April 28, 2015
Mr. James Williams Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office Federal AviationAdministration 800 Independence Avenue, SW Washington, DC 20591
U.S. DepartmentofTransportation, Docket Operation West Building GroundFloor, Room w12-140 1200NewJersey Avenue, SE Washington, DC 20590 

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Re: Request for exemption from multiple regulatory provisions to allowthe use ofsmall unmanned aerial systems on land controlled by clients of[WELLS FARGO] to assist in the safe evaluation ofagricultural operations and crop damage for our clients.
DearMr. Williams: [WELLS FARGO] respectfully requests an exemption from several provisions ofTitle 14 ofthe Code ofFederal Regulations (C.F.R.) to permitthe use ofsmall-unmanned aerial systems (sUAS) to assist inthe evaluationofagricultural operations,infrastructure andcrop damage for ourclients. · This request is motivated primarily by the desire to maximize safety in infrastructure and operations. While an exemption would not eliminate the current need for in-person visual inspectionrequiredby variousfederal regulatory departments, itwould allow [WELLS FARGO] to broadly evaluate assets and operations with sUAS, resulting in a safer and more efficient infrastructure network. Accordingly, the grantofan exemption is consistent with Congress' intent, reflected in Section 333 oftheFAAModernization and Reform Act of2012 (ModernizationAct), 1that safe systems be permitted in the national airspace priorto the issuance offinal regulations governing general use ofthese systems.2 A summaryofthis request suitable for publication inthe Federal Registeris provided as Appendix A.
Mark S. McAdam Vice President, Wholesale Innovation, Research and Development Wells Fargo & Company 7679 Archer Lane N. Maple Grove, MN 55311 Office: 612 2416 fargo.com

2Section 333(b) (2) specifically contemplates that the FAA may issue a certificate ofwaiver upon a finding that atype ofUAS, as a result ofits size, weight, speed, operational capacity, proximity to airports and populated areas, and operations within visual line ofsight do not create a hazard to users ofthe NAS orthe public orpose a threat to national security

### Background Information [WELLS FARGO] is in the business ofassessing risk relative to the lands and infrastructures present on farm and ranch businesses operated by our clients. We have Clients looking to us to assess damage incurred onthe farm and ranch properties: damages that can be most safely and thoroughly assessed through the operation ofsUAS for Infrastructure Safety, Agricultural & 

### Maintenance Inspections. As such, [WELLS FARGO] Clients look to us for Safe Operations of sUAS. We have developed specific [WELLS FARGO) Safe UAV Operational Procedures. 

### Infrastructure Safety Inspection Operations: Utility & 

### Infrastructure Inspection specificto crop harvest and delivery from field Agriculture Inspection
Aspart ofthis [WELLS FARGO) is requesting FAA Exemption for sUAS operations for safety, inspection and image 

### Ivideo capture usage: 

### Regulatory Basis for Exemption Request
In addition to the waiver authority provided in §333 ofthe ModernizationAct, the FAA may grant an exemption under 49 U.S.C. §44701(£) ifit has determined that such an exemption is in the public interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety orhowthe exemption would provide at least an equivalent level ofsafety as compliance with the underlying regulation. In this case, approval of this exemptionwould advance the public interest by significantly enhancing the safety and efficiency ofinfrastructure operations and by providing the FAA with valuable user experience on sUAS in a context with appreciable economic and societal benefits. As described more fully below, the requested exemptionwould permitthe operationofsUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary, as explained below, [WELLS FARGO] anticipates that use ofsUAS will enhance safety in infrastructure and agricultural operations. Granting an Exemption is in the Public Interest. The safety and efficiency ofinfrastructure and agricultural operations is heavily dependent upon constant analysis ofassets, right-of-way, infrastructure and otherassets/facilities on the farm and ranch land along with the condition of the farm and ranch land itself. There are a wide variety offactors that can affect conditions and cause problems for infrastructure and agricultural operations that can impact crop yield and soil conditions. Evenrelatively small objects orminorfailures can lead to accidents or other incidents causing downtime ofinfrastructure. Extreme weather events can lead to flooding or overheating infrastructure, damage to the structural integrity ofthe buildings themselves and the conditions ofthe surrounding fields. As a result, pursuantto federal regulations and company policy, ourclient'smaintenance employees and in the case ofan alleged loss, WellsFargo, routinely inspect the infrastructure and agricultural fields at issue. At present, this work is done primarily by company personnel in motor vehicles, on foot, in specialized equipment. This is often a labor-intensive and sometimes arduous and riskyjob. While our clients do all they canto make these inspections as safe as possible, there is an irreducible elementofrisk involved whenever employees are required to go out on structures ill'l:d distraught farm land. Employees

