U.S Department of Transportation January 19, 2016 From: AMK Services, To: U.S . Department of Transportation Attn: Docket Operations Secretary of Transportation West Building Ground Floor, Room w12 - 140 1200 New Jersey Avenue, SE. Washington, DC 20590 - 001 **SUBJECT: SMALL UNMANNED AIRCRAFT FOR USE IN THE INSPECTION OF**  **TRANSPORTATION INFRASTRUCTURE EXEM**  **P TION REQUEST**  Reference (a) Exemption No. 11637 Regulatory Docket No. FAA

–2015

–0599

(b) Exemption No. 111 71 Regulatory Docket No. FAA - 2014 - 0816 AMK Services is respectfully requesting and applying for Exemptions by Section 333

– FAA Reform and Modernization Act of 2012 and Part 11 - Federal Aviation Regulations from 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.7 ; 14 C.F.R. § 43.11; 14 C.F.R. § 45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.25; 14 C.F.R. § 45.27; 14 C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.203; 14 C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F. R. § 417(a) and (b). Dear Sir/Ma’am : On behalf of the AMK Services, LLC . ( “AMK Services ”), we submit to you this Request and Application for Exemptions from certain requirements of the FAA Reform and Modernization Act of 2012 and Regulations described above and in our proposal . In support of our Request and Application, we will describe the operations and equipment to be used by AMK Services , the necessity and reasons for exemptions as well as the precautions that AMK Services will implement and commit to follow. We seek an exemption from the aforementioned regulations to operate our unmann ed aerial s ystem commercially and lawfully . We seek relief of FAA restrictions for commercial UAS use to have the ability to offer asset inspectio ns for the Transportation Industry to include but not limited to Rail systems, Bridges and Highway/Interstate support structures . By granting our request, we will be able to provide a safer and more economical approach to the inspection of Railways, Bridges and S upport S tructure s throughout the United States. Our UAV is certified to work around bridges, railway s and other support structures while maintaining a safe distance from the structures as set forth in F ederal, S tate and L ocal regulations. AMK Services respectfully request that the FAA grant our exemption request and are willing to work with and share all inf

ormation to benefit the FAA to ensure that lessons learned and procedures are reported back to the FAA for future use in guidelines and regulations.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 2 **Table of Contents** 1. Applicant Information - AMK Services, LLC. ................................ ................................ ............... 3 2. Description of Operations ................................ ................................ ................................ ............... 4 2.1 Description of UAS ................................ ................................ ................................ ................ 4 2.2 UAS Pilot in Command ................................ ................................ ................................ .......... 8 2.3 UAS Operating Parameters ................................ ................................ ................................ .... 8 2.4 Limited and Predetermined Use ................................ ................................ ............................. 8 2.5 Preflight Inspection ................................ ................................ ................................ ................ 9 2.6 Flight Functional Test ................................ ................................ ................................ ............. 9 2.7 Manufacturing Requirements ................................ ................................ ................................ . 9 2.8 Operating and Flight Precautions ................................ ................................ ........................... 9 2.9 COA ................................ ................................ ................................ ................................ ...... 10 2.10 Maintenance ................................ ................................ ................................ ......................... 10 2.11 Safety Bulletins ................................ ................................ ................................ .................... 10 2.12 Radio Frequency ................................ ................................ ................................ ................... 10 2.13 Plan of Activities ................................ ................................ ................................ .................. 10 2.14 Documents ................................ ................................ ................................ ............................ 11 2.15 Right of Way ................................ ................................ ................................ ........................ 11 2.16 Operations ................................ ................................ ................................ ............................ 11 2.17 Accident Reports ................................ ................................ ................................ .................. 11 3. AMK Services’ Request for Exemption ................................ ................................ ....................... 11 3.1 Exemption Requests ................................ ................................ ................................ ............. 12 4. Privacy ................................ ................................ ................................ ................................ .......... 19 5. Conclusion ................................ ................................ ................................ ................................ .... 19 6. Exhibits Enclosed ................................ ................................ ................................ ......................... 20 6.1 Exhibit A - DJI

– Phantom 2 User Training Guide ................................ .............................. 20 6.2 Exhibit B - DJI

– Phantom 2 User Manual ................................ ................................ ........... 20 6.3 Exhibit C - DJI - Phantom 2 Release Noted Dated Feb 2015 ................................ ................ 20 6.4 Exhibit D - Training Course Materials from Unmanned Experts Training Facility ............. 20 6.5 Exhibit E - License and Pilot Information for Robert Bailey. Pilot for AMK Services ...... 20U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 3 

