1

Mark Sherwood Sr

. Ma rk Sherwood Forensic Photographer 265 School Lane Springfield, PA 19064 610

- 506

- 1933 marksherwoodsr@gmail.com
November 18, 2015

U.S. Department of Transportation Docket Management Syst em 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9(b) (2); 91.103 (b ); 91.109; 91.119; 91.121; 91.151 (a); 91.203(a) & (b); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Mark Sherwood Sr. , owner and operator of small Unmanned Aircraft Systems ("sUAS") / small Unmanned Aerial Vehicle (“sUAV”) equipped to conduct aerial Search and Rescue Operations in the US to get higher success rates on (SAR) on operations and to help prevent contamination of lands if there was a manned aircraft accident. Along with municipal services for Delaware County Emergency Services Support, with the collectio n of motor vehicle accident scene data, h ereby applies for an exemption from the listed Federal Aviation Regu lations ("FARs") to allow commercial operation fits sUAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As described more fully below, the requested exemption would permit the operation of small Unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe opera tions in the Emergency S ervices / SAR presently using conventional aircraft.2

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "... establish requirements for the safe operation of such aircraft systems in the national airspace system for public safety ."

The name and address of the applicant is:

Ma rk	Sherwood	Forensic	Photographer Attn: Mark	Sherwood	Sr. Phone: 610

- 506

- 1933 Email: markshe rwoodsr@gmail.com Address: 265	School	Lane

Springfield,	PA	19064

The conditions proposed by the applicant are drawn from order 8900.1 CHG 0. Similar exemptions have been previously granted to a private, volunteer search and rescue group in Exemption #11282 and this request largely reflects those exemptions. Regulations from which the exemption is required 14	C.F.R.	Part	21	Subpart	H 14	C.F.R.	45.23(b) 14	C.F.R.	61.113	(a)	&	(b) 14	C.F.R.	91.7	(a) 14	C.F.R.	91.9	(b)	(2)	(c) 14	C.F.R.	91.103 14	C.F.R.	91.109 14	C.F.R.	91.119 14	C.F.R.	91.121 14	C.F.R.	91.151	(a) 14	C.F.R.	91.155 14	C.F.R.	91.203	(a)	&	(b) 14	C.F.R.	91.215 14	C.F.R.	91.405	(a) 14 C.F.R. 91.407 (a) (1) 14 C.F.R. 91.409 (a) (2) 14 C.F.R. 91.417 (a) & (b)3

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transpo rtation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:
•T he UAS s size, weight, speed, and operational capability• Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act Section 333 (a). Lastly, if the Secretary determines that such crafts "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 Section 333(c) (emphasis added) The Federal Aviation Act expressively grants the FAA the authority to issue exemptions. This statutory authority by i ts terms includes exempting civil aircraft, as the term is defined under section 40101 of the Act that includes sUASs, from the requirement that civil aircraft must have a current airworthiness certificate. Applicant interprets this provision to place the duty on the Administrator not only process applicants for exemptions under section 333, but for the administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the sta tutory requirements for approval. 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 U.S.C. Section 44701(f) see also 49 USC Section 44711(a); 49 USC Section 44704; 14 CFR Section 91.203 (a) (1). The Administrator has recently granted such an exemption under very similar circumstances (Exemption #11282). Mark Sherwood’ s multi rotor / quad copter sUAS’s weigh less than 55 lbs. including payload. They operate, under normal conditio ns at a speed of no more than 30 knots (34 mph) and in the case of our multirotors have a capability to hover, and move in the vertical and hori zontal plane simultaneously. They will operate in a line of sight and will operate only within the area made up of forest, county parks and open space, rural land, suburban land and power utility grid and towers. Given the small size of the sUASs involved and restricted sterile environment within which they will4

