emissions that may harm t he environment. In the unlikely event of a Greenlando UA crash, the consequence is far less than a full size manned helicopter or fixed wing aircraft

, which are heavy and contain combustible fuel , crashing and causing catastrophic devastation to the public

.

The public’s interest is furthered as Greenlando minimiz es ecological and crash threat by permitting aerial imaging, video graphy and photo graphy capture d through Greenlando’s battery operated ultralight UA’s

. Permitting Greenlando to immediately fly wi thin national air space
furthers not only public safety but economic growth. In the end, the granting of this exemption to
Greenlando will serve as a benefit and stimulus to any community.

Accordingly, Greenlando respectfully requests that the FAA grant t he requested exemption without delay

.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Greenlando proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations unde r the current regulatoryPage 8 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com structure because the proposed operations represent a safety enhancement to the operations
conducted with conventional aircraft

.

These limitations and conditions to which Greenlando agrees to be bound when conducting
all operatio ns under an FAA issued exemption include:

1. The UAs will weigh less than fifty

- five ( 5 5) pounds (25 Kg)

.

2. Maximum total flight time for each operational flight will be two (2) hours . Flights
will be terminated at twenty

- five percent (25 % ) battery power res erve should that occur prior to the two (2) hour time limit.

3. Flights will be operated at an altitude of no more than four

- hundred ( 400 ) feet AGL

.

4. Greenlando’s UA s may not be operated at a speed exceeding eighty

- seven ( 87 ) knots (100 miles per hour) and may use either groundspeed or calibrated airspeed to determine compliance with the eighty

- seven ( 87 ) knot (100 miles per hour) speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

5. The UA Pilot will be Pilot in Command ( PIC ).

6. Minimum crew for each operation will consist of the PIC and a Visual Observer (“ VO ”)

.

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

8. The UA s will only operate as defined in the FO P M.

9. A briefing will be conducted with regard to the planned UA operations prior to flight operations . It will be mandatory that all personnel who will be performing duties with regard to the flight operations be present for this briefing.Page 9 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 10. Greenlando will obtain the consent of all participating persons involved in the

purpose s outlined above or such similar operations

.

11. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons

.

12. The PIC and VO will have been trained in operation of UAs generally and received

up

- to

- date information on the particular UA to be operated and the UA will be operated in conformity with Greenlando’s FOPM.

13. The PIC and VO will at all times be abl e to communicate via voice communication.

14. Written and/or oral permission from the relevant property holder ( s ), or their authorized representative(s), will be obtained.

15. 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.

16. If the UA loses communications or loses its GPS signal, the UA will return to the launch site of the UA, or another more appropriate site, and land.

17. The UA will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. PART 21, SUBPART H:

AIRWORTHINESS CERTIFICATES 14 C.F.R. §91.203 (A) (1)

Subpart H, entitled Airworthiness Certificates, establishes the proced ural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Greenlando , an exemption from Part 21 Subpart H meets the require ments of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness

ce rtificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UA . In all cases, an analysis of these criteria
demonstrates that the UA operated without an airworthiness ce rtificate, in the restrictedPage 10 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com environment and under the conditions proposed will be at least as safe, or safer, than a conventional fixed wing or rotorcraft aircraft operating with an airworthiness certificate without the restrictions and conditions propose d.

The UAs to be operated hereunder is less than fifty

- five ( 5 5) pounds (25 Kg) fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively as set out in the FOPM . Unlike other c ivil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the FOPM ’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the ar ea of operation as is now done with conventional aerial photography

. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production

, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAs , due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (B). MARKING OF THE AIRCRAFT

The regulation requires:

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

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

- sport," "experimental," or "provisional," as ap plicable.

Even though the UAs will have no airworthiness certificate, an exemption may be needed
as the UAs will have no entrance to the cabin, cockpit or pilot station on which the word s "limited," "restricted," "light

- sport," "experimental," or "provisi onal," may be placed. Given the size of the

UAs , two

- inch lettering will be impossible. Any other term as is so required by the FAA, will be placed on the fuselage of the UAs in compliance with §45.29 (f).Page 11 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com The equivalent level of safety will be provided by having the UAs marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAs will see the
identification of the UA s. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 87 38, 10167 and 10167A.

14 C.F.R. § 61.113 (A) & (B): PRIVATE PILOT
PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND

14 C

. F

. R

. § 61

. 11 3 ( A) & ( B ) ; 6 1

. 133 ( A ) : P R I V A T E P IL OT P R I V IL EGES ANDL I M I T A T I ONS;
P IL O T I N C OMMAND; C O M MERC I A L PI L OT P R I V IL EGES AND L I M I T A T I ONS.

