November 16,2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition of Infinity Technologies, LLC for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 Director : Flight Standards Service: Pursuant to Section 333 of the FAA Moderni zation and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, Infinity Technologies, LLC ("Infinity") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of sma ll unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial photography, videography, inspection ofcrops and imaging for farmers and the agriculture industry. This petition for exemption i s made based on information outlined in this Petition for Exemption , as well as the accompanying Infinity documents; 1. PIC Flight Operations Manual and; 2. Operations Manual s (Collectively 2 and 3 are referred to as "Documents & Manuals") 3. User Guide and; 4. Flight Manual 1 (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Infinity submits these supporting materials as confidential documents purs uant to 14 C.F. R. § 11.35(b) , as the material s contain confidential commercial and/or proprietary information that Infinity has not and will not share with other requesting parties. Additionally, the se documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom of Information Act , 5 U.S.C. 

### § 552 et. seq. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIAL AND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER. For your convenience , thi s Petition is organized as follows:

1 • The term "Manuf actur er' s Manual" also includes all relevant manuf acturer publications, including, but not limited to: operations and fli ght manuals, u ser guides, component maintenance manuals, pilot training manuals , service information letters and , safety/s ervice bulletins.U.S Department ofTransportation November 16,2015 Page2 I. Description of Petitioner II. Description of Proposed Operations A. Aerial Photography, Videography, In spection and Imaging III. Relevant Statutory Authority IV. Infmity's Proposed VAS Operations Meet the Requirements of Section 333 of the Reform Act A. Approval is Warranted Based on the UAS ' s Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals V
. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, Subpart H

- Airworthiness Certificate s and 14 C
. F.R. § 91.203(a)(l) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Catego ry Rotorcraft C. 14 C.F.R. §§ 91.9(c) , 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61 , 14 C.F.R. 

### § 61.3, 14 C.F. R. 

### § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): Civi l Aircraft Airworthiness G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Fl ight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civi l Aircraft Certification and Registration H. 14 C.F.R. 

### § 91.103: Preflight Action I. 14 C.F.R. 

### § 91.109(a): Flight Instruction J. 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes K. 14 C.F.R. 

### § 91
. 121: Altimeter Settings L. 14 C.F.R. § 91.15l(a): Fu e l Requirements for Flight in VFR Co ndition s Vl. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX
. Federal Register Summary X
. Conclusion I. DESCRIPTION OF PETITIONER Infinity i s based in Poseyville, IN working in aerial photography, videography, in spection of crops and imaging for farmers and th e agriculture industry. The Company special izes in , and will continu e to focus on the photography, videography, inspection and imaging The Company'sU.S Department ofTransportation November 16,2015 Page3 Principal and Chief Pilot Carl Seib been flying UAV Quadcopters as a hobby for more than two years without incident, spending hundreds of hours flying
. Upon the grant ofthe 333 Exemption the Co mp any's business will specialize in aerial photography, videography, inspection and imaging
. Infinity's staff are well trained and experienced in providing support as visual observers ("YO") for the pilot in command (" PIC") in addition to any other needed on site assistance
. A ll ofthe equipment owned by Infinity is of the highest quality gear and has been able to provide these services safely and without any claims or incident. Infinity's goal is to advise the perspective client that Infinity is following all the applicable state and federal rules to ensure the safety of the public while providing the client with a competitive and cost effective product. Infinity seeks an exemption to allow for photography, videography, inspection and imaging for farmers and agriculture related bu sinesses. The contact information for Petitioner is as fo ll ows: Carl Seib Infinity Technologies, LLC 57oo High Schoo l Road Poseyville, IN 47633 Phone: 812.457.7140 Email : admin @ infdrones.com II. DESCRIPTI O N OF PROPOSED OPERATION Infinity seeks an exemption pursuant to Section 333 of the Reform Act to operate the 3D Robotics IRIS+ (referred to IT-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on private property or approved location where Infinity has received verifiable permission to operate from the landowner, controller or authori zed representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations of this Petition for Exemption and Infinity's Operations Manuals. As detailed in Infinity's Operations Manuals , all UAS operations wi ll be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator , in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, Infinity's Operations Manual s incorporate redundant safeguards to assure the aircraft does not travel outside the contro ll ed area ofUAS operations, including GPS "geo-fencing" technologies. A. Aerial Photography, Videography and Inspection Infinity seeks to use small IT-UAS for the purpose of conducting aerial photography, videography, inspection and imaging to aid farmers and other related agricultural business in crop management. Infinity has purposefully tailored its operations to meet the requirements estab li shed by th e FAA in prior grants of exemption authorizing commercial use ofUAS in the real estate industry, including:U.S Department ofTransportation November 16,20 15 Page4