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the aut hority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissi ons and chemical spills, exemptions associated with allowing UASs for emergency service / public safety operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the req uested exemption without delay. AIRCRAFT AND EQUIVELANT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to 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 regulatory structure because the proposed operations represent a safety enhancement to the already safe agricultural services and crops dusted currently being u sed with conventional aircraft.
1. The sUASs will weigh less than 55 lbs.
2. Flights will be operated within visual line of sight of a pilot in command (PIC ) and /or visual ob server (VO).
3. Maximum total flight time for eac h operational flight will be 60 minutes for sUAS operations. Flights will be terminated at 25% battery power reserve.
4. Flights will be operated at an altitude of no more than 300 feet at speeds not to exceed 20 knots (34 miles per hour) or the maximum operating airspee d recommended by the aircraft manufacturer, whichever is less.
5. Minimum crew for each operation will consist of the sUAS Pilot and a Visual Observer.
6. The UAS will on ly operate within a confined "safe area" and have a "Security Perimeter” with in the f light operations area.
7. A briefing will be conducted in regard to the planned sUAS operations prior to each day's5

mission activities. It will be mandatory that all personal that will be performing duties within boundaries of the safe ty perimeter be present for this briefing.

8. The operator will obtain the consent of all persons involved in the flying area and ensure that only consenting persons be allowed within 100 feet of the flight operation, and this radius may be reduce d to 30 feet based upon an equivalent level of safety and determination. With the advanced permission of the FSDO, operations at closer range can be approved.
9. The operator will notify a Plan of Activities to the FSDO prior to proposed flights.
10. Pilot and observer will have been trained in the operation of UAS generally and received up

to
- date information on the particular UAS. Visual Observer and PIC will at all times be able to communicate by voice or radio.
11. Forensic Aerial Data & SAR operati ons will be launched from and/or oral permission from the relevant property holders or public safety officials will be obtained.
12. If the sUAS loses communications or it loses its GPS signal, the UAS will have capability to return to a pre
- determined locat ion within the Security Perimeter and land.
13. The sUAS will have the capability to abort flight in case of unpredictable obstacles or emergencies.
14. The owner shall follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limi t requirements for the aircraft and aircraft components.
15. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. 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 found to be in a c ondition for safe flight.
16. Any UAS that has undergone maintenance or alterations that 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 op erations under this exemption. Functional6

test flights may only be conducted by a PIC with a VO and must remain at least 250 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons or property.
17. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the P IC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. Dur ing training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled

- access property.
19. The UA must remain clear and give way to all manned aviation operations and activities at all t imes.

**14	C.F.R.	Part	21,	Subpart	H: Airworthiness**  **certificates	14	C.F.R.	Section	91.203	(a)	(1)** Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the issuance	of	airworthiness	certificates	as	required	by	FAR	S ection	91.203	(a)	(1).	Given	the	size and	limited	operating	area	associated	with	aircraft	to	be	utilized	by	the	Applicant,	an	exemption from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety	under	Part	11 and	Section	333	of	the	Refo rm	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed, operational	capability,	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	a	restricted	environment	and	under	the	conditions	proposed	will be	at	least	as	safe,	or	safer,	than	conventional	aircraft	(fixed	wing	or helicopter)	ope rating	with an	airworthiness	certificate	without	the	retractions	and	conditions	proposed. The	sUAS	to	be	operated	here	under	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor passenger,	carries	no	explosive	materials	or	flammable	materials	l iquid	fuels,	and	operates exclusively	within	a	secured	area	as	set	out	in	manual.	Unlike	other	civil	aircraft,	operations7

under	this	exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and, pursuant	to	the	requirements,	and	in	complianc e	to	l ocal	public	safety	requirements. The	FAA	will	have	advance	notice	of	all	operations.	These	safety	enhancements,	which	already apply	to	civil	aircraft	operated	in	connection	to	agricultural	aerial	applicators,	provide	a	greater degree	of	safety	to	public	and	property	owners	than	conventional	operations	conducted	with airworthiness	certificates	issued	under	14	C.P.R.	Part	21,	Subpart	H.	Lastly,	application	of	these same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	posed	by	the UAS,	due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	explosive	materials	or flammable	liquid	fuels,	and	inability	to	carry	a	substantial	external	load. **14 C.F .R. Section 45.23 (b). Marking of the aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the registration of the number is displayed on limited, restricted or in a light