# 1. **Applicant I nformation**  **- AMK Services, LLC**  **.** This is the second request from AMK Services to operate UAVs in a commercial setting in order to benefit local and national infrastructure by providing safe and cost effective inspections without the need for extensive personnel risk. AMK Services was previously granted an exemption for the use of UAV within the public safety arena for the inspection of towers. Please see Exemption No. 11637 Regulatory Docket No. FAA

–2015

–0599 (Reference a) for further amplification. AMK Services has registered as operators of Drones in accordance with statutes set forth by the FAA dated 21 December 2015, stating that anyone who owns a small unmanned aircraft of a certain weight must register with the Federal Aviation Administration's Unmanned Aircraft System (UAS) registry before they fly outdoors. AMK Services’ Registration number is FA3YLKPF9H AMK Services, LLC is a full service communications and technology company with over 50 combined years of sales, engineering, implementation, project management and ongoing maintenance of Public Safety systems. AMK staff qualifications include a number of Degreed System Engineers, Senior System Technicians, P25 System Technicians, Project Managers, Vehicle Specialist, and Journeymen Technicians. All AMK personnel are background checked through a national screening process and then a local background check for each customer project. All AMK employees are required to comp lete a pre - employment drug screening. AMK also has instituted a monthly random drug screening policy for all employees and incorporated a companywide safety program. The name and address of the applicant is: AMK Services LLC . Attn: Greg Graham . Chief Executive Officer 9291 Crouse Willison Road Johnstown , Ohio 43031 740 - 975 - 1127 Greg@amk- services.com www.AMK - Services.comU.S. Department of Transportation January 19, 2016

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# 2. **De scription of Operations**  AMK Services requests permission to operate a small, unmanned, lightweight and relatively inexpensive aircraft system, the DJI Phantom 2 Quadcop ter (“Phantom 2”) under controlled conditions in airspace that is limited and predetermined. This will enable AMK Services to safely and efficiently inspect and monitor rail l ines, bridges and other support structures vital to Federal, State and Local t

ransportation infrastructure. AMK Services has worked with Public Safety and understands the need for cost effective and safe measures to inspect and monitor public infrastructure. As noted in Reference B , performing infrastructure inspections with unmanned systems is a benefit to the public for the following reasons:

 The operation significantly improves safety and reduces ri sk by alleviating human exposure to the dangers associated with aerial survey and inspection;  Itwill not be necessary to close a lane on bridge s while the inspection is being conducted; this significantly improves traffic flow and safety;  Railways can b e inspected without the need for works to remain on or near tracks or in the case of electric trains, power sources;  The UAS being operated are very small and contain no flammable fuel and in the remote event of an accident, will cause no damage or injurie s;  G iven that the cost to conduct an inspection using a UAS is considerably less than available alternatives, this important task can be accomplished which will benefit everyone utilizing this infrastructure. Your approval of AMK Services ’ request of the Exemptions stated herein will benefit the public and transportation Industry . The Exemptions will also reduce direct and indirect financial impacts on municipalities as well as state agencies and reduce or eliminate expensive surveying and aerial photography by conventional manned aircraft. The Exemptions will enable AMK Services to perform and provide real time data to Rail Lines , Cities and State Agencies to determine infrastructure integrity without danger to railway personnel, motorists and road crews. 

# 2.1 **Description of UA S**  AMK Services requests the Exemptions for use of the Phantom, a small unmanned aircraft system (“UAS”), for nonprofit land and conservation easement management, site inspe ctions, monitoring, conducting necessary aerial surveying, mapping, and aerial photography. 

## 2.1.1 Flight Time and Weight The high capacity, high performance 5200mAh Lithium Polymer battery offers up to 25 minutes of flight time. It provides battery capacity da ta, over charge/discharge protection, as well as maintenance reminders making the battery extremely safe and reliable .U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 5 The Phantom weighs less than three pounds. 

## 2.1.2 Live GPS Feedback The Phantom is equipped with GPS that displays the current position of th e Phantom in relation to the operator. Exceeding the control range of the remote control triggers the Phantom to automatically fly back to the original takeoff point and land safely. 

## 2.1.3 Precision Flight and Stable Hovering An integrated GPS auto -pilot system that offers position holding, altitude lock and stable hovering allows you to focus attention to be focused on shooting. 

## 2.1.4 Mobile Vision The operator may track the current flight and see what the Phantom sees through a mobile device. 

## 2.1.5 Manufacturer Updates Th e Phantom can connect to computers to receive manufacturer (DJI) firmware and applications, updates, news, alerts, and support. 

## 2.1.6 Remote Control The remote control contains a gimbal control dial, a trainer port, a built- in rechargeable LiPo battery with a capacity of 2000mAh, battery level LED indicators, and a throttle locking feature. 

## 2.1.7 Antistatic Compass The Phantom has an anti - static compass with a protective shell. Together, these equipment features ensure AMK Services and the UAS will “not create a hazard to users of the national airspace system or the public.” 