• Trudeau, Realtor® (Exemption No. 11138 ) • Alon Sicherman (Exemption No. 11728) • Sokoler Medly (Exemption No. 11341) • Raven Executive (Exemption No. 12639) All UAS aerial photography, videography, inspection and imaging operations will occur on private property or approved location in a controlled area away from s pectators and perso ns not involved in the recording process. In addition , the operation will be conducted between dawn and dusk to ensure maximum safety for the public and those involved in the manipulation and operation of the UAS; VFR conditions, at altitudes below 400' above ground level ("AGL"). As set forth below, Infinity 's operations provide an equivalent level of safety which is superior to performing the same work using conventional fixed-wing aircraft or helicopters. Small UAS video production is also safer than traditional manned aircraft performing the same function. Videographer-inspectors also frequently need to climb rooftops , ladders , trees, or otherwise perform elevated work, which exposes them to the ri sk of dangerou s falls , electrocution or other work related injuries. In addition , depending on the nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with indu s trial s ite s and construction facilities often involve s a risk ofexposure to hazardous conditions. The use of IT -UAS miti gates the se h azards and is ultim ate ly a much safer and cost efficient method of performing these and mo st other types of in spectio ns. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated with vehicles weighing tens of thousand s of pound s (including payload) and carrying large amounts offuel which inherently presents significant fire hazar ds as well as exposure to other chemical contaminates. It is important to note the use of small UAS in thi s area will not only be sa fer and more cost effective to the perspective u ser or purchaser of the service, but the quality and expanse of acquired information will be far more robust given the low cost associated with its acquisition and other potential consumers an inexpens ive product. UAS video production is more reliable , and allows for the collection, dis semination , and storage ofvisual and other sensory data with greater precision and duration at a very low cost. Small UASs will also be capable of accessing and in specting areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other in s pection methods
. 

### III. RELEVANT STATUTORY AUTHORITY This Petition for Exemption is submitted pursuant to Section 333(a) through (c) ofthe FAA Modernization and Reform Act of2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmann ed aircraft system s to operate in the National Airspace Systems ("NAS") where it is safe to do so b ased on the following considerations:

• The UAS's s i ze , weight, speed and operatio nal capability;U.S Department ofTransportation November 16 , 2015 PageS

• Operation of the UAS in close proximity to airports and populated areas ; and • Operation of the UAS within the visual line of sight of the operator. Additionally , the FAA Administrator has general authority to grant exemptions from the agency's safety regulation s and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a) , (b) and §§ 44702

- 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rule s). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. INFINITY'S PROPOSED IT-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT The small IT-UAS operations propo sed by Infinity as noted above in thi s Petition for Exemption qualify for expedited approval pursuant to Section 333 ofthe Reform Act as each of the statutory criteria and relevant factors are satisfied. A. Approval is Warranted Based on the 

### VAS's Size, Weight, Speed, and Operational Capability A Grant of Exemption is appropriate for operations conducted usi ng the UASs due to their size weight, speed, and operational capability.

• The IT-UAS utilized by Infinity has been approved for u se in prior Section 333 Grants of Exemption from the FAA. 2

• The IT-UAS weighs le ss than 55 pounds, including payload

• The IT-UAS will not be flown at a ground speed in excess of 50 knots. The exemption holder may u se either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction.

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof
. This information will be tran s mitted to the pilot via telemetric data feed.

• The IT-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. If connection to the remote

2 See e.g., Grant of Exemptio n to Trudeau , Realtor® ( Exemption No. 111 38) ; Grant of Exemption to A Ion Sic herrnan (Exemptio n No. 11 728) ; Grant of Exemption t o Soko l er Medly (Exe mption No. 11 341 ).U
. S Department of Transportation November 16, 2015 Page6 control or ground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control of the IT-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the IT-UAS is 2.4 GHz frequency bands. If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed 6,000 pounds depending on payload. The difference in weight between the IT-UAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or incident. In addition , the risk to the onboard pilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in Infmity's Operations Manuals Infinity's Operations Manuals and the Manufacturer's Manual for the selected IT-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption
. To assist the FAA in making a safety assessment of Infinity ' s proposed operations , below is a summary of operational limitations and conditions that Infinity will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines: 1. The IT-UAS weighs less than 55 pounds, with payload. 2. All operations shall be conducted over private or controlled-access property with verifiable permission from the land owner /controller or authorized representative. Permission from land owner /controller or authorized representative will be obtained for each scheduled flight prior to operation. 3. All UASs operated under the Grant of Exemption will be identified by serial number, registered in accordance with 14 CFR part 47 , and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 4
. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in Command ("PIC") of the IT-UAS , and one or more Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a 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 Columbia, Puerto Rico , a territory , a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate
.U.S Department ofTransportation November 16,2015 Page7 6. The IT-UAS shall be operated within VLOS of the PIC and Observer at all times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8
. Electronic messaging or texting will not be permitted during flight operations. 9. The additional requirements identified in the Grant of Exemption shall be added to the Infinity's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and Infinity 's Operations Manuals , the conditions and limitations in the Grant of Exemption shall take precedence and must be followed. Otherwise , Infinity shall follow the procedures outlined in their Operations Manuals. 10. Infinity may update or revise its Operations Manuals. Revisions will be tracked and a revised copy of the Manual will be provided to the Administrator upon request. Infinity will al so present an updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption. If an update or revision would affect the basis upon which the FAA grants the exemption, Infinity will seek an amendment to its Grant of Exemption. Infinity will contact the FAA' s UAS Integration Office (AFS -8 0) if questions arise regarding updates or revisions to the operating documents. 11. Infinity Operations Manuals and its Grant of Exemption will be available to the PIC at the ground control station anytime the IT-UAS is operating. 12. The PIC is prohibited from beginning a IT

