January 21, 2016

Branden Granger Granger Aerial Services Owner: Branden Granger 5370 W Patricia Dr

. Connersville, IN 47331 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 9 1.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 201 2 (the “Reform Act”) and 14 CFR Part 11, Branden Granger, operator of an Unmanned Aircraft System (UAS ), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operat ion of its UAS, so long as such operations are conducted within and under the conditions outlined herein or a s may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, arch itecture, land surveying, engineering and other related professional activities.
 Aerial video and/or photography for public and/or private use including television, public events, cinematography and newsgathering.
 Aerial inspection/photography of residenti al/commercial structures under contract with the owner or local government authority. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.
 Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.
 The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property. As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enh ancements to the already safe operations in the industry presently using conventional aircraft. 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.” (continued next page)The name and address of the applicant is:

Granger Aerial Services Attn: Branden Granger, Owner/Chief Pilot Email: branden.granger@icloud.com Address: 5370 W Patricia Dr. Connersville, IN 47331 Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) s 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) We are petitioning for exemption to enable Granger Aerial Services to operate a DJI In spire 1 equipped with a three

- axis gimbal and using High

- Definition camera. This UAS has a built

- in capabili ty to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator an d to exclude it from flying in Cl ass A, B, C, and D airspace including a no

-fly zone feature near smaller airports . The Inspire 1 also has the fail

-safe function of the Naza

- M autopilot system, which means when the communication between the Main Co ntroller and the transmitter is disconnected, the GPS equipped DJI Inspire will automatically trigger a Return to Home function and will land safely. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a ma ximum speed of approximately 42 knots. The DJI Inspi re 1 UAS is equipped with four main rotors; driven by Lithium Polymer b attery powered electric motors. Given the small size of the UAS and the controlled environment provided the proposed operations would adhe re to the Reform Act’s safety requirements. The approval of this application presen ts no national security issues. Regarding the level of safety surrounding the proposed operations and t he public benefit, reduction in e nvironmental impacts, including but not limited to reduced emissions and no ise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests t hat the FAA grant the requested exemption with minimum delay.

**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further e nhance the safety of the persons and/or property using conventional aircraft.These limitations and conditions to which the applicant agrees to adhere to when conducting

commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.
 The UAS will have a maximum operating speed of no more than 40mph.
 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).
 Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve or 20 minutes of flight time whichever occurs first.
 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.
 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.
 The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary certifications currently being approved by the FAA administration for commercial use.
 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.
 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.
 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.
 The DJI Inspire 1 has built in software for all FAA regulated ‘No Fly Zones’ and is updated by DJI on a regular basis . This i s checked prior to any flight to prevent any possible flights occurring within no

-fly zones.
 DJI Inspire 1 has installed software (code) that denies flights within the FAA no

-fly zones. If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.
 The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation.
 The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety dete rmination, as required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.
 The PIC and VO will have been trained in operation of UAS and receive up

-to
- date information for the particular UAS to be operated.
 The PIC and VO will b e able to communicate by voice or radio at all times.
 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmenta l agencies.
 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.
 The UAS will have the capability to abort a flight in case of un predicted obstacles, weather, or emergencies.**14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)**

Subpart H, entitled Airworthiness Certificates, establishes the procedural requiremen ts 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 the Applicant, an exemption from Part 21 Subpart H meets the requirements of an e quivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act b oth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upo n considerat ion of the size, weight, speed, operational capability, and proximity to airports and populated areas of the p articular 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 (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully load ed, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, an d operates exclusively within a secured and designated area. Unlike other civil aircraf t, operations under this exemption will be tightly controlled and monitored by both the operator and under the requiremen ts and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancemen t s provide a greater degree of safety to the public and property owners than co nventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. La stly, application of these same criteria demonstrates that there is no credible threat to national security pos ed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flamma ble liquid fuels, and inability to carry a substantial external load.