## 2.1.8 Flight Limitation Application In order to increase flight safety and prevent accidental flights in restricted areas, the firmware for the Phantom 2 series includes a No Fly Zone feature. These zone s have been divided into two categories that prevent inadvertent flyover of restricted areas that are uploaded into the onboard computer prior to flight and as part of the pre - flight checklist The Phantom has software to prevent the UAS from flying into restricted areas, such as airports. The software creates a five mile safety zone around the restricted area. The operator is notified when the Phantom is 330 feet away from a safety zone. If the Phantom is five miles from an airport, the UAS cannot fly higher than 400 feet. This height limit decreases as the UAS moves closer to the airport so that when the UAS is 1.5 miles away, the Phantom may not fly higher than 35 feet. If this occurs, the operator has full control of the Phantom’s movement, except that the Phantom will automatically descend to the restricted height. The operator is prevented from initiating flight if the Phantom is within 1.5 miles from a restricted area. If the operator accidentally flies into a safety zone due to a loss of GPS signal, the Phantom will land immediately once the signal returns. If this occurs, the operator may control the Phantom, with the exception that the operator cannot make the UAS ascend in altitude. In addition, the Phantom has features that allow the operator to manually set height limitations and limit how close a Phantom may fly to a safety zone.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 6 

## 2.1.9 Phantom E quipment Factory Specifications **2.1.9.1 Key** 

**Features**  Stabilization Gimbal 3 - axis Camera Stabilization Gimbal  Video Downlink Max 700m Wi - Fi Connection  Camera 14 Me gapixels/1080p  Controllable Range - 90°

– 0° (Vertical)  Ground Station Built into the DJI Phantom App  Remote Control New version (left dial, built- in LiPo battery)  800m (FCC), 5,8 Ghz preinstalled smartphone holder  Max Flight Time 25 minutes 

### 2.1.9.2 **Ai rcraft**   Weight (Battery & Propellers included): 1284g (approximately 2.8 lbs)  Battery 5200mAh LiPo Battery  Max Ascent/Descent Speed: Ascent: 6 m/s  Descent: 2m/s  Max Fl ight Speed: 15 m/s  Max Yaw Angular Velocity : 200°/s  Max Tilt Angle : 35°  Diagonal Length : 350mm 

### 2.1.9.3 **C amera**   Gimbal Pitch Control Range : 0° - 90°  Operating Environment Temperatures : 0°C - 40°C  Sensor Size : 1/2.3”  Effective Pixels : 14 Megapixels  FOV : 110°/85° Information from www.dji.com/products/compare -phantom. See also DJI

– Phantom 2 Specifications “ Exhibi t B ” attached hereto.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 7 

### 2.1.9.4 **Remote Control**  Operating Frequency : 5.728 GHz - 5.85 GHz  Communication Distance (Open Area) : CE: 400m  FCC: 800m  Receiver Sensitivity (1% PER) : - 93dBm  Transmitter Power (EIRP) : CE: 25mw  FCC: 100mw  Working Voltage: 120 mA@V  Battery LiPo Battery : 3.7V 2000mAH  Left Dial: Available  Throttle Lock : Available  Trainer Port: Available 

### 2.1.9.5 **Range Extender**  Operating Frequency: 2412 - 2462 MHz  Communication Distance (Open Area) : 500 - 700m  Transmitter Power: 20dBm  Power Consumption : 2WU.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 8 

# 2.2 **UA S Pilot in Comma**  **nd** The petitioner states that it will utilize commercial or private pilots with considerable experience in multiple unmanned systems or personnel who have extensive and documented training in UAS operation . Further, the petitioner indicates that the PICs will possess a minimum of 25 hours and 250 cycles in UAS in addition to at least 10 hours in the particular make and model. The petitioner notes that for all flight operations , a PIC will be designated and this person will be directly responsible for the operation of the UAS and the safety of the operation. It will be the responsibility of the PIC to ensure the operation complies with all applicable regulations and/or ensures professional “best practice” to all applicable regulations. In addition, for e ach operation a visual observer (VO) and team leader will be assigned. The VO will be responsible for the Ground Control Station (GCS) assembly, disassembly and pre and post flight procedures. During flight, the visual observer will visually maintain contact with the unmanned aircraft (UA) and scan the area for undetected aircraft and/or obstacles. The observer will also be responsible for all aviation related communications. The team leader will have overall responsibility for the mission . 

