### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmazi arz@gmail.com 303 - 641 - 1105 Page 1 of 17 Brian R. Maziarz 88 Emerson Rd. Longmeadow , MA 01106 August 22, 2015 U.S. Department of Transportation Docket Management System 1200 New

Jersey Ave., SE Washington DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 C.F.R. 21 subpart H; 14 C.F.R. 45.23(b ) ; 14 C.F.R. 61.113(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. 91.103; 14 C.F.R. 91.119 ( c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C .F.R. 91.203(a) and (b); 14 C.F.R. 91.405(a ) ; 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409 ( a)(1) and (2); 14 C.F.R. 91.417 ( a) and (B) Dear Sir or Madam: P ursuant of Section 333 of the FAA Modern ization and Reform Act of 2012 ( The Reform Act) and 14 C.F.R. P art 11, Brian Maziarz, Operator of Small Unmanned Aircraft Systems ("sUASs"), 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 FAA as required by Section 333. Commercial operation sUASs, as described herein, which are equipped with cameras and sensors, would operate in the following manner: 1. Aerial Photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. Aerial video and/or photography for public and/or private use including television, closed
- set motio n picture, public events, cinematography and ne ws gathering. 2. Aerial Inspection/photography of residential/commercial structures under contract with the owners or local authority. 3. Aerial video/photography or providing live video feed to assist with search and rescue operations In cases of an emergency or natural disaster only when the local authorities or government has requested It by contract or donation. 4. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of sUASs for the purpose of the safe operation of sUASs to enhance the safety of the National Airspace System ("NAS") as well as for the protection of the persons or property.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 2 of 17 As Described fully b elow the requested exemption would permit the operation of sUASs under controlled conditions in the NAS that would be a) Limited b) Controlled c) Predetermined and d) Will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (The FAA Administrators) responsibilities to "establish requirements for the safe operations of such aircraft systems i n the national airspace system.'' The Name and address of the applicant is: Attn: Brian R. Maziarz Ph: 303
- 641 - 1105 Email : bmaziarz@gmail.com Address: 88 Emerson Rd. Longmeadow, MA 01106 Regulations from which the exemption is requested: 14 C.F.R. part 21 subpart H 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113 (a) & (b) 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 (c) 14 C.F.R. 91.121 14 (.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) The Applicants sUASs are multi
- ro tor craft weighing less than 55lbs. i ncluding payload. Under normal conditions they ope rate at speeds of no more than 5 Okts and have the ability to hover and move along a vertical and horizontal plane simultaneously. They will o perate in the line of sight and will operate within a closed off and predetermined area owned and/ operated by the property representative. Given the small size of the s UASs and the controlled environment provided the proposed operations will adhere to the Reform Act's Safety Requirements. The Approval of this Application presents no National Security issues. Regarding the level of safety surrounding the proposed operatio ns and the public benefit, reduc tion in environmental im pacts, including but not li m ited to reduced emissi ons and noise, the grant of the requested exemption is in the public Interest. Accordingly th e applicant requests that the FAA grant the r e quested exe mp tion with minimum delay.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmazi arz@gmail.com 303 - 641 - 1105 Page 3 of 17 **AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventiona l aircraft. These limitations and conditions to which the applicant agrees to adhere to w hen conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The sUASs will weigh less than 55 lbs. 2. Flights will be operated within line of sight of the pilot and/or observer. 3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight whichever occurs first. 4. Fli ghts will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the sUASs Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator/ Technician. 6. The sUASs pilot will be a designated Pilot In Command (PIC) and hold a current Third or Higher Class Medical Certificate, along with a valid state driver's license. If the PIC feels an other operator to be qualified with the necessary skills to be PIC & possess a Third or higher Class Medical and a valid state driver's license, that person may be designated PIC provided they have a minimum of 20 hours of flight time with the sUASs. 7. A bri efing will be performed regarding the planned sUASs operations prior to each day's flight consisting of all the days' production activities. 8. The operator will file FAA Form 7711