- UAS flight unless (considering wind and forecast weather conditions) there i s enough power to fly to the first intended point of landing, and assuming normal cruising speed , to fly after that for at least 10 minutes. 13. Maximum total flight time for each operational flight using the IT-UAS will be limited to 40 minutes or the amount of time the UAS can be flown and s till maintain a reserve battery power of no less than 25% , whichever occurs firs t. 14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL , the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons . (persons other than the PIC , VO , operator trainees or essential persons) , vessels , vehicles , and structures unless:U.S Department ofTransportation November 16 , 2015 Page 8

a. Barriers or structures are present that s ufficiently protect nonparticipating persons from the UA and / or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection
. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner /controller of such vessels, vehicles or structures has granted permission and the PIC h as made a safety assessment ofthe ri sk of operating closer to those objects and determined that it does not present an undue hazard , and;

c. Operations nearer to the PIC, YO, operator trainees or essential persons do not present an undue hazard to those perso ns per§ 91.119(a). 16. The IT-UAS may not be operated less than 500 feet below or less than 2 ,000 feet hori zo ntally from a cloud or when visibility is less than 3 statute miles from the PIC. 17. The IT-UAS may not operate within 5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Infinity Technologies , LLC COA. The letter of agreement with the airport management will be made available to the Administrator upon request. 18. Prior to each flight the PIC shall inspect the IT-UAS to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components , items , or equipment, not already covered in the relevant sections of the operating documents as well as equipment updates
. The PIC shall not operate any IT-UAS if the inspection reveals a condition that affects the safe operation of the IT- UAS until the necessary maintenance has been performed and the IT-UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflight inspection. All maintenance and alternations must be properly documented in the UAS's records as required by Infinity's Operations Manuals. 19
. Infinity will timely carry out its maintenance , inspections, and record keeping requirements in accordance with the Operations Manuals
. Maintenance, inspection , and alterations will be fully noted in the IT-UAS records , including total time in service, description of work accomplished, date completed and the signature of the authorized person returning the IT-UAS to service. 20
. Any IT-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement of a flight critical component) must timely undergo a functional test flight in accordance with Infinity's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and IT-UAS record entry shall be included in the Infinity's Operations Manuals.U.S Department ofTransportation November 16, 2015 Page9 21. The IT-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety / Service Bulletins and product updates. 22. Prior to the operation , a Mission Packet will be created in accordance with the requirements on Infinity's Operations Manuals. 23. Infinity will obtain an Air Traffic Organization ( "ATO" ) issued Certificate of Waiver or Authorization , otherwise known as a COA, prior to conducting any operations under this Grant of Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements
. 24
. All required permissions and permits will be obtained from territorial , state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. If the IT-UAS loses communication with the PIC, it will have the capabi lity to safely return to a pre-determined location within the operational area and land safely. 26
. Contingency plans wi ll be in place to safely terminate flight ifthere is a loss of communication between the PIC and the Observer. 27. The IT-UAS will have the capability to safely abort flight in the case ofunpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificat e or a valid and current state driver's license issued within the United States
. 29. Prior to conducting operations for filming , the PIC will have accumulated and logged , in a manner consistent with 14 CFR § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pi lot and at l east 10 hours logged as a UAS pilot with a simi l ar IT-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming , the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.5l(b), a minimum ofhours pursuant to 54 CFR § 61.5l(b) as UAS pilot operating the make and model ofiT-UAS to b e utili z ed for operations under the exemption and three take-offs and three landing in the preceding 90 days. 31. Operations shall occur during daytime VFR Meteorological Conditions ; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The IT-UAS shall remain clear and yield the right of way to all other manned operations and activities at all times (including , but not limited to, ultralight vehicles , parachute activities , parasailing activities , hang gliders , etc
. )
.U.S Department ofTransportation November 16 , 20 15 Page 10 33. IT-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited. 34. The UAS wi ll not be operated from an elevated platform unless designed and engineered specifically for s uch purposes and be in compliance with the general restrictions imposed by the applicabl e regu l ations. Additionally no PIC will provide any film-flight operations wh ile in motion from atop any elevated platform vehicle or device. 35
. Before conducting operations, the radio frequency spectrum used for operation and control of the IT-UAS will comp ly with the Federal Communications Commiss ion (FCC) or ot h er appropriate government oversight agency requirements. V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal Aviation Act express ly grants the FAA the authority to issue exemptions. This statutory auth ority, by its terms , includes exempting civi l aircraft, as the term is defined under § 40101 ofthe Act , including UASs , from its safety regulations and minimum standards when the Admini strator decides a requested exemption is in the public intere st. 3 Infinity seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code of Federal Regulations ("14 C.F.R") Parts 21 , 45, 61 and 91 for purposes of conducting the requested operations using IT-UAS platforms noted above. Listed below are : (1) the specific sections of 14 C.F.R for which exempti on is sought, and (2) the operating procedures and safeguards that Petition er has estab li shed which wi ll ens ure a l eve l of safety better than or equal to the ru les from wh i ch exemption is sought. 4 UNMANNED AIRCRAFT SYSTEM A. I4 C.F.R. Part 21, Subpart H -Airworthiness Certificates and 14 C
.F.R. §9 1 .203(a)(1) The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS se lected provides an equivalent leve l of safety when compared to aircraft normally used for the same application. These criteria are met and in point of fact exceeded , and therefore no exemption is needed
. 5 If, however, the FAA determines that there are some characteristics of the chosen UAS that fai l to meet the requirements of the Reform Act , an exemption is requested.