 **14 C.F.R. § 45.23 (b). Marking of the Aircraft**  The 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 o r experimental or provisionally certificated aircraft, the ope rator 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 in ches high, the words "limited," "restricted," "light

-sport," "experimental," or "provisional," as appli cabl e. Even though the UAS will have no airworthiness certificate, an exemption will 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, two

- inch l ettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will se e the identification of the UAS as “Experimental.”**14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in**

**Command.** Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensati on or hire. An equivalent level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or pa ssengers nor property. The risks attendant to the operation of UAS is far les s than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limita tions set forth in the FOM will equate to the safe operation of the UAS

. **14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.** The regulation requires that no person may operate a civil aircraft unless i t is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, shoul d this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an 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 ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapte r, unless t here 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 size and configura tion has no ability or place to carry such a fligh t 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 flight manual at the ground control poin t where the pilot flying the UAS will have immediate access to it. **14 C.F.R. § 91.103: Preflight Action.** This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft fligh t manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre -flight inspection section, including but not limited to reviewing weather, flight battery requirements, la nding and 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 flig ht 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 t he 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 prov ided by the fa ct that neither a pilot nor passengers will 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 operation of civil aircraft. Sectio n 91.119 (d) all ows helicopters to be operated at less than the minimums prescribed, provided the person op erating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this e xemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up t o 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exempt ion may be needed to allow such operations. As set forth herein, the UAS will never operate at highe r than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however b e operated in a restricted area with security perimeter, where b uildings and people will not be exposed to operations without their pre

-obtained consent. The equivalent l evel of safety will be achieved given the size, weight, speed of the UAS as well as th e 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 filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weig hting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated wi th 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 UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.
**14 C.F.R. §91.121 Altimeter Settings.** This regulation requires each person operating an aircraft to maintain cruis ing altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropri ate altimeter setting avai lable before departure.” As the UAS may not have a barometric altimeter, but inst ead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site sh own 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 an 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 lea st 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 18 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 mi nutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasona ble. Applicant believes that a n exemption from 14 CFR §91.151(a) falls within the scope of prior exem ptions. Operating the 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 minu tes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sm all UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption w ill be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power

— whichever happens first. Thisrestriction would be more than adequate to return the UAS to its planned landing zone from anywhere

in its limited operating area.
**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 airwo rthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate re quired by paragraph (a) of this section or a special flight au thorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no mo re than 55 lbs. 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 wi ll be achieved by keeping these documents at the ground control point where the pilot flying the UAS will ha ve immediate access to them; to the extent they are applicable to the UAS.

**14 C.F.R. §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 a ircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragra ph (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 applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating h andbook. An equival ent level of safety will be achieved because the UAS is very limited in size and will ca rry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues ari se the UAS can land immediately and will be operating fro m no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, an d keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the airc raft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety . An equivalent level of safety will be achieved because maintenance and inspections will be perfo rmed in accordance with the UAS Manufacturer' s User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

**Public Interest** Manned aircraft conducting aerial photography/videography can weigh 6,000 pounds or more and contain one or more individuals on board. Granger Aerial Service’s UAV will weigh le ss than 7 pounds and contain no living crew (the PIC and VO being remotely located from the UAV). The limit ed weight significantly reduces the potentia l for harm to participating and nonparticipating individuals or property in the event of an incident or accident. There is no risk to an onboard crew while using a UAV.Traditional manned aircraft contain highly flammable fuel and are at risk of fuel sp illage and fire in the

event of an incident or accident. The battery

- powered Inspire 1 carries no fuel, eliminat ing this fire and environmental risk. Traditional aerial photography/videography operations using conventional aircraft can operate in very cl ose proximity to persons and property on the ground. While the FAA mitigates these ris ks in a variety of ways, the proposed UAS operations would reduce risks even further due to the limited size, weight, speed, operating conditions, and safety features of the Inspire 1. Furthermore, as Congress outlined in the FAA Modernization and Reform Act, integration of UAS into the National Airspace System is inherently in the public interest, as long as it can be accomplished safely. As described above, not only will the proposed UAS operations provide an equiva lent level of safety to current operations
– they will actually provide a greatly improved level of safety t o construction managers and the general public.

**Conclusion** Granger Aerial Services seeks exempt ion from the FARS outlined above in order to commercially operate a small UAV that weighs less than seven pounds for the purposes described above. The operation of the UAS described herein, under the strict conditions outl ined above and in the operating d ocuments, will provide an equivalent level of safety to support the grant of the requested exemptions. Please do not hesitate to contact me if you have any questions or concerns. Sincerely, Branden Granger Owner, Granger Aerial Services