# 2.3 **UA S Operating P**  **arameters** The petitioner states that all flights will remain within visual line of sight (VLOS) of the pilot or observer. The petitioner further states that if the UAS loses communications or GPS signal, the UAS is equipped with advanced safety features th at will allow the attempt to re - establish contact with the GCS (hover in place), and after 3 minutes the UAS will automatically return to a pre - determined location. The petitioner notes that the UAS will operate at or below 400 feet above ground in remote, sterile areas. The petitioner further notes that it will launch and recover the UA from the area below bridges or at least 100 feet away from rail lines or supporting structures . The petitioner states that all flights will take place with optimal weather conditions and only under visual flight rules. No flights will occur from sunset to sunrise. The petitioner will use the small UAS to visually inspect the support structure of the bridge s, roadway s or railways . Because the structure supporting the roadway is below the roadway, in the rare occurrence that a malfunction occurs to the small UAS, the small UAS would fall to the canyon floor rather than onto a roadway. Moreover, the structure of the bridge and the space between the members of the bridge allow the pilot and observer to maintain line of sight on the UAS for the duration of the flight. For railways and support structures, the UAS can remain cl ear of any lines or traffic. Thus, the risk to the public is greatly reduced because the PIC will be able to avoid any obstacles and other aircraft in real time. Flights will not last any longer than 25 minutes. 

# 2.4 **Limited and Predetermined Use** AMK Services agrees to be bound by the following limitations and conditions when conducting management, inspection, mapping, surveying, and monitoring operations under an FAA issued exemption:U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 9  Phantom Weight: The UAS will weigh less than three pounds including energy source(s) and equipment. Operations authorized by this grant of exemption are limited to the following aircraft: DJI Phantom 2. [See “Exhibit B ” attached hereto .]  Limited Flight Speed: The UAS will not be flown at a speed exceeding a ground speed of 30 knots.  Flight Altitude Limit: Flights will be operated at an altitude of no more than 400 feet above ground level.  VLOS: The UAS will be operated within the visual line of sight (“VLOS”) of the pilot in command at all times. This requires the pilot in command (“PIC”) to be able to use human vision unaided by any device other than corrective lenses.  VO: All operations will use a visual observer (“VO”). The VO may be used to satisfy the visual line of sight requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 

# 2.5 **P reflight Inspection**  Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is re - inspected and found to be in a condition for safe flight. If there is a ground control station, it must be included in the preflight inspection. All maintenance and alterations will be properly documented in the UAS records. 

# 2.6 **Flight Functional Test** Any UAS that has undergone maintenance or alterations that affect UAS operations or flight characteristics such as the replacement of a flight critical component will undergo a flight functional test. The PIC who conducts the flight functional test will make an entry in the UAS aircraft records of the flight. 

# 2.7 **Manufacturing Requirements** AMK Services will follow the manu facturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. At a minimum, this will include requirements for the following: actuators, transmission (single rotor), power plant (motors), propellers, electroni c speed controller, batteries, mechanical dynamic components (single rotor), remote command and control, and ground control station (if used). 

# 2.8 **O perating and Flight Precautions** 

 The UAS will not be operated directly over any person, except authorized and con senting personnel, or below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.  Regarding the distance from participating persons, those persons must be essential to the mandatory conservation and environmental monitoring operations and any surveying operations. Because these procedures are specific to participating persons, no further FlightU.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 10 Standards District Office (“FSDO”) or Aviation Safety Inspector approval is necessary for reductions to th e distances specified.  Regarding the distance from non -participating persons, AMK Services will ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the mandatory conservation and environmental monitoring operations and any surveying operations. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved the reduction.  If the UAS loses communications or loses the GPS signal, the UAS will return to the original takeoff point.  The UAS will abort the flight in the event of unpredicted obstacles or emergencies. Each UAS operation must be completed within 25 minutes flight time or with 25% battery power remaining, whichever occu rs first. 

# 2.9 **CO A**  AMK Services will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to conducting any operations. This COA will require AMK Services to request a Notice to Airmen (“NOTAM”) not more than 7 2 hours in advance, but not less than 48 hours prior to operations. 

# 2.10 **Maintenance** AMK Services has develop ed procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. 

# 2.11 **Safety Bulletins** The UAS will be operated by AMK Services in compliance with all manufacturer Safety Bulletins. 

# 2.12 **Radio Frequency** Before conducting operations, the radio frequency spectrum used for operation and control of the UAS will comply with the Federal Communications Commission (“FCC”) or other appropriate government oversight agency requirements. 

# 2.13 **Plan of A cti**  **vi ties**  At least three days before scheduled use, AMK Services will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed UAS use. The three - day notification may be waived with the concurrence of the FSDO. The Plan of Activities will include at least the following:  Date and times for all flights.  Name and phone number of the operator of the UAS under this grant.  M ake, model, and serial or FAA issued N -num ber or registered number of UAS to be used.  Name and age of the UAS’s PIC involved.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 11  Statement that the operator has obtained permission from property owners and/or local officials.  The signature of exemption-holder or representative.  Description of the flight activity, including maps and diagrams of any area, city, town, county an d/or state over which UAS use will be conducted and the altitudes essential to accomplish the operation. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1.  All operations will be conducted under visual meteorological conditions (“VMC”). 

