February 20, 2015

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. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington , DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act. Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") , AviTronics Integrated Solutions, LLC ("AviTronics"), the operator, David 

### A. Akers (the applicant) , planned operator of Unmanned Aircraft Systems (UASs) equipped to conduct aerial photography and digital point cloud surveys forvarious industries hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation ofour UASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333
. As described more fully in Appendix A, the requested exemption would permitthe operation of UASs by the operatorfor commercial use that would provide the following benefits: 1. Operations would be performed in an area of operation limited in size suitable to the specific use, in advance offlight. 2
. The flight would be planned in advance to minimize hazards to persons and property in the air and on the ground

. 3
. The operatorwould reasonably limit or control access to provide safety to those not involved in the operation

. 4. Operation ofa UAS would provide significant safety, environmental and other enhancements not possible by larger sized aircraft. 5. An FAA licensed airman with a Commercial Pilot Certificate would operate the UAS or directly supervise the operation. 6
. Provide a beneficial and currently unavailable service to governmentorganizations and the general public that would serve the public interest.Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAAAdministrators) responsibilities to "

...establish requirements for the safe operation of such aircraft systems in the national airspace system
. "Section 333(c) ofthe Reform Act. It is possible to operate an UAS so to not create a hazard to users ofthe National Airspace System (NAS), the public or pose a threat to national security if done so safely and responsibly

. The applicant has demonstrated theirwillingness to act safely and responsibly by not engaging in commercial UAS operations

. The applicant has worked within FAA guidelines to obtain a legal authorization to conduct commercial operations

. Additionally, the fact that the applicant currently holds a FAA Commercial Pilot Certificate demonstrates thatthe applicant has a high regard to safe operations, as well as a necessary high-level understanding ofthe NAS and FARs

. The experience of a FAA certificate serves to add significantly to the level ofsafety in any operation performed by the applicant orthe applicant's employees. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics of UAS and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level ofsafety to operations underthe current regulatory structure as the proposed operations represent a safety enhancement to the already safe aerial commercial photography and survey operations conducted with conventional aircraft. The UASs planned to be operated are the OJI Phantom 2 Vision , DJI Phantom 2 Vision Plus, and the 30 Robotics IRIS Plus rotorcraft

. Each unmanned aircraft (UA) is equipped with four rotors that are driven by electric motors, powered by batteries, and weigh less than 4 pounds, including payload

. The UA would have a maximum airspeed of 30 knots

. The principal construction material ofthese UA is plastic. Operations will be performed by a qualified UAS Pilot in Command (PIC) , as outlined below, to insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public." Given the small size ofthe UAS involved and the pre-planned environment within which they will operate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption , allow commercial operations of UAS to commence immediately

. Also, operation in a researched (to include applicable NOTAMs), predefined area will prevent the possibility ofa national security issue

. The operation of UASs by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the public benefit and reduce environmental impacts related to current methods of aerial photography and survey. These limitations and conditions to which the operator, or its employees, acting as an UAS PIC, agrees to be bound when conducting commercial operations under an FAA issued exemption : 1
. Safety will be the first and foremost consideration in any UAS operation

.2
. The UAS pilotwill be an FAA licensed airman with at least a Commercial Pilot Certificate orthe UAS pilot will be directly supervised by an FAA licensed airman with at least a Commercial Pilot Certificate

. 3
. The UAS Pilot, and observerwill hold at least a Second Class Medical Certificate

. 4
. The UAS FAA licensed airman will be considered PIC, whetherflying or supervising , and will be responsible for safe operation ofthe flight. 5
. Flights will be conducted within line of sight ofthe PIC and an observer

. 6
. Flights will be conducted in Class G airspace whenever possible. If an operation in another airspace is required, the relevant controlling agency will be notified at least 24 hours prior to the operation and , if required , any necessary permission obtained

. 7
. Flights will be conducted under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR). 8
. The UAS will at all times give way to any aircraft, object, or persons. 9
. Minimum crew for each operation will consist ofthe UAS PIC and an observer. The observer and PIC will at all times maintain visual line ofsite to the UA, and be able to communicate byvoice

. 10
. Priorto a UAS flight, an area of operation will be established

. This area of operation will include a defined lateral and vertical area, where the UAS will operate (Appendix J)

. Safety procedures will be established for persons, property and applicable airspace within the area of operation

. 11. Flight planning will include flight completion with at least 20% battery power remaining as measured by the UAS or appropriate timing. 12. The UAS will utilize GPS navigation, failsafe, return-to-home (RTH) and/orflight abort safety features. 13. A briefing will be conducted in regard to the planned UAS operations prior to operation at each new location (Appendix I through K)

. All personnel who will be performing duties within the boundaries ofthe area ofoperation will be presentforthis briefing

. 14. All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire , or other appropriate governmental agencies

. 15. Written , to include electronic, and/or oral permission from the relevant property owners will be obtained priorto an operation

.16. The UAS pilot will be trained in advance for the safe operation ofthe UAS to be operated

. This will include operation ofthe UAS both in normal and emergency modes of operation as applicable, and will include familiarization with the operation manual (or similar) if published by the UAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace. Attached Appendix B, please find a letterfrom Technical Applications & Consulting , LLC requesting a UAS operation in Orange, Texas thatwill document a current landfill project. This operation serves as an excellent example ofthe benefits of using a UAS

. It represents an enhancement in safety as well as benefiting the public interest. It is respectfully requested that the FAA grant an exemption as soon as possible to enable TAC's project to be documented within their time constraints. It is the applicant's beliefthat the size, speed, operating environment, limitations, and level ofapplicant's experience in the NAS outlined provides an "equivalent level of safety" or better when operating a UAS for the public interest as outlined in Section 333 in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue an exemption to permit safe, legal, commercial UAS operation by the applicant as soon as possible

. Sincerely,

David Akers, President AviTronics Integrated Solutions, LLC P.O. Box 1644 Rockwall, TX 75087 972-708-1535

Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Exemption Requests and Equivalent Level ofSafety Letterfrom Technical Applications 

### &Consulting DJI Phantom 2 Vision User Manual DJI Phantom 2 Vision Plus User Manual 3D Robotics IRIS Plus Operation Manual 3D Robotics IRIS Plus Flight Checklist 3D Robotics Gimbal User Guide AviTronics Flight Log Form AviTronics Project Risk Assessment Form AviTronics Project Concept Sheet AviTronics Project Brief/Debrief Form