Electronic Submission

Monday, October 26, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as FMRA) and 14 CFR Part 11, UAV Flight Ops, LLC (herein referred to as UAV Flight Ops or Operator) hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of UAS for the acquisition of aerial data, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA.

As detailed in this document and the attached Appendix of UAS, the requested exemption would permit the operation of UAS platforms previously approved by the FAA for commercial operations in the United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) Reform Act.

The petitioner feels that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

The name and address of the applicant/ petitioner is:

UAV Flight Ops , LLC Captain Mark H Meyer, ATP CEO & Director of Flight Operations 10764 S. 93rd E. Ave. Tulsa, Oklahoma 74133-6176 Tel: 918-899-1932 Email: Director@UAVFltOps.com

Page of 1 21 

# UAV Flight Ops

An Unmanned Aerial Systems Service ProviderAUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections §44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the national airspace system without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:



## • The UAS’ size, weight, speed and operational capability;



## • Whether the UAS operates within the visual line of sight of the operator;



## • Whether the UAS operates outside of highly populated areas and away from close proximity to airports.

In addition, Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. 333(c).

Regulations from which the exemption is requested:

14 CFR 61.23(a) & (c) 14 CFR 61.101(e)(4) & (5) 14 CFR 61.113(a) & (b) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(1) & (2) 14 CFR 417(a) & (b)

Page of 2 21The Basis for Grant Request

Previously, the FAA has issued a Grant of Exemption No. 12646 to Measure, a 32 Advisors Company, LLC (see Docket No. FAA

− 2015

− 1602) in circumstances similar in all material respects to those presented in this petition. In addition, Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. (see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA

− 2014

− 0642), were granted based upon the enhanced safety achieved using an unmanned aircraft (UA) carrying no passengers or crew, rather than a manned aircraft, thus providing the FAA with good cause to find that the UAS operation was in the public interest.

BACKGROUND ON UAV FLIGHT OPS

UAV Flight Ops is an Unmanned Aerial Systems Service Provider

. It is owned, operated, and staffed by a group of highly experienced active and retired airline pilots.

UAV Flight Ops provides consulting services to a wide range of clients, highlighting current UAS technology applications. The UAV Flight Ops business model is predicated on the implementation of a means-end approach. Defining operational requirements, matching the appropriate technological UAS solution, developing business use case scenarios, and demonstrating the Return on Investment (ROI) for UAS operations in a number of industries. All with a goal of safely delivering specific, low risk, and cost effective actionable data to clients in a regulatory compliant manner.

UAV Flight Ops then services those needs by providing wet lease practical solutions appropriate for the client. The UAV Flight Ops custom solution approach allows each client to take advantage of the latest drone technologies in a safe, responsible and cost effective manner. Providing the client with the ability to safely match the needed aerial data collection instrument(s) with the most appropriate UAV for the job.

UAV Flight Ops was founded specifically to help clients avoid expense mistakes and large capital outlays. Assisting clients with crew selection, training and safety issues, regulatory burdens, while providing deferred liability from the operating risks naturally inherent when establishing their own drone programs. As a simple alternative approach, clients can purchase drone support operations in a way that better fits their operations and cost profiles. Ensuring standardized, regulatory compliant operations utilizing trained aviation professionals.

UAV Flight Ops believes in a risk-based and technology agnostic approach to operations in the national airspace. We believe that approval for any operation should be based on an analysis of the specific needs and the risks associated with a specific task and matching those needs with a fully integrated solution, operated by professionals.

Page of 3 21UAS AND OPERATIONAL DESCRIPTION

UAV Flight Ops seeks to commercially operate a variety of UAS weighing less than 55 pounds, including payload, in the United States for the purpose of acquiring aerial data. The Appendix attached to this exemption petition lists the aircraft that UAV Flight Ops contemplates offering to our clients and operating for them. In prior, similar exemptions the Secretary has approved every UAS platform included in the Appendix.

As the operator of these aircraft, UAV Flight Ops is committed to the following conditions and limitations on its operations. UAV Flight Ops understands that failure to comply will be grounds for the immediate suspension or rescission of any exemption granted.

1. Operations are limited to the UAS listed in the Appendix and those UAS previously approved by the Secretary when weighing less than 55 pounds including payload. Proposed operations of any aircraft not listed in the Appendix will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not contemplated and would require a new petition and exemption.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour) using either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s U.S. driver’s license.

6. All operations will utilize a visual observer (VO).

6.1. The aircraft will be operated within the visual line of sight (VLOS) of the PIC and VO at all times.

6.2. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations.

6.3. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight.