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may need to climb over or onto structures, which can be slippery, rough, and/or exposedto the elements. Equipment moving through inspection zones can increase risk as well, especially in remote areas where they can get stuck and the conditions ofimpactto the soil difficult to obtain 

### in flood like conditions. While the use ofsUAS for supplemental infrastructure and general asset evaluationwould not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risks to employees by allowing for remote aerial review. Additionally, the sheeramount ofassets and the widely dispersed locations inherent in the field ofagriculture operations

- in most ifnot all instances far from sizeable population centers

- means that visual inspection in all instances by company personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical because the required altitudes for safe flight reduce visibility below meaningful levels- it is simply not possible to see all asset anomalies from such heights. Helicopters present better vantage points; however manned helicopters are much more costly, subject to human safety and carry highly explosivejetfuel making them impractical for deployment. By using sUAS for supplemental asset evaluation, [WELLS FARGO] will be able to substantially upgrade its capacity to detect and address issues with the right-of-way and other assets before they become a problem for safe operations. Thus, the use ofsUAS has the potential to improve efficiency, resulting in faster and safer delivery of crop/damage evaluations, and agricultural resources vital to the U.S. economy. 

### Granting an Exemption will not Adversely Affect Safety [WELLS FARGO] notes that there is no applicable standard for an equivalency determination. Some have argued that the appropriate standard is that for model aircraft, noting that their operations, ifconducted for recreational purposes, would fall completely within the allowable operations for model aircraft. We believe it is difficult to argue that there is sufficientcorrelation between model operations controlled by the Academy ofModel Aeronautics and the ones contemplated by [WELLS FARGO]. At the same time, it is clearthat equivalency cannot be established for traditional, manned civil aircraftbecause the design and use profiles between traditional aircraft and sUAS are simply too different. As such, we believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, which is all that §11.8l(e)requires. Granting an exemption will not adversely affect safety. [WELLS FARGO] contemplates conducting sUAS operations overclient owned or controlled land, solely during daylight hours, at altitudes under 400 feet AGL well belowthat which would pose a risk to other aircraft and within FAA sUAS requirements. In general, sUAS operations are intended to be conducted in areas distant from both congested areas and airports. Moreover, because ofthe inherent risks presented by standard infrastructure operations, ourclients have already taken steps to secure property against unauthorized public access. For example, substantial stretches ofpipeline, utilities, railroad track and oil production sites are fenced, elevated, or otherwise secured to prevent access. Other long stretches ofinfrastructure are, as noted above, in very remote wilderness areas. The nature ofoperations anticipated by [WELLS FARGO] requires that the sUAS be flown at relatively lowaltitudes and relatively low speeds.

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### Accordingly, the risk ofinterference with another aircraft is minimal. [WELLS FARGO] also plans to conduct sUAS operations at least five miles from any public airports (including heliports). In the event an operation needs to be conducted closerto an airport, [WELLS FARGO] will inform the airport operator and airport air traffic control tower ofthe contemplated operation and will comply with any directions issued by airtraffic control at that airport. sUAS PICS will also be instructed as a part ofpre-flightplanningto contact local crop dusting business(s) to ensure the sUAS will not be flown over fields scheduled during dusting operations at least three days in advance. Approval ofexemptions allowing commercial operations ofsUASs in the infrastructure and agricultural aerial inspection industry will enhance safety by reducing risk. Conventional operations, usingjetorpiston power aircraft, operate at extremely low altitudesjustfeet from the subject being inspected and in extreme proximity to people and structures; and presentthe risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts of jetA or other fuel (140 gallons forjethelicopters). Such aircraft must fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthatrisk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the inspection site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.
The operation ofsmall UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft requirements and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in closeproximity to the ground and people. The safety ofthose on the ground is protected by the fact that no one will be allowed into the area without the permission ofthe company. Security will be established for the flight area as part of the pre-flightcontrol. Each individual within the secure area will be briefed priorto flight and will consentto being in the area. All others will be excluded from the area. [WELLS FARGO] initially intends to use a dedicated stafffor sUAS operations. All operations will be within visual line-of-sight (i.e., no more than approximately 0.5 miles from the manipulator ofthe controls, orpilot in command (PIC)). Each PIC will conduct at least three take-offs and landings with the sUAS on which he or she is trained every 90 days. PIC's will establish their qualifications thru a combination ofaeronautical knowledge, UAS airmanship skills, and verificationthrough testing offlight ability before infrastructures operations have commenced. Depending onthe type ofoperation, additional ground-based visual observers may be employed as well. These observers will be within constant visual line ofsight and in constant contact with the PIC. The visual observers will assist the PIC in avoiding objects nearthe sUAS.[WELLS FARGO] intends to use commercially available sUAS Components for sUAS. These sUAS systems will be tested for quality & safety in ourtest facility before being deployed to the field. The sUAS is less than 50 lbs. fully loaded, carries neither a pilot
nor passenger, and operates exclusively within a secured area. We have a routine maintenance schedule to verify that the sUAS will remain in safe and operational condition.
Please see