# 2.14 **Documents** The manufacturer’s Flight User Manual will be available to the PIC at the ground control station or ground control point of the UAS any time the aircraft is operating. 

# 2.15 **Right of Way** The UAS will remain clear of and yield the right of way to all manned aircraft operations and activities at all times. 

# 2.16 **Operations**

 The UAS operations will not be conducted at night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under VMC.  The UAS will not be operated by the PIC from any moving device or vehicle.  The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than three statute miles from the PIC.  The UAS will not be operated in Class B, C, or D airspace. The UAS will not be operated within five nautical miles of the geographic center of a non -towered airport as denoted on current FAA -published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is c onducted in accordance with Notice to Airmen as required by the Applicant’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request. 

# 2.17 **Ac cident Reports**  Any incident, action, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s Integration Office (AFS - 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (“NT SB”). Further flight operations will not be conducted until the incident, accident, or transgression is reviewed by the AFS - 80 and authorization to resume is provided. 

# 3. **AMK Services ’**  **Request for Exemption** AMK Services understands that the government is readying rules largely favorable to companies that want to use small drones for commercial purposes, according to a federal analysis, potentially leadingU.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 12 to the widespread flights by unmanned aircraft performing aerial photography, crop monitoring, inspecti ons of cell towers and bridges and other work. Due to the Phantom’s small size, light weight (less than three pounds), built - in safety features, and the remote, rural, and restricted locations where the Phantom will be operated, AMK Services can meet all requirements of safe UAS operations envisioned by Congress. The UAS’s size, weight, limited range and flight capacity, and restricted use on transportation infrastructure , inspected, and monitored by AMK Services in no way presents a national security issue. The Exemptions requested by AMK Services provide for the equivalent, if not a higher, level of safety than the current regulatory scheme provides due to the dangers associated with much larger, heavier, and f

aster conventional manned aircraft. In the alternative, AMK Services ’ operations meet the “special purpose operations” descriptions of 14 C.F.R. § 21.25 (b)(3) Aerial Surveys, Photography, and Mapping. 

# 3.1 **Exemption Requests** Based on the facts and descriptions we have provided for you on behalf of AMK Services , we respectfully request that the FAA grant the following requested exemptions: 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.7; 14 C.F.R. § 43.11; 14 C.F.R. § 45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.25 ; 14 C.F.R. § 45.27; 14 C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 14 C.F.R. § 91.1 19; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.203; 14 C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b). 

## 3.1.1 14 C.F.R. 21, Subpart H: Airworthiness Certificate AMK Services requests an exemption from 14 C.F.R. 21, Subpart H. This Subpart establishes the procedures for the issuance of an airworthiness certificate. AMK Services requests an exemption from Part 21, Subpart H because the Phantom meets an equivalent level o f safety pursuant to Section 333 of the Reform Act due to its small size, light weight, and remote rural operating environment. 

## 3.1.2 14 C.F.R. 43 **3.1.2.1 43.7: Persons A** **uthorized to A pprove Maintenance, Rebuilding, and**  **Operation** AMK Services requests an exemption from 14 C.F.R. 43.7. This part provides that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service. AMK Services operators will co nduct inspections and maintenance based on maintenance guidelines provided by DJI, the manufacturer of the Phantom. The capabilities of AMK Services operators to maintain and repair the UAS will meet the requirements for an equivalent level of safety pursuant to Section 333 for this type of UAS, its intended use, and the remote rural operating environment.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 13 

### 3.1.2.2 **43.11: Records for Inspections** AMK Services requests an exemption from 14 C.F.R. 43.11. This part provides that maintenance record entries be maintained, that the inspector list discrepancies, and to affix placards to the aircraft. This UAS, due to its small size, does not have room for placards to be placed in or on it and no inspections for UAS have been certified by FAA at the present time. However , as a condition to the grant of the exemption, AMK Services is willing to keep records and log books of all maintenance and repairs. 

## 3.1.3 14 C.F.R. 45 **3.1.3.1 45.21: General**  AMK Services requests an exemption from 14 C.F.R. 45.21. This part provides that except as p rovided in § 45.22, no person may operate a U.S. -registered aircraft unless that aircraft displays nationality and registration marks in accordance with the requirements of this section and §§ 45.23 through 45.33. There are no current procedures for obtaining a registration mark for UAS by the FAA. However, as a condition to the grant of the exemption, AMK Services is willing to be assigned a registration number and to display it where practicable as addressed in this Request and Application for Exemptions relative to Parts 45.23, 45.27, and 45.29, below. 