S ec t i on 61

. 11 3 ( a) & ( b) li m i t p r i v a t e p il o t s t o no n

- c o mm e r c i al ope r a t i ons. U n li k e a

con v en t i onal a i r c r a f t t hat c a rr i es a p il o t , passe n g e r s, and c a r g o , t he UA i n t h i s case i s r e m o t e l y

con t r o ll ed wi t h no passe n g e r s or p r ope rt y o f o t h e r s on bo a r d. S ec t i on 6 1

. 133 ( a ) r e qu i r es an i nd i v i dual wi t h a c o m m e r c i al p il o t ’ s li cense t o be p il ot i n co m m and o f an a i r c r a f t f or

c o m pensa t i on or h i r e. Greenlando r e spec t f u ll y p r oposes t h a t ope r a t or r e q u i r e m en t s shou l d t a k e i n t o account t he cha r ac t e r i s t i cs o f t he pa r t i cu l ar UA

.

The FAA has noted the following in the previously granted exemption number 11192:

“ R egarding the petitioner’s requested relief from 14 CFR § 61.113 Private pilot privileges and limitations, the FAA must consider the appropriate level of pilot certification for the petitioner’s proposed operations. The petitioner states it would operate its UAS with a pilot holding a sport pilot certificate or a recreational pilot certificate and certified by the UA manufacturer and has completed the FAA private pilot ’s written exam. Under current regulations, civil operations for compensation or hire require a PIC holding a commercial pilot certificate per 14 CFR part 61. As established in 14 CFR § 61.113(a), with limited exception, a pilot holding a private pil ot certificate cannot act as a PIC of an aircraft for compensation or hire. However, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus
UAS would not adversel y affect operations in the NAS or present a hazard to persons or property on the ground. Additionally, as previously determined by the Secretary of Transportation, the requirement to have an airman certificate ameliorates security concerns over civil UAS o perations
conducted in accordance with Section 333.”Page 12 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS

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

.

14 C.F.R. § 91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT

Section 91.9 (b) (2) provides:

No person may operate a U.S. registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved a irplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The UAs , given their size and configuration has no ability o r place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the FOPM at th e ground control point where the pilot flying the UAs will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C .F.R. § 91.103: PREFLIGHT ACTION

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safet y will be provided as set forth
in the FOPM . The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.Page 13 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 14 C.F.R. §91.109: FLIGHT INSTRU CTION

Section 91.10 9 provides that no 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.

UA s and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional d ual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K and 9862A. The equivalent level of safety is provided as neither a pilot nor passengers will be carried in the aircraft and by the size and speed
of the aircraft.

14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person

ope rating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for UAs that are a helicopter and the exemption requests authority to operate at altitudes up to four

- hundred ( 400 ) feet AGL, or not mor e than two

- hundred ( 200 ) above an elevated platform from which aerial photography is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the FOPM , the UAS will never operate at hig her than four

- hundred ( 400 ) feet AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieve d given the size, weight, speed of the UA s as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner (s), or their
authorized representative(s), all affected individuals will be aware of the planned flight operations
as set forth in the FOPM . Compared to flight operations with aircraft or rotorcraft weighing far in excess of the less then fifty

- five ( 5 5) pounds (25 Kg) limit pro posed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below five

- hundred ( 500 ) feet AGL

. In addition, the
low

- altitude operations of the UAs will ensure separation between these small UAs operations and the operations of conventional aircraft that must comply with Section 91.119.Page 14 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 14 C.F.R. §91.121 ALTIMETER SETTINGS

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UA may no t have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the FOPM and Safety Check list, confirming the altitude
of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS

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

– (1) 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.”

Gree nlando believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly contro lled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than thirty ( 30 ) minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate gi ven the size and speed of the small UA s

. Additionally, limiting UA flights to ten ( 10 ) minutes would greatly reduce the utility and economic efficiency for which the exemption will be granted.

Greenlando believes that an equivalent level of safety can be achieved by limiting flights

to two (2) hours or twenty

- five percent ( 25% ) of battery power whichever happens first. This restriction would be more than adequate to return the UAs to their planned landing zone from anywhere in its limited operating area.

Similar exemptions to this regulation have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.Page 15 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 14 C.F.R. §91.203 (A) AND (B): CARRYING CIVIL
AIRCRAFT CERTIFICATION AND REGISTRATION

The regulation provides in pertinent part:

(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 airwo rthiness 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.

The UA s fully loaded weigh t is no greater than fifty

- five ( 5 5) pounds (25 Kg) and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UA

.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UA will have immediate access to them to the extent they are applicable to the UA . The FAA has issued numerous exemptions to th is regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (A); 407 (A) (1); 409 (A) (2); 417(A) & (B):
MAINTENANCE INSPECTIONS

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Greenlando . Maintenance wi ll be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the FOPM

. An equivalent level of safety will be achieved because these small UA s are very limited in size and will carry aPage 16 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com small payload and operate on ly in restricted areas for limited periods of time. If mechanical issues
arise the UA s may land immediately and will be operating from no higher than four

- hundred ( 400 ) feet AGL. As provided in the FOPM , the operator will ensure that the UA s are in workin g order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provid e the equivalent level of safety.