### Appendix B, for Specific Types ofsUAS.
Notes Regarding: 14 C.F.R. Part 21, SubpartH In accordancewith the statutorycriteriaprovided in Section 333 ofPL 112---95 in referenceto 49 USC 44704,andin consideration ofthe size, weight, speed, andlimited operatingarea associatedwith theaircraftand its operation,we requestthatthis aircraftexemptionmeetsthe conditions ofSection 333.Therefore, ifgranted Section 333 reliefof14CFRpart21, and any associated noise certificationandtestingrequirements ofpart 36, is notnecessary.
Notes Regarding: 14 C.F.R. 

### §45.23 (b). Marking ofthe Aircraft Given the size ofthe sUAV, two-inch lettering will be impossible.
UA will be identified by serial number, registered in accordance with 14CFR part47, and have identification (N---Number) markings in accordance with 14 CFR part45, Subpart C. Markings will be as large as practicable.
Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness [WELLS FARGO]'srequest is based on the fact that no airworthiness certificatewill be issued for the UAS. [WELLS FARGO]'s UAS will not require an airworthiness certificate in accordance with 14 CFRpart21, Subpart H. Based onthe fact that an airworthiness certificate will not be issued, exemption from§ 91.7(a) is not necessary.
Notes Regarding: 14 CFR 

### §91.9(b)(2) Civil aircraft flight manual, marking & placard Certifications required, the original intent ofthese regulations was to display an aircraft's airworthiness, certification, and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014, the requested relieffrom 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary.
NotesRegarding: §91.109 Flight instruction; Simulated instrument & certain flight tests Small UASs, by their design, do not have fully functional dual controls. Flightcontrol is accomplishedthroughthe use ofa control box that communicates with the aircraft via radio communications. Aircraftbeingconsidered for use by [WELLS FARGO] allowthe UAS Instructorto placethe aircraft into 'loiter' mode (fixed altitude stationary hold). Inthe event of the student losing control, the UAS Instructor can quickly and via alternate equipment (equipmentnot in the hands ofthe student) place the aircraft into a mode that then allows the instructorto bringthe aircraft back into control and back to thepredetermined and/or safe landing location. [WELLS FARGO] does not describe training scenarios in which a dual setofcontrols would be utilized orrequired, i.e. dual flight instruction, provided by a flight instructor orothercompany-designated individual, that would require that individual to have fully functioning dual controls. Rather, [WELLS FARGO] evaluates the qualification ofits PICs based ontheirexperience with the VAS to be operated and verifies through testing, in lieu of formalized training.
As such, [WELLS FARGO] does not seek relieffrom 14 CFR 

### §91.109. Notes Regarding 

### § 14 CFR91.119(b) Relieffrom 

### § 14 CFR91.119(b), operation over congested areas, is not applicable, because the [WELLS FARGO]'s operations will only be conducted withinthe secured areadescribed herein. 