### 3.1.3.2 **45.23 (b): Marking of the A ircraft**  AMK Services requests an exemption from 14 C.F.R. 45.23(b). This regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light - sport category aircraft or experimental or provisionally certificate d aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "pro visional," as applicable. Even though the UAS will have no airworthiness certificate, AMK Services requests an exemption from this requirement since the Phantom will have no entrance to the cabin (no cabin), cockpit (no cockpit), or pilot station on which the word “Experimental” or such other required description can be placed. Given the size of the UAS, two - inch lettering will be impossible, AMK Services is willing to place the word “Experimental” on the UAS in compliance with § 45.29(f). The equivalent level of safety will be provided by having the UAS marked as required by § 45.29(f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental” or such other required lettering. 

### 3.1.3.3 **45.25: Location of Ma rks on Fixed**  **- Wing A** **ircraft** AMK Services requests an exemption from 14 C.F.R. 45.25. The UAS is a multirotor, quadcopter, model - sized aircraft and is not a fixed-wing aircraft. Therefore, 14 C.F.R. 45.25 by its terms does not apply. 

### 3.1.3.4 **45.27: Location of Mar ks: Nonfixed**  **- Wing A** **ircraft** AMK Services requests an exemption from 14 C.F.R. 45.27. This part provides that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom,U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 14 or tail the marks required by § 45.23. The UAS, due to its small size, does not have a cabin, fuselage, boom or tail to display the marks required by § 45.23. 

### 3.1.3.5 **45.29: Size of Marks** AMK Services requests an exemption from 14 C.F.R. 45.29. This part provides at subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. The UAS, due to its small size, does not have any surface area large enough to display marks anywhere near 12 inches high. However, as a condition to the grant of the exemption, AMK Servic es is willing to place an aircraft mark on one or more of the "arms" of the UAS. The size of the marking will be determined by the size of the "arm" being used and may be less than one inch in size. 

## 3.1.4 1 4 C.F.R. 47.3(b)(2): Registration Required AMK Service s requests an exemption from 14 C.F.R. 47.3(b)(2). This part provides: (b) No person may operate an aircraft that is eligible for registration under 49 U.S.C. 44 101 - 44104, unless the aircraft:  Has been registered by its owner; [or]  Is carrying aboard the temporary authorization required by § 47.31(c). There are no current procedures for obtaining a registration mark for UAS by the FAA. However, as a condition to the grant exemption, AMK Services is willing to be assigned a registration number provided by F AA and to display it where practicable as addressed in this Request and Application for Exemptions relative to Parts 45.23, 45.27, and 45.29, above. 

## 3.1.5 14 C.F.R. 61, Subpart E – Certification: Private Pilots AMK Services requests an exemption from 14 C.F.R. 6 1, Subpart E. Section 61, Subpart E describes the requirements for issuance of private pilot certificates and the general operating rules for persons who hold those certificates and ratings. Because the UAS will not carry a pilot or passengers, the propos ed operations can achieve the equivalent level of safety of current operations by requiring the PI C operating the UAS to have completed a UAS flight training course before flying the UAS (See DJI

– Phantom Pilot Training Guide, Phantom 2 User Manual, and C ourses of Training fo r Certification). Unlike a conventional manned aircraft that carries the pilot and passengers, the UAS is small in size, weighs three pounds or less, is remotely controlled, and has no humans on board. The area of operation is contro lled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional manned aircraft. The risks associated with the operation of the UAS are much reduced from the level of risk associated with conventional manned aircraft operations contemplated by Part 61. Allowing the Exemptions and special purpose operations of the UAS as requested by AMK Services with an operator who has met the requirements of safety and training as stated in the DJI

– Phantom Training Guide and User Manual. AMK has also completed the Scheduled DJI Phantom Training Course, and will have completed the Pilot Training p rogram Certificate from The Unmanned Experts Training Academy which exceeds the present level of safety prescribed by 14 C.F.R. § 61.113 (a) and (b). Additionally, in the interim, AMK Services has on staff a fully licensed Commercial pilot. His license and information is presented in Exhibit “E”U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 15 

## 3.1.6 14 C.F.R. 91  See DJI

– Phantom 2 Training Guide, “Exhibit “ A ” attached hereto.  S ee DJI

– Phantom 2 User Manual, “Exhibit “ B ” attached hereto.  See DJI

– Phantom 2 Release Notes Dates Feb 2015l, “Exhibit “ C” attached hereto.  See List of Training Courses from Unmanned Experts , “Exhibit “ D ” attached hereto; http://www.unmannedexperts.com/wp - content/uploads/140610 -UMEX - Training - Cours e Brochure -US.pdf AMK Services requests an exemption from 14 C.F.R. 91.7(a). The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Given the small size, light weight, and low noise level output of the UA S, the requirements for maintenance, and the use of safety checklists prior to each flight, an equivalent level of safety will be provided. 

