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time fra

EPS Gr

and wit

Lockhe

(a)). O

engend

given t

no pilot

UXS flig

event t

weight

the cur

EPS Gr

by mai

flight ti

landing

uivalent le

aterial wit

rmission o

vance noti

rvey fligh

t or rotorc

ny risk as

tly allowed

ndeed, the

en these 

t that mus

F.R. § 

tions 

gulation p

VFR con

ons) there

ssuming n

least 30 

s." 

XS batter

t an exem

to appro

ed operat

ame for fl

oup, Inc.

thin the s

ed Martin

perating t

der the ty

he size an

t, passeng

ghts to 20

that the U

and cons

rrent regu

roup, Inc.

ntaining

ime, woul

g zone from

evel of saf

h which th

of the land

ice to the

hts. Comp

craft weigh

ssociated 

d with co

e low-altit

small-UAS

st comply 

91.151(a

prohibits a

nditions u

e is enoug

normal cru

minutes;

ries provid

mption fr

ximately 

ions and t

ight in day

believes t

scope of a

n Corpora

the small

ype of risk

nd speed 

ger, or ca

0 minutes

UXS shou

struction m

lation. 

believes 

10 minute

ld be mor

m anywhe

Pa

fety will b

he UX5 is

d owner o

landowne

pared to a

hing far m

with thes

nventiona

tude opera

S operatio

with Sect

a): Fuel

an individu

unless (c

gh fuel to

uising spe

or (2) A

de approx

om§ 14 C

20 minute

the locatio

ylight VFR

that an ex

a prior exe

ation to o

UAS, with

ks that Se

at which 

argo also

s would g

ld run ou

material, 

that an e

es of rese

re than ad

ere in its o

age 7 of 10

be achieve

built. Also

or those w

er, all affe

aerial sur

more than

se operati

al aircraft

ations of t

ons and 

ion 91.11

l Requir

ual from b

onsidering

o fly to th

eed- (1) D

t night, t

ximately 

CFR 91.1

es in leng

on of thos

R condition

xemption f

emption. 

operate w

hout 30 m

ection 91

the UAS o

enhances

reatly red

t of fuel,

the risks

equivalent

erve fuel,

dequate to

operating

ed given t

o, no fligh

who contro

ected indiv

rvey oper

5.5 lbs. a

ions will 

operating

the UAS w

the opera

9. 

rements 

beginning 

g wind a

e first po

During the

to fly afte

50 minut

51, the U

gth. Given

se propose

ns is reaso

from 14 C

See Exem

without co

minutes of

.151 (a) 

operates.

 its safety

duce their

it would

are less 

level of s

 which, a

o return t

area. 

he size, w

ht will be t

ol the lan

viduals wi

rations co

and carryi

be far les

g at or be

will mainta

ations of

for Flig

"a flight 

and forec

int of inte

e day, to

er that fo

tes of po

UAS's flig

n the limi

ed operat

onable. 

CFR § 91.1

mption 10

ompliance

f reserve 

was mea

The fact 

y. Additio

r utility. In

simply la

than con

safety can

allowing 4

the UAS t

weight, sp

taken with

d. Becaus

ll be awar

onducted

ng flamm

ss than th

elow 500 

ain separa

conventi

ght in V

in an airp

cast wea

ended lan

fly after

or at least

owered fli

hts would

tations on

ions, a lon

151(a) is 

673 (allow

with 91

fuel does

nt to prev

that it car

nally, lim

n the unli

and. Given

templated

n be achie

40 minute

to its plan

eed, 

hout 

se of 

re of 

with 

able 

hose 

feet 

ation 

onal 

VFR 

lane 

ather 

ding

that 

t 45 

ight. 

d be 

n its 

nger 

safe 

wing

.151 

s not 

vent 

rries 

iting

ikely 

n its 

d by 

eved 

es of 

nned 
Trimble

100 UA

applica

Exempt

14 C.F

Regist

This reg

(a

a

(

c

a

e

The UX

or plac

on the 

An equ

the gro

access

A repre

9665, 9

14 C.F

Inspec

Section

that ai

betwee

section

.... " S

Section

airwort

to kee

accomp

records

Mainten

pursua

An equ

e holds an

AS and ap

tion. Sim

tions 2689

.R. § 91.

ration 

gulation p

a) ... no

ppropriate

b) No pe

ertificate 

uthorizati

entrance s

XS fully loa

e to carry

UAS. In a

ivalent lev

ound contr

to them. 

esentative

9789, 978

F.R. § 91

ctions 

n 91.405(

rcraft ins

en require

, have dis

ection 91

n 91.409(

hiness ce

ep record

plished by

s of approv

nance of

nt to the 

uivalent le

n Exempti

pplied for 

milar exem

9F, 5745,

203 (a) 

provides a

person m

e and curr

rson may

required 

on issued

o that it is

aded weig

y certificat

ddition, th

vel of safe

rol point w

The FAA h

e sample o

89A, 9797

1.405(a);

a) require

spected as

ed inspect

screpancie

.407 simi

a)(2) req

rtificate. 