3 49 U.S.C. § 4470 I (f) (authorizing the grant of exemptions from requirement s of regulations prescribed pursuant to Sections 4470 I (a) and (b) and Sections 44702- 44716). 4 14 C
. F.R § 11 .81 (e), which requires a petition for exemption to include: The reaso ns why granting the exemption wou ld not a dv ersely affect safety, or how the exempt ion would provide a level of s afety at le ast equa l to that provided by the rul e from w hich yo u seek exempt ion.
5 See Grant of Exemption No. 1106 2 to Astraeus Aerial (FAA-20 14-0352 at pgs. 13-14 , 22).U
. S Department ofTransportation November 16 , 2015 Page 11 

### Equivalent Level of Safety Infinity 's u se of the IT

- UAS i s safe when taking into account its size, weight, s p eed , and operational capability. As set forth in the de scription ofpropo sed operations in Section IV(A) , the IT-UAS weighs less than 55 pounds, including payload and will not be flo w n at a ground s peed in excess of 50 knots. The IT-UAS is also equipped with safety features which will allow Petitioner to operate the IT-UAS safely after experiencing certain in-flight contingencies or failure s as noted below. 6 7 Additi onally, the IT-UAS carries neither pilots nor passengers, carr ie s no explosive material s or flammable liquid fuel s, or ot h er elements id en tified by Homeland Security as bein g prohibiti ve and operate excl u s ively within the p arameters stated in Infinity's Operations Manual s. Operations conducted under this exemption will be clo sely controlled and monitored by the PIC operator a nd will be conducted in compliance with local public safety requirements, to provide security for the area of operation. Infini ty will a lso provide the FAA with advance notice of a ll operations via NOTAMs as required b y th e applic able COA. In all cases , operation of the ITUAS under the proposed conditions will be at leas t as safe as, or safer than , conventional ro torcraft operating with an airworthiness certificate
. Lastly, the IT-UASs do not need a me a ns t o communicate with other aircraft or ATC, because tho se capabilities will b e so lel y p ossessed b y the PIC and Observer, who are not onbo ard the IT-UAS. 8 In addition, no se nse- and- avoi d technolo gy is neces sary for the IT -UASs bec ause they will be operated at all times in YFR co nditi o n s and within VLOS of the PI C and Operator. 9

6 See e . g. , Grant of Exe mp tio n No. 111 84 to Low Co untry RC , Corp. (FAA-20 14-0803 at pg. 3): "The [DJI S JOOO] ha s the capab ilit y to opera te safely after experiencing ce rtain in

-flight cont ingencies o r failures and uses an autopilot sys t e m to mainta in UAS stabil ity and contro l. The UAS is a lso able to res po nd to a los s of globa l pos itioning sys tem (G P S) or a lost
- link eve nt w ith a pre-coo rdin at e d , pr edic table , automated fli g ht maneuver, and manual fli ght co ntrol fun c tionality as a bac kup . T hese sa f ety features prov ide an eq ui valent level of safety compar e d to a m a nne d air

c raft pe rforming a similar operat io n ."
7 See e.g. , G rant of Exemp tio n No. 111 84 to VDOS G loba l, LLC. (FAA-2014

-0382 at pgs. 4-5): "T he IT -UAS can b e ope rated e ntire ly by a touch- screen , map-based interface
. T hj s means the operator o nly need s to co mmand the sys t em where to go, and the system does all th e flying for the operato r. The IT- UAS can be o pe rated in both semi and fully auto no m o u s flight modes, with the operator s imply c lic king o n a map to crea t e a pre- pl a nn ed fli ght path for a fli ght. In addition , the op erator can creat e no fl y zo ne s or m ax imum fli ght range s and a ltitudes so the system canno t e nte r areas d eemed uns a f e or unnecessary to fly over. The petitioner states furth er t ha t th e UAS ha s built-in int ell igent fault handl i n g which all ows th e IT

- UAS to detect a sys tem fault while in the a ir a nd automaticall y fl y b ack to its takeoff lo cati o n and land
. Faults that can be detec t ed include: l oss of communi cation ; exceeding pre-set w ind thresho l ds; and low battery leve ls." A ll flight operati ons are g l obal po si tioning system (GPS) controlle d , mak ing the system easy to navigate. At any po int if the op erator is not explici tl y co mmanding the syste m to mo ve, the sys t e m automatically ho ld s its GPS posi tion. The fli g ht control syste m e mpl oys no t on ly GPS po s itioning but a va riety of se nsors inc l ud i ng so nar, barome tri c pr ess ure, t emp erature, wind s peed and o ther s to ens ur e s tability so long as w ind thres ho l ds are not exceeded
. A lso a fli g ht termin atio n link

- to prevent a 'fl y away' or oth er potentially da ngero u s s ituat i o n - is avai lab le t o the operato r."
8 See Grant of Exe mptio n No. II 062 t o Astraeu s Ae rial (FAA-20 14-0 3 52 at pg . 1 3).
9

. IdU.S Department ofTransportati on November 16 , 2015 Page 12 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R
. Part 27 sets forth the procedural requirements for airworthiness certification of n ormal category rotorcraft
. To the extent that Infinity ' s small IT-UAS wou ld otherwise require certification under Part 27 , Petitioner seek s an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. R. Part 21 , Subpart H , 

### supra. C. 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Infinity seeks an e xemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45 .23(b ) and 45 .27( a).