- 1, or its equivalent, as modified in light of the requested exemption, with th e appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 9. The operator will obtain verbal/w ritten consent of all persons involved with the planned operation and ensure that only cons enting persons will be allowed within the 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 10. The PIC and VO will have been trained in operation of sUASs and receive up
- to - date i nformation for the particul ar sUASs to be operated. 11. The PIC and VO will be able to communicate by voice; radio, and/or text at all times. 12. Written and/or verbal permission and permits will be obtained from territorial, state, county, or city jurisdictions , including law enforcement, fire or other appropriate governmental agencies. 13. If the sUASs loses communication or loses GPS signal, the sUASs will have the capability to return to a Pre
Determined location within a designated location and land autonomously. 14. The sUASs will have the cap ability to abort a flight in case of unpredicted obsta cles, weather, or emergencies.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 4 of 17 **14 C.F.R. Part 21, Subpart l -**  **t: Airworthiness Certificates 14 C.F.R. § 91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requ irements 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 the Applicant, an exemption from Part 21 Subpart H meets the requirements o f 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 certificat @1 upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUASs. In all cases, an analysis of these criteria demonstrates that the sUASs operated without an airworthiness certi ficate, in the restricted environment and under the conditions proposed will be at least safe, or safer, that a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUASs to be operated hereunder Is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive material or flammable liquid fuels, and operates exdus1vely within a secured and designated area. Unlike other civil aircraft , operations under this exemption will be tightly controlled an d monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advanced notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C,F,R, Part 211 Subpart H. Lastly, application of these same criteria demonstrates that there Is no credible threat to national security posed by the sUASs1 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 capitol letter "N" and the registration number is displayed on limited, restricted or light
- sport category aircraft or experimental or provisionall y 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 mo re than 6 inches high, the words "limited”, "restricted”, "light· sport”, “experime ntal”, or Provisional”, as applicable. Even though the sUASs will have no airworthiness certificate, an exemption may be needed as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" will be placed on the fuselage i n compliance with §45.29 (f). The equivalent level of safety will be provid ed by having the sUASs marked on i ts fuselage as required by §45 .29 (f ) where the pilot , observer and others working with the sUASs will see the identification of the sUASs as ''Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738 10167, and l0167A.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 5 of 17 **14 C.F.R. § 61.113 (a) & (b): Private pilot Privileges and limitations: Pilot In Command.** Pursuant to 14 C.F.R, 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Our sUASs do not carry any pilots or passengers nor prope rty therefore I am seeking an exemption to 14 C.F.R. 61.113 (a) & (b). Although helpful, a pilot's license will not ensure remote control piloting skills. Unlike conventional aircraft that carries a pilot and passengers, the sUASs is remotely controlled wi th no persons onboard. The area of operation is controlled and restricted; and all flights are planned and coordinated in advance. The risks associated with the operation of the sUASs are so diminished from the level of risk associated with commercial oper ations contemplated by Part 61 when drafted, that allowing operations as requested with a skilled PIC in the ground crew exceeds the present level of safety achieved by 14 C.F.R. §31.113 (a) & ( b). The applicant has also been found to be properly qualifie d to exercise the privileges of Commercial Pilot with Rotorcraft
- Helicopter and Instrument Helicopter Rating. 1 **4 C.F.R. § 91.7 (a): Civil aircraft Airworthiness.** T he regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certi ficate issued for the aircraft, should th i s exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety che ck lists prior to each flight and equivalent level of safety will be provided. **14 C. F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft**  **.