FAA Petition for Exception for “Imaging Mapping Technical Professionals, LLC”.

July 1 4 , 2015 U.S. Department of Transportation Docket management System 1200 New Jersey Ave., SE Wa shington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 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, “Imaging , Mapping & Technical Professionals, LLC”, h ere after referred to as IMTP , LLC being the operator of small Unmanned A ircraft Systems (UAS ) , seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in supplement attachment
. The requested exemption would permit commercial operation of IM TP , LLC ’s small UAS(s) wh ich weigh less than 55 lbs
. , fo r the purposes of aerial imaging , inspection, surveying and mapping
. The se aerial systems acquire a series of high quality digital images and /or video for referenc e and measurement applications, and as such reduc e the need for conventional aircraft. This has the additional benefit of reducing environmental impact as well as lower ing operational expenses for our customer base (e.g., real e state imaging , site inspect ion, environmental assessments, geo - spatial data acquisition etc. ). IM TP , LLC’s proposed o perations ( under the exemption ) will adhere to exacting requirements , under strict ly visual flight rules (VFR) and/or condition ( s ). It will in sure an equivalent level of safety to that of any currently authorized manned aircraft under modification by the FAA’s Section 333
. T he requested exemption would permit commercial imaging and remote sensing operations through off- the - shelf , professional aerial platforms from DJI ( www.dji.com ) and 3D Robotics (3drobotics.com)
. These small unmanned aerial system’s will be operated in strict adherence to all manufactures operational parameters and following all proposed part 107 provisions for small UAS. IM TP, L LC’s will utilize o perators w ho have passed an FAA approved ground school , possess an existing pilot certificate (e.g., Sport Pilot, Recreational P ilot, Private Pilot, Commercial, etc...) and have completed training on the UAS being operated.These small unmanned aerial systems possess automated control features , and will be within

visual sight of the respective operator in Class G airspace ; unless otherwise approved in advance by the FAA. Wi th the before mentioned in mind, IM TP, LLC respectfully submits that small unmanned aerial vehicles fro m DJI ( www. dji.com ) and 3D Robotics (3drobotics.com) could be used in lieu of comparatively hazardous conventional platforms and/or systems. IM TP, LLC believes that by approving the requested exemptions enhanced safety would be achieved , with additional economic benefits to the general public. IM TP, LLC further believes that said approval would ful fill the Secretary of Transportation ’s and FAA Administrator’s responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.” IM TP, LLC’s current mailing address & contact information is as follows: Imaging , Mapping & Technical Professionals, LLC Attn: Laura Malta Address: 209 Osborn Avenue, Point Pleasant Borough, NJ 08742 - 2225 Ph one : 732 - 267 - 1434 Email: lbmalta@imtprofessionalsllc.com The regulations from which the exemption is requested are as follows:  14 C.F.R. Part 21  14 C.F.R. 45.23(b)  14 C.F.R. 61.113(a) & (b)  14 C.F.R. 61.133(a)  14 C.F.R. 91.7(b)  14 C.F.R. 91.9(b)(2)  14 C.F.R. 91.109(a)  14 C.F.R. 91.119  14 C.F.R. 91.121  14 C.F.R. 91.151(a)  14 C.F.R. 91.203(a) & (b)  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) Very truly yours, Laura Malta , President & CFO Dr. Raymond A. Birchler Jr. GISP, CTO Cc: Supplement Attachment : Exemption s Request ed**Supplement A ttachment**  **- Part 1**  IM TP, LLC seeks exceptions similar to the excerpts here - after cited (“ APPLICABLE LEGAL STANDARD UNDER SECTION 333 “ ) and modified in passages from Aerial Pros LLC Exemption No. 11416 of ( Blairstown NJ 07825 ). At the time of this writing IMTP, LLC is aware of approximately thirteen existing exceptions granted in our operating area for similar purposes . They are as follows:

 Aerial_Media_Systems11297.pdf Lakes NJ 07417

 Aerial_Pros_LLC_11416.pdf Blairstown NJ 07825

 Air- Mods_Flight_Training_Center_Inc_11273.pdf Robbinsville NJ 08691

 Anderson_Rojas - Photography- 11708.pdf Califon NJ 07830

 Fovea - Aero - Systems - LLC - 11659.pdf Medford, NJ 08055

 Keystone_Aerial_Survey_11472.pdf PA

 Lauchit_Technologies_1 1411.pdf Rumson NJ 07760 & Haven NJ 07704

 Next - Generation_Aviation_Services_LLC_11311.pdf Ridgewood NJ 07450 & Park NJ 07035