• 14 C.F.R. § 91.9(c) , Civil Aircraft Flight Manual , Marking and Placard requirements , prov ides that: No person may operate a U
. S.-registered civi l aircraft unless that aircraft i s identified in accordance with Part 45 of this chapter.

• 14 C .F.R
. § 45 .23 (b) , Markings ofthe Aircraft, state s : When marks include only the Roman capital letter "N" and the registration number i s displayed on limited, restricted or light- s port category aircraft or experim e ntal or provisiona lly certificated aircraft , the operator must also display on that aircraft near each entrance to the cabin , cockpit, or pilot station , in l etters not less than 2 inches nor more than 6 inche s high , the words "limited " "restricted" " light- s port "experimental "or 

### ' ' ' ' "provisional," as applicable.

• 14 C.F.R. § 45.27(a) , Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft hori z ontally on both surfaces ofthe cabin , fuselage , boom , or tail the marks required by § 45. 23
. In a previous Grant of Exemption, the FAA determined that exemptio n from th ese requirements wa s warranted provided that the aircraft "have identification (N-N umb er) markings in accordance with 14 C.F.R Part 45 , Subpart C if the markings are as large as practicable
. " 1 0 

### Equivalent Level of Safety All IT-UAS flown by Infinity will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45 , Subpart C. 11

10 FAA Do cket No. FAA

- 20 14-03 5 2
. II See , e . g . , FAA D ocket No
. FAA

- 2014 -035 2 , at 14
.U.S Department ofTransportation Novemb er 16 , 2015 Page 13 D
. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections Infinity seeks an exemption from the maintenance in spection requirements contained in 14 C
.P. R. § 9 1.405 (a), 91.407(a)(1 ) , 91.409(a)(2) ; 9 1.417(a) and (b)
. The se regulations s pec ify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g . , 14 C
. F. R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft in s pected as pre scri b ed in subpart E of this part and shall between required in spection s ...h ave discrepancies repaired as prescribed in part 43 of thi s chapter"). An exemption/rom th ese r egu la tions is needed b ecause Part 43 and these sections only apply t o air cr

aft with an airworthiness

**cert~ficate ,**  which the VASplatforms to be ope rated und e r this grant of exemption will not have. (Emph asis added) Equivalent Level of Saf e ty An equi valent l evel of safety will b e achi eved or exceeded becau se maintenance and inspections will be timel y performed in accordance with the Manufacturer's Manual and any required manufac turer S afety or Service Bulletin s. Further , as req uired b y Infinity's Operations Manuals , the PIC will c o nduct a pre-flight inspection ofthe IT-UAS and all assoc iated equipment to account for all di screpancie s and / or inoperable components. Maintenance w ill be performed and verified to address any conditions potentially affecting safe operation of the IT- UASs and no fli g hts will occur unless , and until , a ll fli ght critical components of the IT- UAS have been found to be airworthy and in a condition safe for operation. A functional test fl ig ht w ill b e conducted following the replacement of any flight- critic al components. As requi red by Infinity's Operations Manuals , the PIC who conduct s the functional te st fli ght will make an entry in the I T-UAS aircraft reco rd s of the flight. Infinit y's Operations Manual a lso incl udes requirements to foll ow the manufacturer's UAS aircraft/component, maintenance , over haul , replacement, in s pection, and life limit requirements for the following applicable components: powertrain system (powerp lant), propellers , av ionics and co ntro l surfaces ( including ai leron s/elevons) , structure s & airframe, camera system , e lectrical system s (including batteries) , ground control sta ti o n , h azard accesso ri es, and s pare parts. F urth er, Infinity 's Operations Manuals a lso include procedures to document and maintain a record ofthe IT-UAS 's m aintenance, preventative maintenance , alterations , s tatu s of rep lacement /overhaul component parts, and th e tota l tim e in service of the IT-UAS used und er thi s Grant of Exempti on. As a whole, the maintenance a nd in sp ection procedures required in Infinity's Operations Manuals ens ure that an equi vale nt or hi gher l evel of safety will be achieved. PILOT-IN-COMMAND OF THE UAS E
. 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations Infinity seeks exemption from 14 CFR § 6 1.1 13, wh ich re stricts private pilot certificate ho lders from fl yi ng aircraft for compensation or hire, and wou ld also require a second cla ss medical certific ate. The purpose ofPart 6 1 is to ensure that the sk ill and comp etency of any PIC matches th e airspace in which the PIC w ill be operatin g, as well as requiring certi ficati o ns if the private pilot is carryi ng passenger s or ca rgo for hire. In t hi s case, while the IT -UAS will be operated as part of a commercial operation, they carry neither passengers nor cargo. ln the Grant of Exemp ti o n to Astraeus Aerial , the FAA determ ined that the unique characteristics ofUASU.S Department ofTransportation November 16,2015 Page 14 operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 1 2 The fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. 

### Equivalent Level of Safety The restrictions Infinity has placed on its IT-UAS operations meet or exceed the restrictions simil arly imposed on Astraeus Aerial. Infinity will operate on private property away from persons and property not involved in the operation. Infinity will also obtain an ATO issued COA prior to conducting any operations under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A NOTAM will also be issued as required by the applicable COA. In addition to these flight restrictions, Infinity will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of IT-UAS flight. As set forth in the Operations Manuals , pilots will have experience not only in IT-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf ofInfinity. The pilot qualification , training , and currency requirements in the Operations Manuals ensure that Infinity pilots are competent and proficient in the IT-UAS they are operating. Infinity's training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption , and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level of safety to the public
. OPERATING PARAMETERS OF THE UAS F
. 14 C
. F.R. 