### [WELLS FARGO) Safety Operations & 

### Procedures Overview: Technology Considerations: Best-in-class, tried and proven technologies that are in advanced iterations. Software from highly-reputable industry partners will include features1. Auto descent (landing) ifcommunication signal were to be severed. Ifthe sUAS loses communications, the sUAS will have capability to return to a pre-determined location within the Security Perimeterand land.
2. Auto descent and return to home- RTH (landing) ifbattery were to drop lower than nominal level(25%).
3. Flights will be terminated at 25% battery powerreserve.
4. Live video for operator gives real-time positioning feedback. In other words, we can monitor the scene from the vehicle's perspective for collision avoidance, and to maintain spatial orientation.
5. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles oremergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all times: speed, altitude, number ofGPS satellites (when available), heading and voltage.
7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures occur (highly improbable), vehicle returns automatically to the point of launch.
8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, orany combination thereof. Priorto each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot. Mechanical/Physical:1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminatingthe concern ofsignal severance (flying behind objects/walls).
2. The sUAS will weigh less than 50 lbs and travel at less than 87 knots.
3. Batteries should far exceed the capacity required for actual flight time.
4. Flights will be operated at an altitude ofno more than 400 feet AGL.
5. Fireproofbags for storage and charging ofhigh capacity Lipo batteries on-site.
6. UA operated underthis exemptionwill bemarked in accordancewith 14CFR part45 oras otherwiseauthorized bythe FAA.
Personnel:
I. Spotters ensure safe operation and act as a redundant set ofeyes for operators (pilot, gimbal op)
2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication.
3. A briefing will be conducted in regard to all planned sUAS operations priorto each days activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeterbe contact WF RCIS central operations to ensure all required activities have been completed.
4. The operatorwill obtain the consentofall persons involved in the sUAS operations and ensure that only consentingpersons will be allowed within 100 feet ofthe flight operations.
5. Observerand pilot will at all times be able to communicate by voice.
6. Pilot and observer will have been trained in operation ofUAS generally and received up-to-date information on the particular UAS to be operated. 

### Operations:

1. The unmanned aircraft (UA) will weigh less than 50 pounds (25 Kg), including energy source(s) and equipment. Operations authorized by this petition ofexemption are limitedto the following aircraft described in Appendix B. Proposedoperations ofany otheraircraft will require
a newpetitionora petition amendmentto this request.
2. The UA may notbe flown at a ground speed exceeding 87 knots.
3. Flights must be operated at an altitude ofno more than 200 feet above ground level (AGL), as indicated by theprocedures specified inthe operator's manual. All altitudes reportedto ATC must be in feet AGL.( 

### 4. The UA mustbe operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC'sFAA-issued medical certificate.
5. All operations mustutilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mustbe able to communicate verbally at all times.
6. The operator's manual included as Appendix C and this petition ofexemption must be maintained and made available to the Administratorupon request. Ifa discrepancy exists betweenthe conditions and limitations in this exemption and the procedures outlined in the operator's manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator's manual. The operatormay update orrevise its operator's manual. 

### Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administratorupon request. The operator must also present updated and revised documents ifit petitions for extension or amendment. Ifthe operatordetermines that any update orrevision would affect the basis for which the FAA grants this petitionfor exemption, then the operator mustpetition for amendment to their exemption. The FAA'sUAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operator's manual.
7. Priorto each flight the PIC must inspect the UAS to ensure it is in a conditionfor safe flight. Ifthe inspection reveals a conditionthat affects the safe operationofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, ifutilized, must be included in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraft records.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight in accordance with the operator's manual. The PIC who conducts the functional test flight must make anentry in the UAS aircraftrecords ofthe flight. The requirements and procedures for a functional test flight and aircraftrecord entry must be added to the operator's manual.
9. The operatormust follow the manufacturer'sUAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. Whenunavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenancerequirements must be established and identified in the operator's manual. At a minimum, requirements for the following mustbe included in the operator's manual:

a. Actuators 

### I Servos; b. Powerplant (motors);
c. Propellers; d. Electronic speed controller;

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e. Batteries;. f. Remote command and control; g. Ground control station (ifused); and h. Any othercomponents as determined by the operator;
10. Priorto operations conducted for the purpose ofinfrastructure and agricultural inspections, the PIC must have accumulated and logged, in a mannerconsistentwith 14 CFR 

### §61.5l(b), a minimum of50 flight cycles and 10 hours oftotal time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similarUAS type. Priordocumented flight experience that
was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted underthis petition of exemptionto accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119.
11. Priorto operations conducted for the purpose ofinfrastructure inspection, the PIC must have accumulated and logged, in a mannerconsistent with 14 CFR 