 Nixon_Engineering_Solutions_LLC_11252.pdf Ft Monmouth

 Principia_Inc_11633.pdf Parsippany NJ 07054 & Orange NJ 07079

 The_Aerial_ Filming_Company_11362.pdf & Summit NJ 07902

 Unmanned_Aerial_Solutions_11445.pdf Wa ldwick NJ 07463

 Unmanned_Sensing_Systems_LLC_11356.pdf Unmanned_Sensing_Systems_LLC_11499.pdf Laurel NJ 08054**Supplement A ttachment**  **- Part 2**  THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 (as initial submitted via **Ae rial**  **Pros LLC & modified** via **IMTP, LLC** ) **IMTP, LLC** “ submits that grant of this exemption application for use of the proposed UAS's in aerial imaging will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into the national airspace system (“NAS” ) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the 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 UASs 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: ”

 ” The 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 oper ator”
.
“ Reform Act § 333(a)(1). If the Secretary determines that such vehicles ‘ 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) ‘’ Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow appr oval, to supply conditions for the safe operation of the UAS. **IMTP, LLC** too “

welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require modification ”
. “ The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must ha ve a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: ”

“ The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702 - 44716 of this title if the Administrator finds the exemption is in the public interest ”

“ 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority 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 and cost savings associated with transitioning to UASs for aerial inspections and survey photography. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. “ Airworthiness of the UAS

“A critical element of the exemption application involves evidence of the airworthiness of the UAS . The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act bothauthorize 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 . Our small UAS's will ope rate at low speed in a controlled environment, at least five miles from an airport and more than three miles from any city or densely populated area. 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 helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. ” Mandato ry Operating Conditions Grant of the exemption to **IMTP, LLC** will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Authoriz ation, with additional restrictions:  All operations to occur in Class G airspace.  Operations to be conducted over private or controlled- access property.  Permission from land owner/controller required before commencing any flight.  Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).  Aircraft to remain within Visual Line of Sight (VLOS). o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM). o Cylinder walls may be expanded by observer with ability to control aircraft.  Operations to occur during daylight hours.  Aircraft to remain within Visual Line of Sight (VLOS). o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM). o Cylinder walls may be expanded by observer with ability to control aircraft.  Above Ground Level (AGL) altitude to be restricted to 400 feet.  All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline az imuth of run way centerline measured from runway thresholds.  All required permissions and permits will be obtained from territorial, state, county or city , jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies
. Operator Requirements **IMTP, LLC** respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UASs, such as the DJI Inspire and DJI S1000, are characterized by a high degree of control and various built-in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. Please see details in the attached O&M manuals. Additional automated safety functions and safety enhancing features of the UAS 's include the following:  Auto - pilot detection of lost GPS or of insufficient satellites initiates an immediate return to aircraft take - off location ("home")  Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%levels.  If the auto -

pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure begins.Given these safety features; **IMTP, LLC** proposes that operators of the UAS should not be

required a specific pilot certificate . Instead, operators should be required to:  “ have successfully completed, at a minimum, FAA private pilot ground school instruction and passed a FAA written examination or FAA -recognized equivalents ” ;  “ have completed the sUAS training or a minimum of 40 hours training program for operation of the UAS 's ”
.  Either a FAA medical or state issued driver license. **IMTP, LLC** “

notes that the FAA has found that safety factors permitted operation of UASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20- 21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen’s certificates. 49 USC §44701 (f). ” **IMTP, LLC** seeks an exemption from the FARs set forth above and in this Supplement Attachment “

to allow commercial operations of a UAS 's conducting ” **aerial imaging, inspection, survey**  **ing and mapping**
.
“ Approval of the exemption allowing commercial operations of the UAS for” **aerial imaging, inspection, survey**  **ing and mapping work**  “ will enhance safety by reducing risk. Conventional aerial inspection and survey operations, using jet or piston - powered aircraft present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities o f fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. Other conventional manned climbing or manned lifts risk safety haz

ards associated with falls, electrical hazards, fuel related hazards, and inhalation ha zards associated with the structures being inspected. In contrast, a UAS weighing less than 55 lbs . and powered by batteries eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board a manned aircraft and the la ck of risks associated with manned lifts or manned climbing apparatus. The UAS will carry no passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights, manned lifts or climbing hazards. Addition ally, no national security issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the UAS poses no threat to nat ional security ”

.
“ The operation of the UAS, weighing less than 55 lbs ., for” **aerial imaging, inspection, survey**  **ing and mapping wo**  **rk** “ in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting ” **IMTP, LLC** “ from the requirements of Part 21 ”
.
“ The UAS ’s

satisfaction of the criteria set forth in Section 333 of the Reform Act
— size, weight, speed, operating capabilities, lack of proximity to ai rports and populated areas, operation within visual line of sight, and national security
— and its showing of an equivalent level of safety as it may relate to the requirement for FAA training, provide more than adequate justification for the grant of the re quested exemptions allowing commercial operation of the UAS in the commercial ” **aerial imaging, inspection, survey ing and**  **mapping wo**  **rk**
.**Supplement A ttachment**  **- Part 4**  EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY UNDER APPLICABLE RULES SUBJECT TO EXEMPTION **IMTP, LLC** “ requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the UAS 's” : 14 C.F.R. § 45.23(b): Marking of the Aircraft