### 3.1.6.1 **91.9(b)(2): Civil A ircraft Flight Manual [in the A** **ircraft], Marking, and Placard Requirements**  AMK Services requests an exemption from 14 C.F.R. 91.9(b)(2). Section 91.9(b)(2) provides: No person may operate a U.S. -registered civil aircraft f or which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its small size and configuration, has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the UAS. The equivalent level of safety will be maintained by keeping the manufacturer’s Training Guide and User Manual at the ground control point where the operator flying the UAS will have immediate access to it. 

### 3.1.6.2 **91.9(c): Civil A ircraft Flight Manual, Marking, and Placard Requirements**  AMK Services requests an exemption from 14 C.F.R. 91.9(c). This part provides: No person may operate a U. S. -registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. As stated above, there is no current registration process for UAS; and the UAS, due to its small size, does not have room to contain a fireproof pl acard or to display aircraft marks in a conventional size. However, as a condition to the grant of the exemption, AMK Services is willing to affix an aircraft mark to one or more of the "arms" of the UAS. The size of the marking will be determined by the size of the "arm" being used and may be less than one inch in size. 

### 3.1.6.3 **91.103: Preflight A ction**  AMK Services requests an exemption from 14 C.F.R. 91.103. This regulation requires each PI C to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the UAS, an exemption is needed. The PIC will take all actions following the DJI preflight inspection including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.U.S. Department of Transportation January 19, 2016

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### 3.1.6.4 **91.105: Flight Crewmembers at Stations** AMK Services requests an exemption from 14 C.F.R. 91.105. AMK Services requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the UAS carrying no flight crewmembers. However, to achieve an equivalent level of safety, AMK Services will not operate the aircraft unless the same PIC is at the controls at all times. 

### 3.1.6.5 **91.109: Flight Instruction; Simulated Instrument Flight and Certain Tests** AMK Services requests an exemption from 14 C.F.R. 91.109. Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that i s being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety is provided because the UAS will not carry pilots or passengers, and relevant landowners will have prior notice of each flight. 

### 3.1.6.6 **91.113(b): Right -** **of -**  **Way Rules** AMK Services requests an exemption from 14 C.F.R. 91.113(b) to the extent that it applies to overhead aircraft operating at or above 500 feet above ground level as the UAS will be operating no higher than 400 feet above ground level. This part provides:

 General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right - of -way, the pilot shall give way to th at aircraft and may not pass over, under, or ahead of it unless well clear. For example, if another aircraft is operating overhead at 10,000 feet above ground level, there is no danger posed to that other aircraft if the UAS is operating beneath 400 feet above ground level. However, as a condition to the approval of exemption, AMK Services will operate its UAS to see and avoid and give way to other aircraft that should enter airspace at or below 400 feet above ground level. 

### 3.1.6.7 **91.119: Minimum Safe A ltitudes**  AMK Services requests an exemption from 14 C.F.R. 91.119. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(c) prevents flying an aircraft at an altitude of less than 500 feet or operating an aircraft closer than 5 00 feet to any person, vessel, vehicle, or structure. As this exemption requests authority to operate at altitudes up to 400 feet, an exemption is needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 feet ab ove ground level. It will however be operated in a remote area on private property with the landowner’s consent. The equivalent level of safety will be achieved given the size, weight, limited speed of the UAS as well as the remote location where it is operated. No flight will be taken without the permission of the landowner or local officials. Because of the advance notice given to the landowner, all affected individuals will be aware of the planned flight. Compared to flight operations with aircraft or rotorcraft weighing far more than the three pounds proposed herein and the lack of flammable fuel onU.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 17 the UAS, any risk associated with the UAS operations is far less than those presently presented with conventional aircraft operating at or below 500 feet above ground level for environmental monitoring. In addition, the low - altitude operations of the UAS will ensure separation between these small -UAS operations and the operations of conventional manned aircraft that must comply with Section 91.119. 

### 3.1.6.8 **91.121 : A** **ltimeter Settings** AMK Services requests an exemption from 14 C.F.R. 91.121. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “. . .to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is requested. An equivalent level of safety will be achieved by the operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight as well as the operator receiving live feedback information about the UAS, including the height of the UAS, its forward velocity, and compass heading. The operator will be able to observe and control the maximum height of the UAS. Additionally, the UAS will be operated within the line of sight of the PIC. 

### 3.1.6.9 **91.151(a): Fuel Requirements for Flight in Visual Flight Rules (“VFR”) Conditions**  AMK Services requests an exemption from 14 C.F.R. 91.151(a). Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under visual flight rules conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended l anding and, assuming normal cruising speed:  During the day, to fly after that for at least 30 minutes; or  At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 25 minutes of powered flight making it impo ssible to meet the 30 minute reserve requirement in 14 C.F.R. §91.151. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined and remote area, a lower minimum battery power requirement in daylight or night VFR conditions is reasonable. AMK Services believes that an equivalent level of safety can be achieved by limiting flights to 25 minutes or 25 percent of battery power, whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited and remote operating area. 