### § 61 .51(b), a minimum offive hours asUAS pilot operating the make and model of UAS to be utilized for operations underthe exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-offand landing currency flights canbe conducted underthis petition ofexemption to accomplishthe required flight time and 90 day currency. During training, proficiency, experience-building, and take-offand landing currency flights all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### §91.119.
13. Priorto any flight operations authorized by this petition ofexemption, the PIC and VO must have successfully completed a qualificationprocess, as outlined in the operator's manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualifiedperson designated at the sole discretion ofthe operator. A record ofcompletion ofthis qualificationprocess mustbe documented and made available to the Administrator upon request.
14. Priorto operations conducted for the purpose ofinfrastructure and agricultural operations inspection, a flight demonstration, administered by an operator-approved and -qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval ofcompany designated examiners, the petitionerwill conduct these tests in accordance with the operator's manual.
15. The UA may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event ofa UAS failure or emergency.f I

16. Regarding the distance from participating persons, the operator's manual has safety mitigations for authorized and consenting personnel. At all times, those persons must be essential to the operations.
17. Regarding distance from nonparticipating persons, the operatormust ensure that no persons are allowed within 500 feet ofthe area exceptthose consenting to be involved and necessary for the infrastructure inspection operations. This provision may be reduced to no less than 200 feet ifit would not adversely affect safety and the Administrator has approved it. Forexample, an equivalent level ofsafety may be determined by an aviation safety inspector's evaluation ofthe infrastructure inspection area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of
an accident.
18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the security perimeterand land orbe recovered in accordance with the operator's manual.
19. The UAS must abort the flight in the event ofunpredicted obstacles oremergencies in accordance with the operator's manual.
20. Each UAS operation must be completed with 25% battery powerremaining. 21. The operatormust obtain an AirTraffic Organization (ATO) issued Certificate ofWaiveror Authorization (COA) priorto conducting any operations underthis petition ofexemption. This COA will also require the operatorto request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with \4 CFRpart45, SubpartC. Markings must be as large as practicable.
23. Theoperatormust develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status ofreplacement/overhaul componentparts, and the total time in service ofthe UAS. These procedures must be added to the operator's manual.
24. Each UAS operated underthis exemption must comply with all manufacturer Safety Bulletins.
25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator's manual.
26. The preflight inspection section in the operator's manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, orequipment, not covered in the relevant-preflight inspection sections ofthe operator's manual.
27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA mustcomply with the Federal CommunicationsCommission (FCC) orotherappropriate government oversight agency requirements.28. At least three days before scheduled infrastructure inspection, the operatorofthe UAS affected by this exemption must submit a written Plan ofActivities to the local FSDOwith**jurisdic~ion** over the area ofproposed infrastructure inspection. The 3-day notification may be waived with the
concurrence ofthe FSDO. The plan ofactivities must include at leastthe following:

a. Dates and times for all flights; b. Name and phone numberofthe operatorfor the UAS infrastructure inspection operations conducted underthis petition ofexemption;
c. Name and phone numberofthe person responsible for the on-scene operation ofthe UAS; d. Make, model, and serial orN-numberofUAS to be used;·
e. Name ofUAS PICs involved in the infrastructure inspection event; f. A statementthat the operatorhas obtained permission from property owners and/or local officials to conductthe infrastructure and agricultural operations inspection event; the list ofthose who gave permission mustbe made available to the inspector upon request;

g. Signature ofexemption-holder orrepresentative; and
h. A description ofthe flight activity, including maps ordiagrams ofany area, city, town, county, and/or state overwhich infrastructure inspection will be conducted and the altitudes essential to accomplish the operation.
29. Thedocuments required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administratororany lawenforcement official upon request.
30. The UA must remain clearand yield the right ofway to all othermanned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).
31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
32. The UAS may not be operated by the PIC from any moving device orvehicle.
33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC.
34. The UA may not operate in Class 8, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles ofthe geographic centerofa non-towered airport as denoted on a current FAA-published aeronautical chartunless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreement with the airport management mustbe made available to the Administratorupon request.

. 35. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National(

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

### Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, [WELLS FARGO] provides the following information: 

### Contact Information: Mark McAdam./ Vice President Wells Fargo Bank, NA Wholesale Security Strategic Services 7679 Archer Lane N Maple Grove, MN 55311 Mark.Mcadam@wellsfargo.com Regulatory Provisions from which [WELLS FARGO] seeks ari. Exemption
[WELLS FARGO] believes it may need an exemption from the following provisions to conduct the contemplatedoperations. In some instances, reliefis needed because relief from anotherprovisionrenders compliance with the regulation at hand infeasible.
333 Aircraft Exemption Status
14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(l)&(2) 14 C.F.R. §91.417(a)&(b) [WELLS FARGO] believes an exemption is only needed from the above-listed regulatory provisions. To the extentthat the FAAbelievesthat additional reliefis required for [WELLS FARGO] to conductthe operations described here, we request an exemption from any such regulatory provisions as well.33 Forexample, 14 C.F.R. §91.417(a) imposes certain maintenance record keepingrequirements "as applicable". Since none ofthe underlying requirements (e.g., inspection intervals) canbe met and will require an exemption, [WELLS FARGO] believes a separate exemption should not be required for §91.417(a).