** Section 91.9 (b) (2) provi des: No person may operate a U.S. registered civil aircraft ... (2) For wh ich an Airplane or Rotorcraft Flight Manual is not required by §21.S of this chapter, unless there is available in the aircraft a current and approved airplane or rotorcraft flight manual, approved manual material, markings, and placards, or any combinat ion thereof. The sUASs, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board; but because there is no roo m or capacity to carry such an i tem on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control poi nt where the pilot flying the sUASs will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8807, 8737, 8738, 9299, 9299A, 9565; 95658, 10167, 10602, 32827; and 10700 **14 C.F.R. § 91.103: Preflight Action.** This regulation requires each PIC 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. The PIC wi ll take all actions including reviewing weather, flight battery requirements, l anding and takeoff distances, an d aircraft performance data before initiation of f l i ght. Further, w e have proprietary manuals created with the help of sUASs experts, the manufactures, and the regional sUAS vendor, and continue to work with these organizations to ensure best safe practices are adhered to.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 6 of 17 **14 C.F.R. § 91.109: Flight Instruction.** Section 91.103 provides that no person may operate a civil aircraft (except manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs 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 dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passenger will be carried i n the aircraft and by the size and speed of the aircraft. **14 C.F.R. § 91.119: Minim um safe Altitudes.**  Section 91.119 establishes safe altitudes for operation of civil airc raft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operat ing the helicopter complies with any route or altitudes prescribed for helicopters by the FAA . As this exemption i s for a sUASs that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an e levated platform from which filming Is planned, an exemption may be needed to allow such operations. As set forth herein, the sUASs is used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUASs will not be operated more than 100 feet above the highest point of the structure. It will however be operated i n a restricted area with a security perimeter; where buildings and people will not be exposed to operations without their pre - obtain ed consent. The equivalent level of safety wil l be achieved given the size, weight, speed of the sUASs as w ell as the location where it i s to be ope rated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected Individuals will be aware of the planned flight operations, Compared to flight operations with aircraft or rotorcraft weighing far mo re than the maximum 55 lbs. proposed 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 500 AGL. In addition, the low
- altitude operation of the sUASs will ensure separation betw een these small sU AS s operations and the operations of conventional aircraft that must corn ply with Section 91.119. **14 C.F.R. § 91.121: Altim eter Settings.**  Section 91.121 requires each person operating an aircraft to maintain cruisin g altitude by reference to an altimeter that i s set “... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUASs may not have a barometric altimeter, but instead a GPS altitud e read out, an exemption may be needed. An equivalent level of sa fety will be achieved by the operator, confirming the altitude o f the launch site shown on the G PS altitude indicator before flight. The PIC and technician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of heig ht.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 7 of 17 **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 w eather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal crui sing 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. The battery powering the sUASs provides approximately 30 minutes of powered flight in hover mode without payload. The applicant’s sUASs will not be able to mee t the 30 - mi nute reserve requirement in 14 C.F.R §91.151. Given the limitations on the sUASs proposed flight area and the location of its proposed operations within a predetermined area, a longer flight time frame for flight i n daylight or twilight VFR conditions is reasonable. Operating the sUASs, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minute of reserve p ower , does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the s UAS s . Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery p ow er whichever comes first. This restriction would be more than adequate to return the sUASs to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689f, 57 45, 10673, and 10808. **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 airworthiness certificate required by paragraph (a) of thi s section to a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers and crew
. The sUASs fully loaded w eighs 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 or to display them on the sUAS s . An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUASs will have immediate access to them; to the extent they are applicable to the sUASs. Th e FAA has i ssued numerous exemptions to this regulation. A representative sample of other exem pti ons includes Exemption Nos. 9565, 9665 , 9789, 9789A, 9797, 9797A, 9816A, and 10700
.