- sport category aircraft or experimental or provisionally certified aircraft, the operator must also display on th e 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 spot," "experimental," or "provisional," as applicable. Even though the UAS wil l have no airworthiness certificate, and 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 sUAV, the two
- inch lettering will be impossible. The word "experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety wil l be provided by having the sUAS marked on it fuselage as required by §45.29 (f) where the pilot, observer a nd others working with the sUAS will see the identification of the
sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167A. 14 C.F.R. § 61.113 (a) & (b): Private pilots Privilege s and Limitations: Pilot in Command. Sections 61.113 (a) & (b) limit 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 req uiring the PIC operating the aircraft to have a sport pilot's Certificate rather than have than a commercial pilots Certificate to operate this small UAS. Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled w ith no living sole onboard. The8

area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth by in the S.O.P. The level of safety provided by the requirements included in the S.O.P exceeds that provide d by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with the operation of a commercial operations conte mplated with Part 61 when drafted, that allowing operations of the sUAS as requested with a recreational pilot as the PIC exceeds the present level of safety achieved by 14 C.P.R. §61,113 (a) & (b). **14 C.F.R. §91.7 (a): Civil Aircraft Airworthiness.** The regulation requires that no person may operate a civil aircraft unless it is in an airworthy condition. As there will be no airworthiness certificate issued for the aircraft. Should this should this exemption be granted, no FAA regulatory standard would ex ist for determining airworthiness. Given the size of the aircraft and the requirements contained in the SOP for maintenance and use of safety check lists prior to each flight and equivalent level of safety will be provided. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft**  Section 91.9 (b) (2) provides : No person may operate a U.S . registered civil aircraft for 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, approv ed manual material, markings, and placard, or any combination thereof

. The sUAS, 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 onboard, but because there is no ro om or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have access to it. The FAA has issued the following exemp tions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10602, 32827, and 10700. **14 C.F.R. § 91.103: Preflight action** This regulation requires each pilot in command to take certain actions before flight to insure the s afety of the flight. As the FAA approved rotorcraft flight manuals will not be provided as set forth in sections of the SOP. The PIC will take all actions including reviewing weather, flight battery requirements, landing and9

takeoff distances and aircraft performance data before initiation of flight.

**14 C.F.R. §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 ful ly functioning dual controls. sUASs and remotely controlled aircraft, by their design do not have fully functioning 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 functioning dual controls for a number of aircraft and for flight instruction in experimental aircraft. See exemption Nos.5778K & 9862A. The equivalent level of safety provided by that nei ther a pilot nor passengers would be carried in the aircraft and by the size and speed of the aircraft. **14 C.F.R. §91.119: Minimum safe altitudes** Section 91.119 establishes safe altitudes for operations of civil aircraft. Section 91.119 (d) allows helico pters to be operated at less than the minimums prescribed provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As exemption is for the sUAS that is a helicopter and the exemption requests authority to operate at altitudes of up to 400 AGL, or not more than 200 above an elevated platform such as radio towers, an exemption may be needed to allow such operations. As set forth by herein, except for the limited conditions stated in the SOP, the UAS will never operate higher than 400 AGL rotorcraft. It will however be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of sa fety 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 or local officials. Because of the advance notice to the property owner and participants in the activity, all affected individuals will be aware of the planned flight operations as set forth in the SOP. Compared to flight operations with aircraft or rotorcraft weighing more far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk of associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.10

**14 C.F.R. §91.121 Altimeter Settings** 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 sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equi valent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. **14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions**  Section 91.151 (a) prohibits and individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the sUAS provides approximately 20