6.4. The PIC must ensure that the VO can perform the duties required of the VO.

7. All operating documents needed to operate the UAS and will be accessible during UAS operations and made available to the Administrator upon request.

Page of 4 217.1. The operator will also present updated and revised documents if it petitions for extension or amendment.

7.2. If a discrepancy exists between the conditions and limitations in any granted exemption and the procedures outlined in the operating documents, the conditions and limitations in any granted exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents.

7.3. The operator may, in the normal course of business, update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request.

7.4. The operator must also present updated and revised documents if it petitions for an extension or amendment to any previously granted exemption(s).

7.5. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) will be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that might affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption.

8.1. Functional test flights may only be conducted by a PIC with a VO present and must remain at least 500 feet from other people.

8.2. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

8.3. All functional test validations must be recorded in the aircraft’s maintenance log and signed off, electronically or otherwise, by the PIC conducting the tests.

9. The PIC is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for safe flight.

10.1. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment.

10.2. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary

Page of 5 21maintenance has been performed and the UAS is found to be in a condition for safe flight.

10.3. All maintenance and all component replacements, including payloads, must be recorded in the aircraft’s maintenance logbook.

11. UAV Flight Ops will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption will comply with all manufacturer safety bulletins.

13. The PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.

13.1. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.

13.2. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. UAV Flight Ops will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under any granted exemption.

14.1. Training will include skills necessary to safely acquire aerial data, and will include training on evasive and emergency maneuvers. With special focus on maintaining appropriate distances from persons, vessels, vehicles and structures.

14.2. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b).

14.3. UAV Flight Ops will operate flights for the purposes of training pilots, PICs and VOs, (training, proficiency, and experience building) and determining the PIC’s ability to safely operate the UAS.

14.4. Training operations may only be conducted during dedicated training sessions.

14.5. 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.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1.

15.1. All operations will be conducted under visual meteorological conditions (VMC).

Page of 6 2115.2. Flights under special visual flight rules (SVFR) are not authorized.

16. The aircraft will not operate within 5 nautical miles of an airport.

16.1. The 5 nautical mile distance is defined as a straight line distance from the airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart

. 16.2. Any flight within the above mentioned airport exclusion zone must be preceded by a letter of agreement with that airport’s management or as otherwise permitted by a COA.

16.3. In all cases, when flying within 5 nautical miles of an airport , two way radio communications must be established and maintained between the PIC and the appropriate controlling authority for the airspace in use, before takeoff and during all flight operations.

17. The aircraft 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 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the aircraft must returnto a pre-determined location within the bounds of pre approved controlledaccess property.

19. The PIC will abort the flight in the event of the intrusion of non-participants into the safety zone, degraded weather conditions, unpredicted obstacles, or other emergencies. The PIC will land at the safest location possible, in-point-of-time.

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power or fuel for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power or fuel recommended by the manufacturer if greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the blanket COA does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by UAV Flight Ops to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

Page of 7 2124. The UA will remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from a moving device or vehicle; however, specific requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

26.1. Barriers or structures are present that sufficiently protect nonparticipating persons vessels, vehicles or structures

. 26.2. The operator must ensure that nonparticipating persons remain under such protection.

26.3. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

26.4. The PIC, VO, operator trainees or essential persons will not be considered nonparticipating persons under this exemption.

26.5. An exception is requested when the owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

27. All operations conducted over private or controlled-access property will be conducted with the permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours.

29. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by UAV Flight Ops, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.

Page of 8 21The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates 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 operating with an airworthiness certificate without the restrictions and conditions proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, 2 inch lettering may be impossible. UAV Flight Ops will mark the UAS as practicable.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a UAS flight-training course.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The UAS has the ability to land safely, on a moments notice, in extremely confined spaces if necessary. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b).

14 CFR 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, UAV Flight Ops contemplates operating, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the operational restrictions put on the aircraft, an equivalent level of safety will be provided.

Page of 9 2114 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

. The UAS, given its 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 aircraft. The equivalent level of safety will be maintained by keeping the Operating Manuals at the ground control point where the pilot flying the UAS will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and landing distances, and all other actions in the Operating Manual and safety checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

By design, UAS 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 equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio signals from the controller and by the size and speed of the aircraft.

14 CFR 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will never operate at altitude higher than 400 AGL and all operations will occur during daylight hours under Visual Meteorological Conditions (VMC) only. The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner. Because advance notice to the property owner and any onsite personnel, as well as the precautions outlined below, all affected individuals will be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating persons (persons other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, unless operations do not present an undue hazard.