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August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 8 of 17 **14 C.F.R. § 91.405 (a); 407 (a)(t); 409 (a)(2); 417 (a) & (b): Maint enance inspections**  These regulations require that an aircraft operator or owner ''shall have that aircraft inspected as prescribed in subpart E of this chapter 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 the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual, operating handbook and maintenance handbook. An equivalent level of safety will be achieved because these sUAS s are very limited in size and will carry a small payload and operated only in restricted areas for limited periods of time. I f mechanical i ssues arise the sUASs can land i mmediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the sUASs is in working o rder prior to initiating fllght, pe rform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best s uited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and i nspections will be performed in accordance with the sUASs Manufacturer's Manual1 as referenced in the Aircraft Operations Manual (A OM). As provided in the FOM, the operator will ensure that the sUASs is in working order prior to initiat ing flight and perform required maintenance needed.
******* Pursuant to 14 C.F.R. Part 11, the following summary is provided for the publication in the Federal Register, should it be determined that publication i s needed: Applicant seeks an exemption from the following rules: 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; 91.121; 91.15l(a); 91.203(a) & (b); 91.40S (a); 91.407(a)(1); 91.409(a) (2); and 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) in motion picture and television operations , as well as in the public and private sector. Approval of exemptions allowing commercial operations of sUASs lh the film industry will enhance safety by reducing risk. Conventional film operations, using jet or piston powered aircraft operate at extreme ly low altitudes just feet from the subject being filmed and in e xtreme prox imity to people and structures; and present the risks associated With vehicles that weigh in the neighborhood of 4JOOO lbs., carrying large amounts of Jet A or other fuel. (140 gal lons for the jet helicopter shown below .) Such aircraft must fly to and from the film location. In contrast, a sUASs weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible f uel carried onboard. The sUASs is carried to the film set and not flown. The sUASs will carry no pass engers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 9 of 17 **Privacy** All flights will occur over private or controlled access property with the property owner's or official representative's prior consent and knowledge. Filming will be of the people who have also consented to being filmed or otherwise have agreed to be In th e area where filming will take place. **Commercial and Public Benefits** The applicant believes that granting this exemption request furthers the public interest by providing safe (by the way of unmanned system) and efficient means to meet technical problems solvable by elevated data collection instruments . The applicants client base are ty pically small to medium sized business' and realtors looking to increase their aw areness of structures or landscape on their respective properties through data collection b y photographic, video graphic or LIDAR based surveying. By moving these subjects onto sUASs based aircraft ) the potential for loss of life or property is diminished due to the greater control in a smaller and safer aircraft that holds no pilot, crew , or pa ssengers. Second, there are no reactive or combustible materials on board the sUASs and thus the potential for fire or explosion is greatly diminished. Third, the small size and extreme maneuverability of the applicant's sUASs allow the PI C to avoid hazard s. Lastly due to the nature of the remote sensing instrumentation onboard, the sUASs can maintain quite a safe distance between the aircraft and the object(s) undergoing scrutiny. Accordingly, the Applicants sUASs have operated and will continue to operate at and above current safety levels. **The eff ect of an exem** **ption for the appli cant on the quality of the natur**  **al and social environments**  Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an onboard pilo t. Time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civil or military airports, and detrimental effects to the environment caused by operating a combustible fuel_ large scale aircraft, with restrictions o n the proximity to the target for remote sensing, photography or videography. **Flight Capabilities and Characteristics of the Applicants s**  **UASs** Pursuant to 112 P.L . 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and chara cteristics of the sUASs. * The Applicant's s UASs utilizes four (4) counter
- rotating propellers paired oppositely to each other for balance, control and st ability. The total span of the sUASs is = 599 mm to 589mm including propellers, allowing for stable fl ight or landing even with the sudden onset of detrimental environmental conditions. The sUASs maximum weight (including battery, propellers) is 2.9 Kg. The applicant's sUASs is designed to hov er in place to capture photographic data and then operate at le ss than 50 knot maximum speed to the next point of Interest. They are capable of vertical and horizontal operations but, i n practice, is operated only within unaided VLOS of the PIC. In addition to the PIC; the Applicant employs a spotter (VOS role) and a technician (secondary VOS and on - site personnel liaison), which are within verbal communication range. These personnel are supplemented by safety officials provided by the client who are instructed to cordon off and otherwise mi nimize pedestrian access in the flight zone of the client’s grounds. In the eve nt of loss of visual of the s UAS s , the PIC can change the flight controls from Cartesian (X, Y,Z.) based controls to radial (r,x,h) based control, which allows the PIC to utili ze one controller axis to recall the s UAS s to the PIC 's position without concern to the current heading of the sUASs. The sUASs also have a Return - to - Home feature that allow s the s UAS s to return to the PIC 's location in the case of the s UAS s losing signal to the PIC, or i f the PIC initiates the Return - to - Home procedure. In the event of loss of sight of the sUASs i nto an area containing hazards or possible hazards, the spotter has a heads
- up - display containing a live video feed which can be used to locate th e s UAS s while it maintains its position hover mode. The sUASs has de mo nstrated its ability to maintain its position by GPS, SONAR, and Optical flow camera with an accuracy of 0.5m vertical and 2.5 m horizontal.