### 3.1.6.10 **91.203(a) & (b): Carry ing Civil A** **ircraft Certification and Registration** AMK Services requests an exemption from 14 C.F.R. 91.203 (a) and(b). The regulation provides in pertinent part: Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:  An appropriate and current airworthiness certificate. . . .  No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 18 The UAS fully loaded weighs l ess than 3 pounds and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 

### 3.1.6.11 **91.215: A**

**TC Transponder and A ltitude Reporting Equipment and Use**  AMK Services requests an exemption from 14 C.F.R. 9 1.215. This section requires that installed Air Traffic Control (“ATC”) transponder equipment must meet specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder. There are presently no known commercially available ATC transponders that meet the payload requirements of a small UAS and are available at reasonable cost. However, because the UAS used by AMK Services will not be flying into or near airports, and will fly no higher than 4 00 feet above ground level, there is very low risk of collision with any manned aircraft. In addition, because there will be no need to have contemporaneous communication with Air Traffic Control, due to the short distances, short flight times, and restri cted altitude the UAS will operate within, AMK Services requests an exemption from this section. Additionally, the UAS is too small to contain ATC transponder equipment in any form that is known to be available commercially. 

### 3.1.6.12 **91.405 (a) & (d); 407 (a)(1); 409 (a)(2); 417(a) & (b): Maintenance**  **Inspections** AMK Services requests an exemption from 14 C.F.R. 91.405 (a) and (d); 407 (a)(1), 409(a)(2), and 417 (a) and (b). These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . .,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to AMK Services . Maintenance will be accomplished by the operator pursuant to the manufac turer’s Phantom 2 User Manual and Phantom Pilot Training Guide. An equivalent level of safety will be achieved because these small UAS are very limited in size and will carry a small camera and operate only in remote and restricted areas for limited perio ds of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet above ground level. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance , and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain the UAS in an airworthy condition to provide the equivalent level of safety. 

## 3.1.7 Summary for the Federal Register The following summary is provided for publication in the Federal Register in accord with 14 C.F.R. Part 11: AMK Services requests exemptions from the following rules: 14 C.F.R. 21, Subpart H; 14 C.F.R. § 43.7; 14 C.F.R. § 43.11; 14 C.F.R. § 45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.25; 14 C.F.R. § 45.27; 14 C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 C.F.R.U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 19 § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.203; 14 C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b) T o operate commercially a small unmanned aircraft vehicle (three pounds or less) to monitor, map, aerially photograph, survey and perform usual inspections by air of Communications Towers, Pipelines and other structures maintained and monitored by AMK Services. Allowing small UAS to be used for monitoring and inspection purposes enhances safety by eliminating risks associated with conventional surveillance operations, which traditionally use larger manned aircraft and must operate at low altitudes, weigh thousands of pounds, and car ry large amounts of fuel. Approval of the Exemptions, in contrast, would allow a battery operated small UAS weighing less than three pounds and no human passengers to complete the same job with virtually no risk. Under these conditions, the Phantom will provide an equivalent, if not higher, level of safety in the environmental surveillance field, which supports the grant of this Request and Application for Exemptions. 

# 4. **Privacy** All flights will occur over private or controlled access property with the landowner’s , local municipalities and DOT representatives prior consent and knowledge. No attempt will be made to identify any individuals filmed during the flights except in cases where those persons are conducting unauthorized activities, are trespassing upon the AMK Services conservation easement lands, or are damaging any towers or resources under the management responsibility of AMK Services , or interfering with any of AMK Services ’ inspection or monitoring operations. 

# 5. **Conclusion** Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security

– provide more than adequate justification for the grant of the requested Exemptions allowing AMK Services to use the Phantom for and during the management, research, and educational operations of AMK Services .U.S. Department of Transportation January 19, 2016

Request for Exemption For use of UAV Page 20 

# 6. **Exhibits Enclosed 6.1**  **Exhibit A -**  **DJI –**  **Phantom 2 User**  **Training Guide 6.2**  **Exhibit B -**  **DJI –**  **Phantom 2 User Manual**  **6.3 Exhibit**  **C -**  **DJI -**  **Phantom 2 Release Notes Dated**  **Feb 2015 6.4**  **Exhibit D -**  **Training Course Materials from Unmanned Experts**  **Training Facility 6.5**  **Exhibit E -**  **License and Pilot Information**  **fo r**  **Robert Bailey. Pilot for A MK Serv**  **ices**