### § 91.7(a): Civil Aircraft Airworthiness Inasmuch as there will be no airworthiness certificate issued for the UASs, Infinity seeks an exemption from 14 C
. F.R
. § 91.7(a) , which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C
.F.R. § 91.7(a) to the extent that the requirements ofPart 21 are waived or found inapplicable. 1 3 Accordingly, Petitioner requests that the requirements for§ 91
.7(a) be treated in accordance with Section V(A) , supra .

1 2
1 3 G. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Exemption No. 11062 (FAA Docket No. FAA- 2014-035 2 )
. See Id. at 13-14 , 2 2.U.S Department ofTransportation November 16 ,20 15 Page 15 Title 14 C.F.R
. § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R
. § 9 1. 9(b) (2): (b) No person may operate a U.S.-registered civil aircraft

- (2) For which an Airp lane or Rotorcraft Fli ght Manual is required by § 21.5 of this chapter, unless there is availabl e in the aircraft a current approved A irpl ane or Rotorcraft Flight Manual, approved manual material , markings , and placards , or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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 this section or a special flight authorization i ss ued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Given the small size and configuration of the IT-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the IT-UAS because there is simp ly no room and the IT-UAS has no cabin or cockpit. As a way to comply with the code Infinity will maintain the documents with the PIC and make them available for inspection
. 

### Equivalent Level of Safety In an FAA Office of ChiefCounsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight manual , registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. 14 As this FAA Office of Chief Counse l Opinion clarifies , the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS
. 

### H. 14 C.F.R. § 91.103: Preflight Action Infinity seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft
. While the PIC will be familiar with all information necessary to safely conduct the flight , an exemption is requested to the extent that an FAAapproved Flight Manua l is required.

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation , to John Duncan, FAA Flight Standards Service (Aug. 8 , 20 14) ; see also Docket No. FAA-2014-0352 at 16-18.U.S Department ofTransportation November 16 , 2015 Page 16 

### Equivalent Level of Safety An equivalent level of safety will be provided by following the Infinity's Operations Manuals and the Manufacturer's Manual. The PI C will perform a series ofchecklists designed to identif y any defects or inoperab le component s in accordance with the Infinity ' s Operations Manuals, including checklists covering Pre-Flight , Launch, Landing, and Post-Flight procedure s. The PIC will a lso be required to review weather, flight requirements , battery charge, l anding and takeoff di s tance , UA performance data, and contingency landing areas- before initiation offlight. Infinity 's Operations Manual s and the Manufac turer' s Manual will b e kept at the ground control station and will be accessible to the PIC at all times while operating the UAS
. I. 14 C
. F.R
. 

### § 91.109(a) : Flight Instruction Infinity seek s an exemption from 14 C.F. R. § 9 1.1 09(a) , which provide s in pertinent part that "[n] o p erso n may operate a civil aircraft (except a manned free balloon) that is being u sed for flight in s truction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft , by their des ign , do not h ave func tional dual controls
. In stead , fli ght control is accompli shed through th e u se of a device that communicates with the aircraft v ia radio communications
. Accordingly, an exemption will be required for the flight in s truction requirements of 14 C.F.R. 

### § 91.109(a). 

### Equivalent Level of Saf e ty Given the size and speed of the UASs t hat Infi nity intends to u se, an equivalent level of safe training can still be performed without dual controls bec au se no pilot or passengers are aboard th e UAS, and as required by the Infinity's Operations Manuals , all persons will be a safe distance away in th e event that th e UAS experiences any difficulti es during fli ght in struction . Moreover, as required b y the Infinity's Operation s Manuals , a ll flight training will be conducted in controlled and sterile environment. As a whole , the safety procedure s provided for in Infinity's Operations Manu a ls ensure that the proposed UAS o peration s provide an equiv a lent or higher level of safety than that provided by the flight in s truction regulation s . J. 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes Infinity requests an exemption from the minimum safe altitude requiremen ts of I4 C
. F
. R. § 91.119(c). 1 5 Section 91.119 pre scrib es the minimum safe altitudes und er which aircraft may not operate , including 500 feet ab ove the s urf ace and away from any person, vesse l, vehicle, or str uc ture in non-congested areas. See 14 C.F.R. § 91.119(c). Sectio n 9 1.11 9(d) all ows for a heli copter to operate at l ess than those minimum altitude s when it can be operated "witho ut h azard to persons or property on the s urface , " provided that "each person operati ng the helicopter co mpli es with any routes or altitudes specifically prescri bed for helicopters by the FAA."

1 5 Re lief from § 9 1
. 11 9(a) w ill not be necessary because Pe titi oner w ill be able to perform an e mer ge ncy land ing without undu e hazard to persons o r property o n the gr o und in the event of a failure
. Peti ti o ne r's propo sed UAS operati o ns wi ll not occur o ver cong es t e d areas , and the refore an exempti o n from § 9 1.11 9(b) will not b e nece ssary. See e.g. , Gran t of Exemption No. 111 57 to S lugwear, Inc ., dba Like on a tree Aeria l (FAA

- 20 14 -053 4 at 1 5).U.S Department ofTransportation November 16, 2015 Page 17 An exemption is required becau se the propo sed IT-UAS operation will normally need to occur below 400 feet AGL. In circumstances where the IT-UAS is used to inspect a structure whose height exceeds 400 feet AGL , the IT-UAS will not be operated more than I 00 feet above the highest point on the structure, and within 50 feet hori zontally of the st ructure. Additionally, due the nature ofthe proposed operations, the Pilot and / or Observers(s) may need to be less than 500 feet away from the IT-UAS
. 