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Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 10 of 17 All of the applicant's sUASs utilize liPo (lithium polymer) battery based power sources, decreasing safety risks from mo re easily combustible, fuel based, pow er sources. Flight times generally last between eight (8) to ten (10) minutes , allowing the staff to work with small areas per phase. The maximum flight time with payload is approximately 18 mi nutes; however the applicant further restricts flight time by not operating the sUASs with less than t wenty five percent (25%) battery capacity. **Reasons Why an Exemption to the Applicant Will Not Adversely Affect Safety Standards**  The Applicant contends that operation of its sUASs will not "create a hazard to users of the national airspace system or the public." As stated in 112 P.L. 95 § 333(b). Given the diminutive size and weight of the sUASs, combined with their operation in cordoned off and w ell
- controlled areas. The applicant's sUASs falls within congress's contemplated safety zone. The applicant's sUASs have an established safety record bolstered by multi
- p oint preflight checklists, awareness of their surroundings and intimate knowledge and behavior of the sUASs platform in many weather conditions. This safety record and implemented operational practices demonstrates an aw areness of public safety. The app licant has also been found to be properly qualified to exercise the privileges of II COMMERCIAL PILOT III CERTIFICTE NUMBER (provided upon request) X DATE OF ISSUE 14 OCT 2006 (original), 2 DEC 2014 (reissued/copy) XII RATINGS ROTORCRAFT - HELICOPTER; INSTRUMENT HELICOPTER XIII LIMITATIONS NONE The applicant is extremely familiar with airspace regulations, flight safety, planning, navigation and other topics that will ensure safe operations of a sUAS. The applicant routinely provides a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules while operating the sUAS. The applicant's sUASs does not and cannot operate on or near airports and generally has only operated its fleet on private grounds with cordoned off are as or areas under the control of the property owner/ client with assistance by safety officials employed by the business. The applicant determines the areas needed to fulfill the clients goals and only operates its sUASs in these flight zones and only in c om pliance with well
- regarded safety protocols set forth initially by the RC s UAS s trade and hobby groups and recently codified by relevant FAR's. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012
- sl2e, weight, speed, operatin g capabilities, proximity to airports and populated area and operation within visual line of site and national security
provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the applicant's sUA Ss in the real estate, architecture, land survey/ engineering, motion picture and television industry pursuant to the manuals appended hereto. Sincerely, Brian Maziarz Encl: Supplement A: Physical Characteristics./ Specifications of sUASa (3 pages) E ncl: Supplement B : Flight operations and procedures Manua l (FOPM) related to operation (3 pages) Encl; Supplement C : Inspire 1 Safety Guidelines v1.0 **Supplemental A: Physical Characteristics/ Specifications of s**  **UAS s**  **Page 1**