*********

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:

Greenlando seeks an exemption from the following ru les: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small
unmanned vehicle weighing less than fifty

- five ( 5 5) pounds (25 Kg) in its operations.

Approval of exemptions allowing commercial operations of UA s for the operational

purpose s outlined above, or similar operations

, will enhance safety by reducing risk. Typically, these types of operations are performed using jet or piston power aircraft . These aircraft operate at extremely low altit udes just feet from the object being photographed and often in extreme proximity to people and structures . They also present heightened risks associated with vehicles that weigh in the neighborhood of four thousand ( 4,000 ) pounds , carrying large amounts of jet A or other fuel ( one hundred and forty ( 140 ) gallons for jet helicopters )

. Not only is th ere danger created using these types of aircraft during operations, s uch aircraft must fly to and from the site’s location. In contrast, a UA weighing less than fifty

- five ( 5 5) pounds (25 Kg) and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel
carried on board. The UA is carried to the site of the purpose s outlined above (or similar operations) and not flown to the site . The UA will carry no passengers or crew and, therefore, will not expose th em to the risks associated with manned aircraft flights.

The operation of small UAs, weighing less than fifty

- five ( 5 5) pounds (25 Kg) , conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of t he exemptions requested herein, including exempting Greenlando from the requirements
of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speedsPage 17 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com and close to the ground and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

PRIVACY

All flights will occur over controlled or approved property with the property owner’s , or their authorized representative, prior consent and knowledge. The aerial imaging will be of structures and objects whose owner, or authorized representative, has consented to the aerial photography. The grant of this exemption request will provide improved safety in operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adeq uate justification for the grant ing of the requested exemptions allowing co mmercial operation of Greenlando’s UAs pursuant to the
FOPM attached hereto.

SUMMARY OF GREENLANDO ’S REQUEST FOR AN FAA EXEMPTION

1. Operations authorized by this a grant of exemptio n will be limited to the requested aircraft when weighing less than fifty

- five ( 55 ) (25 Kg) pounds including payload.

2. Operations for the purpose of closed

- set motion picture and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding eighty

- seven ( 87 ) knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the eighty

- seven ( 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 must be operated at an altitude of no more than four

- hundred ( 400 ) feet above ground level (AGL) and the a ltitude must be reported in feet AGL.

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

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

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may bePage 18 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UA s and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between th e conditions and limitations in this exemption and the procedures outlined in the operating documents, conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator mu st petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UA that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC w ith a VO and must remain at least five

- hundred ( 500 ) feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UA to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

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

- flight inspection must account for all potential d iscrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UA, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight.Page 19 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 11. The operator must follow the UA manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UA operated under this exemption must comply w ith all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold

a current FAA airman medical certificate or a valid U.S. driver’s license issued by

a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exempti on. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UA operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC).
F lights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within five ( 5 ) nautical miles of an airport reference point ( “ ARP ” ) as denoted in the current FAA Airport/Facility Directory ( “ AFD ” ) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a Certificate of Waiver and Authorization (“ COA ”) is sued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.Page 20 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com 17. The UA may not be operated less than five

- hundred ( 500 ) feet below or less than

two

- thousand ( 2,000 ) feet horizontally from a cloud or when visibility is less than three ( 3 ) statute miles from the PIC.

18. If the UA loses communications or loses its GPS signal, the UA must return to a
pre

- determined location within the private or control led

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning 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 the manufacturer if greater.

21. All aircraft operated in accordance with this exemption must be identified by serial number, register ed in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available

to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official up on request.

23. The UA must remain clear and give way to all manned aviation operations and activities at all times.

24. The UA may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least five

- hundred ( 500 ) feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers /signs will be set up to suffic iently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparti cipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within five

- hundred ( 500 ) feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

,

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made aPage 21 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com safety assessment of the risk of operating closer to those objects and determine d that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

26. All operations shall be conducted over private or controlled

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

27. Any incident, accident, or flight operation that transgresses the la teral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within twenty

- four ( 24 ) hours. Accidents must be reported to the National Transportation Safety Board ( “ NTSB ” ) per instructions contained on the NTSB Web site: www.ntsb.gov

.

Unless otherwise specified in a grant of exemption, the UA, the UA ’s PIC, and the UA ’s operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91

.

Greenlando Consulting, LLC respectfully requests the FAA grant an exemption pursuant to this application.

Sincerely

,

Philip A. K. Stiles, Esq. Stiles Law, P.A.
Counsel for Greenlando Consult ing , LLC