ds showi

y certificat

val of the

the UXS

manuals,

evel of saf

Pa

on from t

such an e

mptions h

and 1067

& (b): Ca

s follows:

may oper

rent airwo

y operate

by paragr

 under §9

s legible to

ghs no mo

tion and r

here is no

ety will be

where the

has issued

of other e

, 9797A, 9

 407(a)(

es that a

s prescrib

tions, exce

es repaire

larly mak

uires an 

Section 9

ng certa

ed mecha

aircraft fo

S will be

 such as 

fety will b

age 8 of 10

this FAR, 

exemption

have been

73. 

arrying C

rate a civ

orthiness c

a civil a

raph (a) o

91.715 is d

o passeng

ore than 6

registratio

o pilot on b

e achieved

e pilot flyin

d numerou

exceptions

9816A, an

(1); 409(

n aircraft

bed in su

ept as pr

d as pres

kes referen

annual in

91.417(a) 

in maint

anics, unde

or return t

e accomp

Exhibit 3,

be achieve

Exemptio

n for the U

n granted

Civil Aircr

vil aircraf

certificate

ircraft un

of this sec

displayed

gers or cre

6 lbs. As s

n docume

board the

d by keepi

ng the UA

us exempt

s includes

nd 10700.

(a)(2); 4

operator

ubpart E 

rovided in

cribed in 

nce to req

spection 

requires 

tenance w

er Part 43

to service

plished by

, provided

ed becaus

on No. 108

UXS as pa

d to othe

raft Certi

ft unless 

. 

nless the 

ction or a

at the ca

ew. 

such, ther

ents or to

aircraft. 

ng these 

AS will ha

tions to th

Exemptio

417(a): M

r or owne

of this p

n paragrap

part 43 o

quirement

for the is

the owne

work tha

3, or licens

e. 

y the ow

d by the m

se the UA

808 for it

art of its 

ers, inclu

ification 

it has ..

airworthin

 special f

bin or coc

re is no ab

display t

document

ve immed

his regulat

on Nos. 95

Maintena

er "shall h

art and s

ph (c) of

of this cha

ts in Part

ssuance o

er or oper

at has b

sed pilots

wner/oper

manufactu

AS is sma

ts XSAC 

ding

and 

. an 

ness 

light 

ckpit 

bility 

hem 

ts at 

diate 

tion. 

565, 

ance 

have 

shall 

this 

apter 

43; 

f an 

rator 

been 

and 

rator 

urer. 

all in 
size, w

predete

the att

reviewe

ensure

require

Moreov

best su

an equ

The UX

every 5

mainte

replace

to its la

2. The

inte

The gra

clear d

the Fed

surroun

includin

UASs fo

3. The

or h

equ

exe

Approv

precisio

Conven

present

5,000 t

in some

In cont

elimina

combus

not flow

will not

flights.

will carry

ermined a

tached Ma

ed as par

that the

d mainten

ver, the o

uited to m

ivalent lev

XS's Main

50 hours o

nance req

ements, sh

aunch site

 reasons

erest; tha

ant of the

irection in

deral Avia

nding the

ng enhanc

or aerial s

 reasons

how the

al to th

mption. 

al of the

on survey

ntional ae

t risks as

to 7,000 l

e cases, c

trast, a U

ates a po

stible fuel

wn there.

t expose 

y no ext

reas and 

aintenanc

rt of Trim

UAS is i

nance, and

perator is

maintain th

vel of safe

tenance M

of flight. T

quirement

hould a m

 or immed

s why g

at is, how

e requeste

n Section 

tion Act, 

e propose

ced safety

survey pho

s why the

exempti

hat provi

exemptio

and phot

rial surve

ssociated 

bs., or mo

cargo. Suc

UX5 weig

ortion of 

carried o

 The UX5

any indiv

Pa

ternal pa

is not a co

e Manual

mble's SA

n working

d keep a l

s the pers

he aircraft

ety. 

Manual p

This will e

ts in Part

mechanical

diately lan

ranting t

w it would

ed exempt

333 of th

as amend

d operati

y and cost

otography

e exempt

ion woul

ided by 

on allowin

tography w

ey operatio

with veh

ore, carry

ch aircraft

hing less

that risk

on board. T

5 will carr

viduals to

age 9 of 10

yload, w

omplex m

l and the

AC applica

g order p

log of any

son most 

t in an air

rovides fo

ensure an

91. In a

 issue aris

nd. 

