Robert A. Simcox

22560 US Highway 64 Somerville, TN 38068 901

-517

-8348 29 December 2015 U.S. Department ofTransportation, Docket Management System 1200 New JerseyAve SE Washington, DC 20590 Filed with www.regulations.gov Subject: Petition for Exemption Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir/Madam: This petition is being submitted on my own behalfwithout legal counsel or consulting services. Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (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 forvarious 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 underthe 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 RobertA. Simcox, underthe 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 thatwill occur over private or controlled access propertywill do so with the property owner's prior consent and knowledge and that only people who have consented orotherwise 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) ofthe unit will also be required to keep a visual line ofsight ofthe 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 ofthe exemption to Aerial Analysis forthe 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 setforth 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 propertywhere approved; Permission from the land owner/authority required before commencing anyflight; Operations over congested areas shall be avoided; Operations must not interfere with manned aircraft operations, must yield the right ofway 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 feetAGL; All operations conducted within 5 miles from an airport shall only be initiated afterverbal coordination with the airport authority, or airtraffic 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 cityjurisdictions; including local law enforcement, fire, orother appropriate governmental agencies; The 3Dr Solo, 3DRX8+, Tuneec Q500 4K, and Blade 350 QX2 operations will be compliant with existing safety procedures inherent to the activities ofthe related company. Due to the geographic locations ofwork 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 forthe activities stated, respecting at all times the space and privacy of citizens and propertywhilst keeping our skies safe. Sincerely, Robert A. Simcox