Page of 10 21The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be conducted at least 5 miles from an airport. The PIC or VO will provide notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an airport. The FAA will have advance notice of all operations through the filing of notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed herein, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the 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 may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of UAS during daylight hours in visual flight rules (VFR) conditions to continue until 90 percent of remaining battery power or fuel reserves remain. UAV Flight Ops seeks the requested relief because without an exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of any aerial acquisition of data that UAV Flight Ops proposes to conduct pursuant to this Petition.

The technical specifications of the proposed UAS, their Operations Manuals, and UAV Flight Ops’s proposed operating limitations, ensure that UAV Flight Ops will safely operate the selected aircraft during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, 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.

Page of 11 2114 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

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 UAV Flight Ops. Maintenance will be accomplished pursuant to the User Guide or Operating Manual. An equivalent level of safety will be achieved because these UASs are limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately in a very small space and will be operating from no higher than 400 feet AGL. The PIC 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 PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Furthermore, the Director Of Flight Operations will ensure that all UAV Flight Ops pilots adhere to UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. As well as strict compliance with all manufacturer safety bulletins.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances safety while reducing risk. Manned aircraft, in certain applications such as pipeline monitoring, create a greater risk because the aircraft are much larger and carry humans onboard. In contrast, a UAS weighing 55 pounds or less will carry no passengers or crew and, therefore, will not expose the UAS operators or people and property on the ground to the risks associated with manned aircraft flights. In addition, additional streams of aerial data will allow large commercial entities to make decisionsabout how to best deploy ground resources and ensure the safety and costeffectiveness of their operations.

EQUIVALENT LEVEL OF SAFETY

UAV Flight Ops proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current and proposed regulatory structure.

Page of 12 21PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue.

FEDERAL REGISTER SUMMARY

Docket No.: No. FAA-2015-____ Petitioner: UAV Flight Ops, LLC Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations (14 CFR).

Description of Relief Sought: UAV Flight Ops is seeking an exemption to conduct commercial acquisition of aerial data using unmanned aircraft systems.

Based upon the foregoing, UAV Flight Ops requests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform Act as requested herein to allow for commercial operations of UAS within the United States.

Sincerely,

Captain Mark H Meyer, ATP CEO & Director of Flight Operations UAV Flight Ops, LLC 10764 S. 93rd E, Ave. Tulsa, OK 74133-6176

ENCLOSURE - Attachment 1, Appendix of UAS - List of UAS platforms requested.

Page of 13 21Attachment 1

Appendix of UAS

The petitioner is requesting relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates and any associated noise certification and testing requirements of part 36.

In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the following aircraft and their operation

. Requested UAS platforms, are all previously approved by the FAA for commercial operations in the United States.

The following list of aircraft meet the conditions of Section 333

1. 2AgEagle 2. 3D Robotics Aero-M 3. 3D Robotics Iris 4. 3D Robotics Iris+ 5. 3D Robotics X8 6. 3DRobotics Fixed Wing 7. 3DRobotics Multirotor 8. 3DRobotics Quadrotor 9. 3DR Solo 10. 3DR Spektre 11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle 12. 3D Robotics Solo 13. 3DRobotics X8+ 14. 3D Robotics X8-M 15. 3D Robotics Y6 16. Aerial Mob Heavy Lifter 17. Aerial Mob Light Lifter 18. Aerial Remote Mineral Detection System (ARMDS) 19. Aerialtronics Zenith with intergrated Airware system 20. Aerialtronics Altura Zenith ATX8 21. Aerigon 22. Aerobo 23. AeroCine Kopterworx Hammer X12 24. Aeromao AeroMapper 300 25. Aeromao Talon 26. Aeromao Aeromapper 300 27. Aeromao Aeromapper EV-2 28. AeroVironment Shrike 29. AeroVironment Puma

Page of 14 21Appendix of UAS - Continued

30. Aeronavics X4 Titanium 31. Aeryon Sky Ranger 32. Aervonics Sky Jib frame with a DJI A2 flight system 33. Aero-M 34. Aeryon Scout 35. Aeryon SkyRanger 36. AgEagle 37. AgEagle Robotic 38. AgScout 39. AgScout Mini 40. Agribotix Hornet Drone 41. Agribotix Enduro Quad 42. AgriView VK Ranger EX 43. Aibot 44. Aibotix X-6 45. Air Rover AR-3000 46. AirCover QR-425s 47. AirRobot AR 180 48. AirRobot AR 100 49. AirRobot AR200 50. Air-X 51. Align M690 52. Altavian Nova 53. Altavian Nova F6500 54. Altavian Nova R8400 55. Altus X-4 56. Altus X-8 57. American Drones, LLC Eagle 58. Apprentice 59. Arch Aerial OCTO multi-rotor UAS 60. Arris hexacoper 61. AR-960 Hex Rotor 62. AR-540 Quad Rotor 63. ARF-MikroKopter OktoXL 64. ARF-MikroKopter OktoXL + 65. ArrowLite 66. AscTec Falcon 67. AscTec Falcon 8 68. Astraeus Aerial Cinema System V.3CS 69. Atlantic RC Aircraft LC04 70. Auburn Trimble UX5 71. Auburn War Eagle 72. Auburn EasyStar 73. Auburn

