C: \PROGRA~2 \Documentum \ CTS \docbases\ProDocbase\ config\tem p_sessio ns\2606369177301692253 \ 0900006481b75804.doc San Antonio Galves ton Austin Dallas

Zero/Six Consulting, LLC 1027 Tremont Galveston, TX 77551

409
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- 0090 (voice) 409
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- 0554 (fax) 866
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- 0090 (toll free) ATTN: Department of Transportation Federal Aviation Administration Washington, DC FROM: Bill Coltzer, Zero/Six Consulting, LLC 1027 Tremont Galveston, TX 77550 Fax: 409
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- 0554 Phone: 409
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- 0090 Email: bcoltzer@z6consulting.com RE: First Exemption Request for Zero/Six Consulting Under Section 333 of the F AA Modernization and Reform Act; FAA
- 2007
- 0001 Dear Sir or Madam: Zero/Six Consulting, LLC (ZSC) opened for business in April of 2003 in respons e to an industry wide need for firms with building envelope expertise. ZSC services include third party pier reviews, quality control programs, preparation of construction documents, construction contract administration, forensic Architecture, and “in hous e” testing. ZSC increases the design and construction quality in multiple phases of a project. This includes, but is not limited to, prevention, identification, and remediation in ensuring air and water tight facilities across Texas and Louisiana. ZSC’s services allow us to maintain better quality control of the testing process. We are dedicated to providing clients with excellent performance testing through our dedicated focus on building envelope commissioning. The objective for ZSC , as it pertains to this exemption we are seeking, is to use a small unmanned aircraft system (sUAS) for commercial purposes in order to ensure the safety of our employees and the public by assuring quality control inspection. The purpose of the s UAS is to increase the quality of the inspections being done while also increasing the safety of both the public and those employed at ZSC. In the attached document you will find:  Zero/Six Consulting’s formal request for exemption  Sections pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 of Title 14 C.F.R. form which we request exemption  The extent of relief sought  How granting said relief would be in the public’s best interest  The reason(s) granting the exemption would not adversely affect safety  A summary the FAA can publish in the Federal Register  Additional information to support ZSC’s request  A diagram/photos of the small unmanned aircraft system (sUAS) to be used by ZSC Thank you for the opportunity to present this petition for exemption and for your time and consideration. ZSC looks forward to your response. For any further questions or information necessary, ZSC can be contacted directly via email or phone number listed.www.z6consulting.com Sincerely,

Bill Coltzerwww.z6consulting.com This petitio n is to serve as Zero/Six Consulting’s official request for issuance of exemption under Title 14 C.F.R., Section 333. The specific sections of 14 C.F.R. from which we are seeking exemption are as follows :  Part 21, Subpart H: Airworthiness Certificates  §4 5.23 Display of Marks; General  §45.27 Location of Marks; Nonfixed
- Wing Aircraft  §91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft  §91.109 Flight Instruction  §91.119 (c): Minimum Safe Flight Altitudes; General  §91.121 Altimeter Settings  §91.151 Fue l Requirements for Flight in VFR Conditions  §91.203 (a) (b): Civil Aircraft Certifications Required  §91.409 Inspections **The extent of relief ZSC seeks, and t he reason ZSC seeks that relief:**  ZSC is seeking relief and exemption from the above listed Federal Aviation Regulations and any other applicable rules based on the decision to use a sUAS commercially in order to supply our clients, as well as the public, with thorough and complete building envelope inspection and analysis. Commercial use of sUAS is currently prohibited unless an exemption is granted. This request for exemption is based primarily on ZSC’s desire to maximize safety and efficiency in all of our inspection operations. **The reason why granting ZSC’s request would be in the public interest; that is, how it**  **woul d benefit the public as a whole:**  Itis ZSC’s mission to operate our sUAS in such a way that not only complies with the FAA regulations set forth by Title 14 of the Code of Federal Regulations (14 C.F.R.) but also to ensure our own standards of safety that both comply with and exceed those that are required
. We will employ and ensure methods of safe operations within the national airspace system. Our sUAS , should the exemption be granted, will be used by ZSC’s operator only for quality control inspections as well as detailed reporting and deficiency tracking. Our sUAS operations will be conducted in a controlled environment during daylight hours with specific regard to inclement weather conditions as well as heightened awareness of our s urroundings
. The sUAS will be flown at or below the required altitude so as not to pose as a threat to other aircraft. This will give way to an increase in the general safety of those involved in the development and construction of the buildings in questio n while also increasing the safety of the public. Use of a drone will allow ZSC to do a multitude of things that pertain to the exterior of buildings and roof tops. ZSC performs building envelope inspections in order to assure the structure of a building is safe and water tight. This helps to guarantee quality assurance during construction as well as air quality by reducing the risk of structural debris and the possibility of mold. With the use of a drone we will be able to efficiently collect real time d ata on the progress of a buildings development whether it be repairs, t esting, or general construction by inspecting roofs, windows, and outside walls of buildings. The drone will also allow ZSC to be able to identify potential hazards or quality issues in a safe and cost effective way. This is beneficial to the public in that is helps protect them from hazardous conditions involved when construction is being completed on any large structure that is exposed to outlying properties. It will also give us the ability to further protect those that will be inside the building by being able to eliminate risks associates with water infiltration. The use of a drone will allow safety measures to be implemented for our employees while furtherwww.z6consulting.com reducing the risk associated with repelling and climbing on high and sometimes unstable surfaces. These are risks that currently need to be taken in order to get a full scope of the building’s envelope structure. By eliminating the need for these actions to take place and replacing them with the use of a drone we are greatly reducing the risk of falling. This not only increases the safety of our employees but those within a general proximity of said building. Exemption approval would be in the public’s best interest because it will allow ZSC to enhance the efficiency and safety of their operations both economically and within society . It will allow for almost immediate detection of potential problems and issues within a building’s envelope before they become hazardous to the safety of the public. **The reason why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule**  **fro m which ZSC seeks the exemption:**  ZSC will implement strict safety protocols that adhere to the safety requirements put in place by the FAA. These protocols will be distributed via Zero/Six Consulting F light and Safety M anual to those who are to operate the sUAS. The manual will not be present on the aircraft as per §91. 9 (b) (2) limitations request due to the sUAS’s small size, but it will be available and present at ground level with the operator and PIC for safety reason s . Any and all operations to be performed by the sUAS will be done under controlled conditions to he lp ensure there will be no adverse impact on safety.  ZSC drone operations will be conducted as follows:

1. Only within the visual line of sight of the operator and have one or more visual observer (VO) 2. With clear verbal communication between the operator and VO 3. With all those involved in flight operations within 100 feet of said operation 4. At less than 4 00 ft. flight ceiling limit 5. Within the designated class G airspace 6. Not within 5 feet of an airport without proper notification to the necessary authorities bef

orehand 7. Flight may not exceed 40 mph  ZSC flight operations will be conducted as follows:

1. Operator and VO will inspect the sUAS before and after each flight
. 2. Flight operations will take place in controlled and supervised areas with clear communication between the operator and VO
. 3. No flight will be allowed to commence unless the weather and surrounding factors are conducive to a safe flight.  The DJI P hantom 2 Vision UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. The DJI P hantom 2 UAV has a maximum gross weight of approximately 2.5 pounds ( and the following technical and operational specifications: 1. Max Flight Speed
- 40 mph (The flights being conducted for observation/inspection of the exterior envelope will rarely exceed 10 mph) 2. Dimensions
- 29x29x18 3. 5.8 GHz remote controller 4. Includes a “no fly zone” feature; exceeding control range of remote will trigger “return home” and the drone will automatically fly back to takeoff point and land safely 5. Battery
- LiPo Smart Flight Battery 6. Flight time
- 25 minutes 7. Serial Number: BI262049413018www.z6consulting.com  The DJI Phantom 2 unmanned aircraft is equipped with four (4) propellers driven by f our (4) Lithium Polymer battery powered electric motors. Note: See attached for sUAS photos As you can see fro m the above listed drone description , ZSC’s drone fits the criteria and limitations set forth by the FAA
. Due to the weight, size, speed, operating capabilities, and general proximity to airports our sUAS ( Phantom 2 Vision) will not pose as a threat or haz ard to users of the national airspace system nor will it disrupt the general public in violations of privacy or sound. For the sake of privacy, if the area in which the sUAS inspection is to take place is heavily populated or in close proximity to private property the necessary steps will be taken in order to receive the proper permission to conduct said flight. In the event of a privacy issue in accordance with the Privacy Act Law for the state of Texas, ZSC will receive the proper permission and report it to the FAA before beginning flight operations. If there is a situation where the sUAS will be within 5 miles of an airport, our operator will provide the airport/air traffic control tower with prior notice of any flight operation that is to take place
. The reliefs being requested four ZSC will allow for safe and managed flights that help ensure a secure building envelope thus ensuring the safety of the public as well as those involved in said construction/development. **A summary the FAA can publish in t he Federal Register, s**  **i tting: (1) The rule from**  **which you seek exemption; and (2) A brief description of the n ature of the exemption**  **you seek:** 1. Petitioner: Zero/Sic Consulting, LLC 2. Sections of 14 C.F.R. Affected: Part 21, Subpart H; §45.23; §45.27; §91.9 (b ) (2); §91.109; §91.119 (c): §91.121; §91.151; §91.203 (a) (b); §91.409 3. Description of relief sought: Petitioner (ZSC) seeks relief from the requirements of 14 C.F.R. Part 21, Subpart H; §45.23 ; § 45.27 ; §91.9 (b) (2); §91.109 ; §91.1 19 (c): §91.121; §91.151 ; §91.203 (a) (b); §91.409 in order to be able to conduct commercial small unmanned aircraft system (sUAS) operations on site; subject to operating procedures that either meet or exceed those put in place by both the FAA and Zero/Six
. The sole purpose of the sUAS is to gather photo documentation in order to provide our clients with adequate building envelope inspections. Due to the size, weight, and intended use of the Phantom 2 Vision our operations pose no threat to the public and greatly reduces the risk of injury to our employees. **Any additional information, views, or arguments av ailable to support your request:**   As this is a small unmanned aircraft system weighing less than 3 pounds, no pilot or passengers can be carried and it does not contain flammab le liquids or explosive materials.  ZSC is currently in the process of receiving a drone liability insurance policy that will cover bodily injury and property damage . Proof of insurance can be submitted for documentation as soon as it is received if neces sary and drone operations will not begin until the policy is in place. 

###  ZSC is also in the process of registering our aircraft through the Aircraft Registration Branch and can submit proof upon request .www.z6consulting.com  The drone flight procedure and safety manual to be used by the operator and VO can also be submitted upon request.  The information provided in this petition serves as adequate justification for an exemption approval to allow Zero/Six Consulting, LLC to operate a sUAS commercially in order to provide accurate and safe building envelopes for the use and wellbeing of the public. **If you want to exercise the privileges outside of the United States, t**  **he reason why you need to do so:**  Zero/Six Consulting does not wish to exercise these privileges outside of the Unites States at this time.www.z6consulting.com 

### DJIPhantom 2 Visionwww.z6consulting.com