- 40 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length at the most. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longe r time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compli ance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risk that Section 91.15l(a) was intended to alleviate given the size speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equival ent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.11

**14 C.F.R. §91.155: Basic VFR weather minimums** Section 91.155 establishes safe distances from clouds for flight visibility. All flights will be made in visual line of sight from the ground to an altitude of no more than 400 feet. The sUAS will never fly into or above the clouds while remaining within v isual line of sight. If cloud

- cover drops below the 500

-foot minimum, a sUAS can operate safely at a lower altitude. Given the size and speed of the small UAS, operating under these conditions should be sufficient to mitigate risk. Similar exemptions have been granted to other operations, including Exemptions 5357, 11208, 11112. **14 C.F.R. §91.203 (a)**  **and (b): Carrying Civil Aircraft Certification and Registration The regulation**  Provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them , to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9816A, and 10700

. **14 C.F.R. §91.215: ATC transpo nder and altitude equipment and use.**  Section 91.215 requires transponder equipment for aircraft within Class A, B and C airspace or within 5 nautical miles of an airport listed in Appendix D, section 1. MS intends to operate within the c ounty, a portion o f which lies within 5 nautical miles of Philadelphia International Airport ( PHL ). At it’s nearest
.12

A ll sUAS operations within Delaware County at an altitude of 400 feet AGL will not enter any Class A, B or C airspace. Additionally, ATC transponder equipmen t would exceed the payload capacity for the sUAS and make flight impossible. Given the size, speed and altitude restriction of 400 feet AGL, the sUAS can operate safely within Delaware County without entering or affecting aircraft in class A, B or C airspa ce. **14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (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 p aragraph (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 section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the application. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved beca use these small UASs are very 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 and will be operating from no higher than 400 feet. As pr ovided in the SOP, 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 preformed. Moreover, the operator is the person most familiar with the aircraft and bes t suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Pursuant to 14 C.F.R Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is nee ded: Applicant seeks an exemption from the following rules: 14	C.P.R.	§21,	subpart	H;	14	C.F.R	45.23	(b);	14	C.P.R.§§	61.113	(a)	&	(b);	91.7	(a);	91.9	(b) (2) ;	91.103 (b);	91.109;	91.119 ;	91.121;	91.151 (a);	91.203	(a)	and	(b);	91.405	(a);	91.407 (a)	(1) ;	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate	commercially	a	small	unmanned vehicle	(55lbs	or	less) Data	Collection	and	Emergency	Services/Public	Safety.13

Approval of exemptions allowing commercial operations of sUASs in the Emergency Services will enhance safety by reducing risk. Conventional operations using aircraft to operate at extremely low altitudes just feet from the equipment and structures; and present the risks associated with vehicles that weigh in the neighborhood of 3,000

- 5,000 lbs., c arrying large amounts of jet A or other fuel in most cases helicopters operating with 140 gallon fuel tanks. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation s of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the Part 21 and allowing commercial operations. These lightweight small UAV s operate at slow speeds, close to the ground and in sterile environment and, as a result, are far safer than conventional operations conducted with a piston and or turbine aircraft operating close to the ground.

Public Acknowledgement/PrivacyAircraft that are going to be covered are seen in Appendix A

Appendix A. DJI Phantom 3 Pro & Inspire 1 DJI Phantom 3 Pro14

DJI Inspire 1

Controller s Times 215

Ground Control Station

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012

- size,	weight, speed,	operating	capabilities,	proximity	to	populated	areas	and	or	close	proximity	to	airports and	operations	within	visual	line	of	sight	provides	more	than	adequate	justification	for	the grant	of	the	requested e xemptions allowing commercial operati on of applicant's UAS in the data imaging services industry.

Sincerely,

Mark Sherwo od Sr.
Ma rk Sherwood Forensic Photographer Delaware County Emergency Support Services