Page of 15 21Appendix of UAS - Continued

74. AV44 75. Bixler 3DR Plane 76. Blade 350QX 77. Bixler 2 78. Boomerang Carbon Fiber Frame (The Identified System) 79. Bormatec Maja UAV 80. BOSH Technologies Super Swiper 81. Bumblebee-S 82. C-Astral Bramor gEO 83. CarbonCore Octocopter 1000 84. Carbon Core Cortex Quadcopter 85. CCO w/Wkm M 86. Chameleon Pro 87. CinesStar 88. Cinestar 6 89. Cinestar X8 90. Cinestar 8 91. Cinestar 8 HL 92. Cinestar 8 Okto XL 93. Coaxial Quad Multirotor VAO1-V1 94. Coaxial Quad Multirotor VAO2-V2 95. CopelandRED LLC Delta Wing Aircraft 96. CyberQuad Maxi 97. DJI Flame Wheel F450 98. DJI Flame Wheel F550 99. DAx8 100. DJI Inspire 101. DJI Inspire 1 102. DJI Inspire 2 103. DJI M P330z 104. DJI Phantom 105. DJI Phantom 1 106. DJI Phantom 2 107. DJI Phantom 2+ 108. DJI Phantom 2 Vision 109. DJI Phantom 2 Vision+ 110. DJI Phantom Vision + 111. DJI Phantom 3 112. DJI Phantom FC40 113. DJI Spreading Wings S900 114. DJI Spreading Wings S1000 115. DJI Spreading Wings S1000+ 116. DJI S800 117. DJI S800 EVO

Page of 16 21Appendix of UAS - Continued

118. DJI T600 119. Draganflyer Guardian 120. Draganflyer X4ES 121. Draganflyer X4P 122. Draganflyer X6 123. DT-18 124. DYS D800-X8 125. Eagle VTOL 126. Eagle V2 127. E-Flite Apprentice 128. Event 38 E384 129. F-450 130. Falcon VTOL 131. Fire Fly 6 132. First Aerial Responder UAV 133. Flame Wheel G4 7.8 Skycrane 134. Flying-Cam 3.0 SARAH 135. Foxtech Kraken 130 V2 136. FreeFly Systems ALTA RTF 137. FreeFly Systems Octocopter Airframe (Legacy) 138. G4 139. G4 models 140. GeoStar 141. GerMAP G220 142. GerMAP G180 143. goFarm GF-1 144. Gryphon Dynamics X8 145. GT80X 146. Harris 18 HL 147. HEFF 148. Helicopters West DJI Inspire 149. Helicopters West SkyJib 8 150. Helios 960 151. Hawkeye Mk-III 152. HexaCrafter HC-1100 85. 153. HexaCrafter HO-1250 154. HH Blade 350QX2 AP 155. Hobbyking “Bixler” Fixed Wing Trainer 156. HoneyComb AgDrone 157. Horizon Hobby Blade 350 Qx2 quadcopter 158. Hoverfly LiveSky, BigSky 60 and H-Frame 159. Hubsan X4 micro drone 160. HVP 14301 Multi Rotor 161. Identified System

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162. IMT Global xFold Cinema 163. Indago 164. InovalDrone:Inova One 165. InstantEye Mk-2 166. InstantEye Mk-2 Gen2 167. Intuitive Aerial Aeragon 168. K130 Octocopter 169. KongCopter X8 170. Kopterworx Hammer X12 171. Latitude HQ-4 Hybrid Multirotor 172. LB700 173. Leading Edge Precision Vision 10 174. Leptron Avenger 175. Lewis Realty Associates Hexacopter 650 176. Liberty 1 177. Lockheed Martin Desert Hawk III 178. Lockheed Martin Indago 179. Matrix quad copter 180. MaxFlight 181. MD4-200 182. MD4-1000 183. Mikrokopter 2.5 184. MLB Company Super Bat 185. MU-1H 186. Multirotor G4 7.8 Skycrane 187. Nighthawk 188. Nighthawk VTOL 189. OktoXL 6S12 190. PAG X4 191. Parksone Radian RTF 192. Parrot Bebop drone 193. Parrot PF 725100 Bebop Drone 14MP 194. Parrot Skycontroller 195. Patriot X4 196. Patriot X8 197. Finwing Penguin V2 198. Birdseyeview FireFly 6 199. Phoenix 200. Phoenix VTOL 201. Phoenix 60 202. Phoenix 60LE 203. Pixhawk 204. Precision Drone Pacesetter 205. PrecisionHawk