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**Supplemental A: Physical Characteristics/ Specifications of s**  **UAS s**  **Page 2**

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**Supplemental A: Physical Characteristics/ Specifications of s**  **UAS s**  **Page 3**

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 13 of 17

**Supplemental A: Physical Characteristics/ Specifications of s**  **UAS s**  **Page 3**

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 14 of 17

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 15 of 17 **Supplemental B: Summary Sections of Flight Operations**  **and Procedure Manual (FOPM) Page 1 I.**  **Introduction** This manual describes the notable roles, tasks, and operations per formed by the applicant Brian Maziarz
. **II. Roles and Responsibilities**  Pilot in Command (PIC)  Piloting the s UAS s . This will Include: o Takeoff o Normal flight o Flight during emergency procedures o Landing  Assembling the s UAS s  Performs pre
- flight checks of the firmware  Performs pre
- flight checks of the hardware  Performs preflight checks of the software Spotter  Relays notable flight parameters such as flight time battery strength, an d telemetry from the s UAS s .  Primary communication between pilot and on
- site safety personnel  Will hold physical documents related to current flight  Performs pre
- flig ht checks of the data collection equipment  Monitors ground and above
- ground environment for safety concerns Technician  Assembling the s UAS s  Preforms pre
- flight checks of the hardware  Preforms pre
- flight checks of the software  Secondary communication link between pilot and onfts1te safety personnel  Relays to the spotter and records notable f light data telemetry from the s UAS s  Monitors ground and above
- ground environment for safety concerns **III. Pre**  **- Flight Check List**  **A. Before power is applied**  Check for physical damage and any missing hardware  Check all electronics present end connected/ check cord connections are tight  Confirm all batteries are charged  Check all rotors and moving parts for debris that would prevent proper operation  Check weather patterns the night beforehand.  Check all data collection equipment for proper Installation/operation  Check all data collection equipment for issues that would impact safe operations of flight package.

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 16 of 17 **Supplemental B: Summary Sections of Flight Operations**  **and Procedure Manual (FOPM) Page 2 B. After power source is applied**   Confirm proper power reading of battery  Run hardware based systems check  Run software based systems check  Check flight LED array  Confirm proper radio link to flight controller  Confirm pr oper radio link to data collection device controller  Confirm secondary controller connection to s UAS s onboard flight controller  Confirm desired behavior of emergency fail safes  Check with on - site safety personnel for any changes i n plan **IV. Run**  **- Up Checklist**   Check with on
- site personnel for safe flight area for first flight  Record relevant metrics in flight log  Check for ground hazards at home base  Confirm GPS lock  Confirm initial state of controllers  Initialize rotors and check for proper operation  Check land ing gear flight mode (up) operation  Perform controlled multi
- axis roll procedure to check for proper orchestrated rotor operation  Hover check  Return s UAS s to normal orientation  Perform controlled flight to hover mode one (1) meter above the ground  Check landing gear landing mode (down) operation  Land the s UAS s and check for proper de
- initialization of rotors  Perform controlled flight to hover mode approximately five ( 5) meters above the ground  Check landing gear flight mode (up) operation  Return s UAS s to normal orientation  Remove power to the flight package  Remove power to the data collection package  Remove power to controllers  Com plete flight log **V. Standing Procedures** 

 The Pilot, Spotter, and Technician will be the only members in the forward flight area. On - site personnel will be within verbal range behind the PIC, Spotter, and Technician  The maximum power used to control the device is soft limited to 75% in order to maintain power in reserve for unforeseen conditions  Flight time is limited to reserv ing 25% battery power  Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 400ft. AGL  Flight time is limited to operation in safe environmental conditions  Flight staff will maintain proximity so as to be in dear ve rbal range  The PIC will announce all movements to staff and on
- site staff so that non
- PIC staff members can identify possible safety concerns before operation of the s UAS s to the next waypoint or position  All regular and irregular operations are noted with timestamps, relevant s UAS s metrics and corrective action procedures ( CAP) that are performed o Note: All irregular behavior have root cause analysis performed before s UAS s operation is resumed

### U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz 88	Emerson	Rd.	Longmeadow	MA,	01106 bmaziarz@gmail.com 303 - 641 - 1105 Page 17 of 17 **Supplemental B: Summary Sections of Flight Operations and Pr ocedure Manual (FOPM) Page 3** 

**VI. Emergency procedures** 

 Loss of Remote Signal o The flight package features an optional enhanced fail
- safe which returns the s UAS s to the home base way point or the operator controller by climbing to an altitude above the highest obstacle but not to exceed airspace limitations and will then return to home direct line of site. o The s UAS s will then perform a hover over the home point o r controller and perform a controlled landing o This failsafe mode can be overridden by the PIC if the signal returns  Loss of GPS signal o The system will operate in GPS mode with three (3) satellites o At loss of three (3) GPS satellites, manual mode can be act ivated and the flight package can be programmed to perform a controlled landing to the home point. o Ground based height ranging is performed by separate system and so loss of GPS will not impact controlled landing in a safe manner  Loss of Ground Control Sof tware o This will not affect operation of the flight. The unit will be piloted to a safe landing area so that examination of the l ink can be made.