### The Extent ofRequested Relief and the Reasons Reliefis Needed Section 333 Aircraft Exemption Status:
Section 333 ofthe Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration ofthe size, weight,

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speed, operational capability ofthe particular UAS, as well as its proximity to airports and populated areas. An analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate in the areas and underthe conditions contemplated by [WELLS FARGO] will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate withoutthe conditions proposed in this request. The sUAS is less than 55 Ibs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operatorand observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area ofoperation as is now done with conventional equipment, infrastructure, bridge and outbuilding evaluation. These safety enhancements provide an expanded degree ofsafety to the inspectors overconventional operations. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials and inability to carry a substantial external load. Given the size and limited operating area associated withthe aircraft to be utilized by the Applicant, this meets the requirements ofanequivalent level ofsafety underPart 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirement for an airworthiness certificate, upon considerationofthe size, weight, speed, operational capability, andproximity to airports andpopulated areas ofthe particular sUAS. In all cases, an analysis ofthese criteriademonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
14 C.F.R. §61.113(a) and (b) 

### §61.113 Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a privatepilotcertificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation orhire; normay that person, for compensationorhire, act aspilotin command ofan aircraft. (b) A private pilotmay, for compensation orhire, act as pilot in command of
an aircraft in connection with any business oremploymentif: (1) The flight is only incidental to that business oremployment; and (2) The aircraftdoes not carry passengers orproperty for compensation or hire. 

## ***** [WELLS FARGO] anticipates initially using a cadre ofspecially trained staffto conductthe sUAS operations. While these individuals will not hold commercialpilot licenses. The sUAS will not carry property for compensation orhire since they will be used solely to assist in evaluationofthe crop 

### IRanch 

### I Orchard 

### IVineyard infrastructure and Fields in furtherance of [WELLS FARGO]'s client'sprimary business, the successful operation ofa infrastructure;....



### however, the employees' operation ofthe sUAS will notbe incidental to theiremployment with [WELLS FARGO], and they will be compensated for such work. The sUAS will fly at altitudes well belowthe permissible limits for other civil aircraft, eliminating the risk to otheraircraft, and within a geographical envelope underthe sole control of[WELLS FARGO] clients. Accordingly, the risk would be limited to [WELLS FARGO] personnel, who will be appropriately outfitted in safety gear, and [WELLS FARGO] client'sproperty onthe ground. Requiring a commercial pilotcertificate would provide no appreciable safety benefit and would needlessly impose additional cost on [WELLS FARGO]. Because the contemplated operations would not comply with §61.113(b)(1) and none ofthe other exceptions to paragraph (a) apply, reliefis needed from both paragraphs (a) and (b).
14 C.F.R. 91.119(c) 

### §91.119 Minimum safe altitudes: General. Except when necessary for takeoffor landing, no person may operate an aircraft belowthe following altitudes: · 

## *** (c) Overotherthan congested areas. An 

### altitude of400 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may notbe operated closerthan 500 feet to any person, vessel, vehicle, or structure. 

## ***** [WELLS FARGO] submitsthat the only reliefit requires from §91.119 is from the minimum altitudes listed in paragraph (c). Reliefis required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet orhigher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk ofcollision with another aircraft, safety can only be assured through the grant ofan exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, reliefshould not be needed from paragraph (a) because an emergency landing ofthe aircraft due to apower failure will not create an undue hazard to persons orproperty on the surface. As noted in the explanation ofwhy an exemptionwill not adversely affect safety, [WELLS FARGO] clients has exclusive use ofthe land overwhich the sUAS will be operated, and public access is restricted. It 

### also has exclusive use ofsignificantportions ofland adjacent to the infrastructure and structures that will be the objects ofevaluation and analysis. [WELLS FARGO]'s Clients tightly control access to land and havethe ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk ofinjury is minimal. [WELLS FARGO] does not contemplate conducting operations over congested areas, so reliefis not requested from paragraph (b).
14 C.F.R. 91.121 

### 14 C.F.R. §91.121 Althneter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departureairport oran appropriate altimeter setting available before departure." 