### Equivalent Level of Safety Compared to flight operations with rotorcraft weighing far more than the maximum weights propo sed herein, and given the lack of flammable fuel with the above noted UASs, any risk associated with these operations is far less than tho se which presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the IT-UAS s, as well as the controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or when inspecting aU .S. structure whose height exceeds 400 feet AGL , within I 00 feet above the highest point on that structure and 50 feet hori zontally of the structure. As set forth in the Operations Manuals, the IT-UAS will be operated in a re s tricted area, and all flights will be operated at a lateral distance of at leas t 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the IT-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet of the IT-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unle ss the property owner /controller timely has granted permission and the PIC has mad e a safety assessment of the risk of operating closer to those objects and , operations near the PIC or Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in Infinit y's Operations Manuals will ensure operations can be conducted without compromising public safety. 16 K. 14 C.F.R. 

### § 91.121: Altimeter Settings Infinity seeks an exemption from 14 C.F.R. 

### § 91.121, which require s a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

1 6 See e.g., Grant of Exemption No
. 111 38 to Doug las Trudeau (FAA-2014-0481 at 19) : "If barriers or s tru cture s are present that can suffi ciently protect nonparticipating persons from the UA or debri s in the event of an accident , then the UA may operate c lo ser than 500 fe e t to person s afforded such protection. The operator mus t also ensure that nonparti c ip at ing persons remain und er s uch protecti on. If a s ituation arises where nonparticipating p e r so ns leave s uch protection and are within 500 feet of the UA , flight operations must cease immediat e ly. When considering how to immedi ate ly cease operations, the primary concern is the s afety of those nonparticipating perso ns . In addition, the FAA fmd s th at operati o ns may be conducted c loser than 500 feet to vessels , vehicles and st ru ctures when the owne r /controlle r of any s uch vessels , vehicles o r structures g rants permission for the operati on a nd the PIC make s a safety assessment of the ri sk ofoperating closer t o those objects and determines th at it does not pre sent an undu e hazard."U.S Department of Transportation November 16,2015 Page 18 

### Equivalent Level of Safety The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §9 1.121 can be achieved in circumstances where: (1) the UAS s will be operated below 400 feet AGL or below 17
, (2) within VLOS , (3) where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display and , (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS. 1 8 The IT-UAS that Infinity intends to u se for the proposed operations will meet all the se operational characteristics. Moreover, as required by Infinity's Operations Manuals , the PIC will be required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption, the IT-UAS Infinity intend s to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level of safety or greater level will be achieved, and a Grant of Exemption to the requirements of§ 191. 121 is therefore appropriate. L. 14 C.F.R
. 

### § 91.15l(a): Fuel Requirements for Flight in VFR Conditions Infinity requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in VFR conditions. Section 91.151 s tates: (a) No person may begin a flight in an airplane under VFR conditions unles s (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 leas t 30 minutes; or (2) At night, to fly after that for at lea st 45 minute s. Here , the technological limitations on UAS battery power mean s that no meaningful flight operations can be conducted while still maintaining a 30-minute battery re serve. An exemption from th e fuel requirements of 14 C.F.R. § 91.151 (a) is therefore required
. Moreover , it is not Infinity' s intention to fly the IT-UASs at night. 

### Equivalent Level of Safety In the Grant ofExemption to VDOS (Exemption No. 11112) , the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a IT-UAS flight unless (considering wind and forecast weather conditions) there was enough power to fly to the first intended point oflanding and, assuming normal cruising speed, to fl y after that for at least 10 minutes. In reaching this conclusion , the FAA considered that th e UAS batteries for the IT-UAS provide approximately 50
1 7 If the heig ht of the s tructure being inspected exceeds 400 feetAGL , th e UAS will not be operated more than 100 feet above the hi ghes t point on the s tructure. 1 8 See Grant of Exemption No
. 110 62 to Astraeu s Aerial (FAA-2014-0352 at 2 1).U.S Department of Transportation November 16 , 2015 Page 19 minutes of powered flight (with payload) and provided battery level and battery time remaining in minutes and seconds to the PIC. 1 9 The FAA also considered the fact the IT-UAS operating manual states: " start every flight with a fully charged battery in the aerial vehicle" , and that in the event that the IT-UAS should run low on power , the PIC will be alerted and can safely land the- IT-UAS as soon as possible. Like the VDOS Grant of Exemption, Infinity ' s use of the ITUAS , combined with the requirements of Petitioner's Operations Manuals , ensure that an equivalent level of safety can be achieved and in fact exceeded. Similarly , in the Grant of Exemption to Alan Purwin (Exemption No. 11161 ), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a flight with the UA unless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point and land the UA with 25 % battery power remaining. Infinity will adhere to this limitation for its IT-UAS flights. The IT-UAS includes a low battery warning system and the amount ofbattery re s erve power remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from the IT-UAS to a ground-based-on-screen display. 20 As required by Infinity ' s Operations Manual s , the PIC will promptly fly the IT-UAS back to the home launch location or predetermined abort location where it may safely land , while still maintaining a minimum of25% reserve battery power. Infinity submits that the procedures requiring flights to be safely terminated once the batteries fall below 25 % capacity , combined with the requirement that flights only be conducted within a secure , isolated area, using a UAS weighing less than 55 pounds , and within VLOS of the PIC and Observer(s ) , ensure that the proposed operation will provide an equivalent or higher level of safety to the public to that provid ed by the regulations from which exemption is sought. VI. DRUGANDALCOHOLPROGRAM Infinity will have policies in place to ensure that no person may participate in IT- UASs flight operations if they are under the influence of alcohol or any drug . VII. PUBLIC INTEREST The public interest will be served by granting Infinity's Petition for Exemption. Congres s has established a national policy that favor s early integration ofUAS into the NAS in controlled , safe working environments such as tho s e propo s ed in thi s Petition. Granting this Petition for Exemption help s fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act