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206. PrecisionHawk Hawkeye Mk-III 207. PrecisionHawk Lancaster 208. Precision Lancaster MK3 209. Prioria Hex 210. Prioria’s Maveric 211. Pulse Aerospace, PA 01 Vapor 212. Pulse Aerospace Pulse Vapor 35 213. Pulse Vapor 214. Puma AE DDL 215. PV 14817 Multi Rotor 216. PV HL1 217. PV HL2 218. Q1 219. Quadcopter LLC MikroKopter 220. Quiet UAV 221. Qube 222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. Multi Rotor 223. Frame Ronin Edition Microdrones:MD4-1000 224. RCTimer Hexacopter 225. RDASS 226. REHawk 500 227. REHawk 680 228. RF-70 229. Riegl RiCopter 230. RITEWING Z3 Spade 47” 231. Ritewing Drake 60” 232. RITEWING Z3 Spade 70” 233. RITEWING Z4 Spade 52” 234. RMAX 235. Roboflight 236. Rotomotion SR-15 237. RV Jet 238. Scout X4 239. SD02 240. Seahawk 1.2 241. SelectTech Geospacial’s EH-4 242. SenseFly eBee 243. SenseFly eBee RTK 244. SenseFly eXom 245. Sensurion Magpie MP-1 246. Service-Drone Recon One 247. Service-Drone Blackbird 248. SH 900

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249. ShadowHawk 250. Shrike 251. Sirius 252. SkyCatch 253. SkyJib 8 v.2 Heavy Lifter 254. SkyPhilly MI 255. Skywalker Aero 256. Skywalker Flying Wing X8 257. SnapRoll Media SUAS 258. Solutions Phoenix 30 259. SteadiDrone 260. Steadidrone Quad 261. Steadydrone QU4D 262. Steadidrone Mavik 263. SuperX/P2 Multirotor 264. Swift Radioplanes Lynx 265. Tali 500 266. Talon 120LE 267. Tarot FY690S Hexacopter 268. Tarot quadcopter 269. Tarot 680pro 270. Tarot 690 271. Tarot 900 272. Tarot 960 273. Tarot T-15 274. Tarot T15 C/F Folding Octocopter 275. Tarot T18 UAV 276. Tarot T690 277. Tarot T810 278. Tarot T960 279. Tarsier Systems MoAC 280. Tayzu Robotics Titan X8 281. TBS Discovery Pro 282. Team Black Sheep Discovery Pro Tarot T15 283. T-Rex 700E F3C 284. TREX 800E DFC PRO 285. Trimble UX5 286. Trimble UX5 hp 287. Trimble ZX5 288. Turningy Talon 500 289. TUP X8-800 290. Turbo Ace CINEWING 6 291. TurboAce Matrix-G quadcopter 292. Turbo Ace matrix-E

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293. Turbo Ace MATRIX-1 294. UAV Solutions Phoenix 60 295. Universeye Penguin 296. Unmanned Flying Rolling Orb “UFRO” 297. US2 GreenHawk 298. UtiliCopter ITX8 299. VA03-v1 300. VA04-v1 301. VA07-v1 302. Viking UAS Multicopter (VTOL) 303. Viking UAS FF-X4/X8 304. VK-Patriot X4/X8 305. Viking UAS Patriot X4/X8 Multirotor 306. Viking UAS X6 Model 800 307. Viking UAS Viking ONE 308. VK-450 309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 310. Viking VK-FF-X4 311. VK- Ranger EX- SAR Fixed Wing UAS 312. Volantex Raptor Tarot T-18 313. Volt Aerial Robotics Octane 314. Vulcan frame controlled by a DJI A2 flight controller 315. Vulcan Mantis 316. Vulcan Octocopter 317. Vulcan Raven 318. Vulcan UAV 319. Walkera TALI H500 320. Walkera Scout X4 321. Wookong DJI 5800 322. xCel Drones XD550CDR 323. XFold Rig Quadcopter 324. XFold Rig Hexcopter 325. XFold Rig Octocopter 326. XFold Rig x12 Copter 327 . X8-M

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