### ***** As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. Anequivalent level ofsafety will be achieved by the operator, pursuantto the Operations Manual and Safety Check list, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, ordigitally encoded barometric altimeter, orradio altimeter, orany combination thereof. Priorto each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.
14 C.F.R. 91.151 

### §91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enoughfuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly afterthat for at least 30 minutes. (b) No person may begin a flight in a rotorcraft under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 20 minutes. 

### ***** Operating the sUAS in a pre-defined area with less than 30 minutes ofreserve fuel does not raise the type ofrisk contemplatedby §91.151, i.e., that an aircraft could run out offuel in the event it has to be flown to analternate airport or circle the planned airport in the event ofunanticipated conditions. [WELLS FARGO] does not intend to use the sUAS for point-to-point flights and will not operate the sUAS beyond visual line ofsight. Norwill the sUAS require an airport in order to land. Rather, [WELLS FARGO] will operate the sUAS using pre-planned flight paths (taking into account weather conditions) designed to allowthe sUAS to fly to the point ofintended landing. As such, there is no need for a time-based excess fuel requirement. Rather it should be sufficient to require only as much additional excess flight capacity as necessary to safely land the sUAS.
We believethat a 25%battery reserve is more than sufficientto meetthis objective.

14 C.F.R. 91.405(a), 91.407(a)(1), 14 C.F.R. 91.409(a)(1)&(2) and 14 C.F.R. 91.417(a) & (b) 

### §91.405 Maintenance required.
Each owneroroperator ofan aircraft

- (a) Shall have that aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter;


### *****

### §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No personmay operate any aircraft that has undergone maintenance, rebuilding, or alteration unless- (1) It

### has been approved for return to service by a person authorized under §43.7 ofthis chapter; 

## ***** §91.409 Inspections. (a) Except as provided in paragraph (c) ofthis section, no personmay operate an aircraftunless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by aperson authorized by §43.7 ofthis chapter; or (2) An

### inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter.


### ***** §91.417 (a) & 

### (b) 

### ***** [WELLS FARGO] believes that an exemption from these three maintenance requirements is appropriate because the FAAhas not developed maintenance standardsthat would allowan operatorto meetthe part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) orto conduct the initial airworthiness and annual return to service inspections required by §91.409(a). [WELLS FARGO] will maintain the aircraft as instructed in the owner'smanual and ASTM F2909, where applicable, and will not operatethe aircraft until it has reasonably determined that any needed repairs have been made. However, because ofthe technical impossibility ofmeeting the requirements of§§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate.
Please do not hesitate to contact me atthe phone number or viathe e-mail address provided above should you have any questions orconcerns. Respectfully submitted, [SIGNATUREAND TYPEDNAME 

### IWELLS FARGO].



### Appendix A Summary for Federal Register Publication Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in ther 

### Federal Register shouldthe FAA determine thatpublication is needed. Petitioner: Drone Fleet & Aerospace Management, Inc. ([WELLS FARGO]) Sections of 14 C.P.R. Affected: 333 Aircraft Exemption Status 14 C.P.R. §61.113(a) and (b) 14 C.P.R. §91.119(c) 14 C.P.R. §91.121 14 C.P.R. §91.151 14 C.P.R. §91.405(a) 14 C.P.R. §91.407(a) 14 C.P.R. §91.409(a) 14 C.P.R. §91.417(a)&(b) Description ofReliefSought:
Petitioner seeks relieffrom the requirements of333 Aircraft Exemption Status, 14 C.P.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations over [WELLS FARGO] Client's owned orcontrolled land, solely during daylight hours, to assist in the safe evaluation and analysis ofinfrastructure and operations. In general, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature ofoperations anticipated by [WELLS FARGO] requires that the sUAS be flown atrelatively low altitudes. [WELLS FARGO] expectsthat in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path ofthe sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk ofinterference with other aircraft is minimal.

### Federal Register should the FAA determine that publication is needed. Petitioner: Drone Fleet & 

### Aerospace Management, Inc. ([WELLS FARGO]) Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) DescriptionofReliefSought:
Petitioner seeks relieffrom the reauirements of333 Aircraft_Exemotion Status. 14 C.F.R

..