the requ

d benefit

tion is in 

he Reform

ded; the s

ons; and

t savings

y and map

tion woul

ld provid

the rule

ng comme

work will e

ons, using

icles that

large qua

must fly 

 than 6 

k given t

The UX5 i

ry no pass

the risks

will opera

mechanical

e Safety 

ation, the

prior to in

y maintena

familiar w

rworthy c

or replace

equivalen

addition, b

se, the ai

uest wou

the publ

the public

m Act; the

strong eq

d the sign

associate

pping. 

ld not ad

de a leve

e from w

ercial ope

enhance s

g jet or p

t weigh in

antities of

to and fro

lbs. and 

he reduc

is carried

sengers o

s inherent

te only 

l device. A

Checklist,

 operator

nitiating fl

ance that

with the a

ondition a

ement of

nt level of

between s

rcraft will

uld be in

lic as a w

c interest

additiona

uivalent le

nificant p

ed with tr

dversely a

el of saf

which y

rations of

safety by 

piston-pow

n the nei

f fuel, pas

om the su

powered

ed mass

to the su

or crew an

t with ma

in restri

As provide

, which w

r of UXS

ight, perf

is perform

aircraft an

and to en

the airfr

f safety to

such airfr

 either re

n the pu

whole. 

based on

al authorit

evel of sa

ublic ben

ansitionin

affect saf

fety at le

ou seek

f the UXS

reducing

wered airc

ghborhood

sengers, a

rvey locat

by batte

and lack

rvey locat

nd, theref

anned airc

cted 

ed in 

were 

will 

form 

med. 

nd is 

sure 

ame 

o the 

ame 

eturn 

ublic 

n the 

ty in 

afety 

nefit, 

g to 

fety 

east 

an 

S for 

risk. 

craft 

d of 

and, 

tion. 

eries 

k of 

tion, 

fore, 

craft 
Additio

request

it oper

materia

UX5, w

strict c

support

exempt

The UX

Act-size

and po

security

the re

justifica

operati

photog

4. Any

sup

EPS Gr

our clie

With th

govern

manne

concern

will dra

data co

a lesse

Group t

on an i

If have

Very tr

Mary K

EPS Gr

2045 S

Mesa, A

nally, no

ted exemp

ates, and

als, the UX

weighing le

conditions

ting the 

ting EPS G

X5's satisf

e, weight,

opulated a

y-and its 

equiremen

ation for t

on of th

raphic bus

y additio

port you

roup, Inc.

ents with

his Exemp

ment clien

r will tran

ns for our

amatically

ollection. W

er expense

to create 

mmediate

 any ques

uly yours,

ennedy, R

oup, Inc. 

. Vineyard

Arizona 85

national

ptions. Giv

 the fact

X5 poses 

ess than 6

outlined 

grant o

Group, Inc

action of 

, speed, 

areas, op

showing o

nt for a

the grant

he UX5 i

siness. 

onal info

r request

values th

inexpens

ption, EPS

nts, the c

nslate dir

employee

decrease

We will be

e than pr

more tech

e and ongo

stions, ple

,

RLS 

d Avenue,

5210 

Pa

 security

ven the si

that it c

no threat

6 lbs., for

above, w

of the ex

c. from the

the criter

operating

peration w

of an equ

pilot's 

of the re

in the co

rmation,

t. 

he safety 

sive, yet 

S Group w

ost saving

rectly to 

es who cu

e with the

e able to p

revious m

hnically ad

oing basis

ase conta

, Suite 10

ge 10 of 10

y issue is

ze, load c

carries no

to nation

precision

will provid

xemptions

e requirem

ria set fort

 capabiliti

within vis

ivalent lev

license, 

equested e

ommercia

views, 

of our em

highly de

will be ab

gs and eff

cost savin

urrently co

e impleme

provide ou

methods. T

dvanced j

s. 

ct the und

1 

s raised 

carrying ca

 explosive

nal securit

n surveys 

de an equ

s reques

ments of P

th in Sect

ies, lack o

ual line o

vel of saf

provide 

exemption

al precisio

or argu

mployees 

etailed aer

ble to acc

ficiency of

ngs for t

ollect data

entation o

ur Clients

This techn

ob positio

dersigned

by the 

apacity, sp

es or oth

y. The op

in accord

uivalent le

sted here

Part 21. 

tion 333 o

of proximi

of sight, 

fety as it 

more th

ns allowin

on aerial

uments a

and desir

rial mapp

complish b

f collectin

he tax p

a on some

of this saf

with mor

nology wi

ons within

. 

grant of 

peed at w

er dange

eration of

ance with

evel of sa

ein, inclu

of the Ref

ity to airp

and nati

may relat

an adeq

g comme

survey 

available

res to pro

ping produ

both. For

g data in

ayers. Sa

e difficult s

fer metho

re product

ll enable

the comp

the 

which 

rous 

f the 

h the 

afety 

ding

form 

ports 

onal 

te to 

uate 

ercial 

and 

e to 

ovide 

ucts. 

our 

this 

afety 

sites 

od of 

ts at 

EPS 

pany