- the FAA Administrator's as s essment ofwhether certain UAS may operate safel y in the NAS before completion ofthe s tatutorily required rulemaking.

1 9

. G rant of Exe mpti o n No. 1111 2 t o VD O S Gl ob al, LLC (FAA

- 20 14-03 82 at 10)
. 20

. The IT

- UAS ground co ntrol s tatio n di spl ays , the UASs po s ition , nav ig ati o n route , tail numb er, altitude, heading , north seeking arro w, rang e t o t a rgets , ca l c ul at ed tar g et pos iti o n , dat e/tim e , and se nsor he ading and ori entation re lati ve to the UAS.U
. S Department ofTransportation November 16 ,20 15 Page 20 The proposed IT-UAS operations in this Petition for Exemption significantly improves the safety and reduces risk of harm , physical injury and property damage to the public at large , the property owners from whom permis s ion was granted for use by Petitioner and abutting properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all tho se who may be in the local vicinity. Traditional methods of inspecting and monitoring potential locations and relevant sites and facilities requires location personnel to climb towers , trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk of serious physica l injury from dangerous falls or other physical mishaps. Moreover , inspectors/ surveyors are often unnec essari ly exposed to hazardous conditions, unsafe environments, culturally tense situations and other hazard s associated with identifying specific locat ions for potential recording sites to be used in the end product. The use of small UASs can eliminate thes e haza rds and ultimately create a much safer method of performing these types of inspections creating a safer environment for the public as well as Infinity employees
. The u se of small UAS also enhances safety and reduces risk to the surrounding public because , unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel , the UAS carry no passengers , crew or explosive fuel. Furthermore, in the unlikely event of an accident, Infinity's small battery powered IT-UAS presents sign ificantly less danger to persons on the ground when compared to operations by conventional manned aircraft. 2 1 As Petitioner's IT-UAS are battery powered , the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality will naturally be improved with the reduction of fuel powered vehicles. Lastly, as recogni zed by the FAA in prior Section 333 Grants of Exemption to filmmakers , UASs provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft. 22 The quality of the finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility ofproduction; therefore , given the lower cost, owner /operators and others in the relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC 's
. VIII. PRIVACY

2 1 See Grant of Exemption No. 11158 to Team 5 , LLC (FAA-2014-0783 at 12) : "Manned he licopters conducting aerial filming can weigh 6,000 pounds or m ore and are operated by an o nb oard pilot, in addition to other o nb oard crewme mb ers, as necessary. The petitioner's UAS will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotel y located from the aircraft. The limited weight sig nificantl y reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. Risk to an onboard pilot and crew during an incident or accident is e liminated with the use of a UA for the aerial filming operati o n . " 22 See e.g., Grant of Exemption No. 111 78 to Picture Fac tory, Inc
. (FAA

- 20 14-0794 at 1 8).U.S Department ofTransportation November 16,2015 Page 21 All IT-UAS operations will be conducted in accordance with applicable federal , state, and local laws regarding privacy. All operations shall be conducted over private or controlled

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

### IX
. FEDERAL REGISTER SUMMARY 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: Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: Part 21, Subpart H; Part 27; 45.23(b) ; 45.27(a) ; 61.113 ; 91.7(a) ; 91.9(b)(2); 91.9(c); 91.103 ; 91.109(a); 91.119(c); 91.121; 91.151(a) ; 91.203 (a) & (b) ; 91.405(a); 91.407(a)(l) ; 91.409(a)(l) & (2) ; 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods. X . CONCLUSION Infinity's Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 which includes weight; speed; operating capabilities ; proximity to airports and populated areas ; operation within VLOS and national security
. The proposed IT-UAS operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. In consideration of the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting the requested exemptions allowing Infinity to use small IT-UAS sin the recorded production of its product. We thank you for your prompt consideration of our requested exemptions
. Respectfully Submitted ,

# CAV~ Carl Seib Infinity Technologies, LLC 57oo High School Road Poseyville , IN 47633 Phone: 812.457.7140 Email : admin @ infdrones
. comU
. S Department ofTransportation November 16 , 2015 Page 22 (The following attached items contain proprietary and commercial information exempt from disclosure under the Freedom of Information Act, 5 U
. S.C
. 

### § 522 et seq. , and should be held in a separate file pursuant to 1 4 C.F.R. § 11.35(b)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8
. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals