Robert A. Simcox

22560 US Highway 64

Somerville, TN 38068

901-517-8348

29 December 2015

U.S. Department of Transportation, Docket Management System

1200 New Jersey Ave SE

Washington, DC 20590

Filed with www.regulations.gov

Subject: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations

Dear Sir/Madam:

This petition is being submitted on my own behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act),

and 14 C.F.R. Part 11.

Aerial Analysis is applying to conduct business as a planned aerial video and photography

company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial

surveying for various industries, hereby applies for an exemption from the Federal Aviation

Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace

regulated by the Federal Aviation Administration (FAA), so long as such operations are

conducted with and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

Regulations from which the exemption is requested:

Enclosed within Uploaded Files

The requested exemption would permit Robert A. Simcox, under the guise of his company, to

pursue his commercial interests in providing services to consumers interested aerial data

capture using a small advanced sUAV in the following areas of aerial data collection (but not

limited to):

Real estate surveying, evaluation, and marketing

Agricultural and geological surveying and research

Wildlife, forestry, and rangeland research and management

I, Robert Simcox, state that all sUAS flights that will occur over private or controlled access

property will do so with the property owner's prior consent and knowledge and that only people

who have consented or otherwise have agreed to be in the area where recording will take place

will be filmed.

Any person who is the acting pilot in command (PIC) will have spent significant time with the

sUAV thoroughly inspecting and flying the unit in a controlled environment. The pilot in

command (PIC) of the unit will also be required to keep a visual line of sight of the unit at all

time by operating from the closest highest point on the landscape. Also, no flights will take place

until the pre-flight checklist has been completed by the PIC.
1. CHARACTERISTICS OF THE AIRCRAFT

Enclosed within uploaded files.

2. APPLICATIONS AND ADDED PUBLIC VALUE OF THE 3DR Solo, 3DR X8+, Tuneec Q500

4K, and Blade 350 QX2

Enclosed within the uploaded files.

OPERATING CONDITIONS

Grant of the exemption to Aerial Analysis for the 3DR Solo, 3DR X8+, Tuneec Q500 4K, and

Blade 350 QX2 who will be subject to the following operating conditions, based on the operating

conditions set forth by the User Manual (see Annex B), and the factors the FAA is to consider

under section 333. The main restrictions are summarized below:

Operations to be conducted over private, controlled-access, or public property where approved;

Permission from the land owner/authority required before commencing any flight;

Operations over congested areas shall be avoided;

Operations must not interfere with manned aircraft operations, must yield the right of way to

manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times;

Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours;

Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored

at all times;

VLOS guaranteed with a GPS geo-fence around operator of 0.5 miles and a flight ceiling preprogrammed at 400 feet AGL;

All operations conducted within 5 miles from an airport shall only be initiated after verbal

coordination with the airport authority, or air traffic control when a control tower is present at the

airport;

All operations shall comply with required permissions and permits established by territorial,

state, county or city jurisdictions; including local law enforcement, fire, or other appropriate

governmental agencies;

The 3Dr Solo, 3DR X8+, Tuneec Q500 4K, and Blade 350 QX2 operations will be compliant

with existing safety procedures inherent to the activities of the related company.

Due to the geographic locations of work type, most surveying will be completed in areas away

from airports and/or highly populated areas.

CONCLUSION

We respectfully request exemption under Section 333 to enable Aerial Analysis to operate

efficient, limited, low-risk commercial sUAV operations for the activities stated, respecting at all

times the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely,

Robert A. Simcox