“ The regulation provides: Wh en marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light - sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft ne ar 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- sport,” “experimental,”

or “provisional,”

as applicable. The UAS 's has 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 lettering will be impossible. The word “Experimental” will be placed on the forward fuselage in compliance with §45.29(f). The equivalent le vel of safety will be achieved by having the UAS marked on its forward fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Aerial Pros, Exemption No. 10700, and to others, including Exemption Nos. 8738, 10167 and 10167A ”
. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

“ Subpart H, entitled Airworthiness Certi ficates, 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 ” **IMTP, LLC**  , “ 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. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt a ircraft 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. Our small UAS 's will be operated at low spe ed in a co ntrolled environment ; at least five miles from an airport ” with a control tower or 3 miles from instrument approach or 2 miles, from other airports or heliports. “ An analysis of these criteria demonstrates that the UAS 's 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 helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed
. ”“ The UAS to be operated hereunder is less than 55 lbs . fully loaded, carries neither a

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operati on as is currently done on active construction sites. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with construction sites, power plant sites and the like provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credib le 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 ability to carry an external load no greater than two lbs. ” 14 C.F.R. § 61.113(a) & (b) ; 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.

“ Section 61.113(a) & (b) limit private pilots to non - commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UAS in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’ s license to be pilot in command of an aircraft for compensation or hire. ” **IMTP, LLC** “ respectfully proposes that operator requirements should take into account the characteristics of the particular UAS ”
. **IMTP, LLC**  “ UAS has a high degree of control and various built-in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption applicatio n ”
.
“ The UAS ha ve {sic} navigation and control system compr ised of a Ground Control Station (GCS) and auto - pilot system. All flights utilize precision GPS guidance. In the case of unplanned events, the operator inputs evasive maneuvers from the control unit, and the control unit executes that maneuver. Operator in terventions include diversion to the right; initiation of holding at present position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and land; and emergency power cut off and land (Flight Termination System). Given t hese safety features”. **IMTP, LLC** “ proposes that operators of the UAS should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: have successfully completed, at a minimum, FAA approved ground instruction and passed the FAA written examination or FAA -recognized equivalents; have completed a UAS training program or a minimum 40 hours training program for operation of the UAS”
. **IMTP, LLC** “ notes that the FAA has found that safety factors pe rmitted operation of UASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N- 8900.227, Unmanned Aircra ft Systems (UAS) Operational Approval, at 20- 21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations ”
. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the UAS without a {sic} commercial pilot’ s certificate, under the conditions set forth herein. The risks associated with the operation of the U AS (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminishedfrom the level of risk associated with private pilot operations or commercial operations

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under §61.133 (a). ” 14 C.F.R. § 91.7(a): Civil aircraft airworthiness. “ This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the UAS . Given the size of the aircraft and the requirements that have presumably already been met for the UAS (for instance, the UAS ’s Operations and Maintenance {sic} Manu al and Safety Manual and Checklist), an equivalent level of safety will be achieved by insuring compliance with the “ **IMTP, LLC** “

manuals prior to each flight ” 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

“ The regulation 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 Rotorcraf t Flight Manual, approved manual material, markings, and placards, or any combination thereof. (2) Given the size and configuration of the UAS, it 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 achieved by keeping the flight manual ( see , e.g. , User Guide, Exhibit 4) at the ground control point where the pilot flying th e UAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700 ”
. 14 C.F.R. § 91.109(a) & 91.319(a)(1): Fl ight Instruction

“ These regulations provide 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. The UAS is a remotely piloted aircraft and by design, does 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. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental a ircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the UX5. ”14 CFR § 91.119: Minimum Safe Altitudes

“ Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas . In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. As set forth herein, the UAS will never operate at higher than 400 feet AGL. It will, however , be operated to avoid congestion . Because ae rial survey work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed ”
.
“ The equivalent level of safety will be achieved given the size, weight, speed, and material with wh ich the UAS 's are built. Also, no flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of ” **aerial imaging, inspection, survey ing**  **and mapping** flights. Compared to “

**aerial imaging, inspection, survey ing and mapping**  **wo rk**  ” operations conducted with aircraft or rotorcraft weighing far more than 55 lbs . and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the lowaltitude operations of the UAS will maintain separation between these small - UAS operations and the operations of conventional aircraft that mus t comply with Section 91.119 ”
. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

“ This regulation 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 least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The UAS batteries provide approximately 15- 40 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the UAS ’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable. **IMTP, LLC also**  “ believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserv e fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting UAS flights to 20 minutes would greatly reduce their utility. In the unlikely event that the UAS should run out of fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation ”
. **IMTP, LLC also**  “

b elieves that an equivalent level of safety can be achieved by maintaining 5 minutes of reserve fuel , which, would be more than adequate to return the UAS to its planned landing zone from anywhere in its operating area ”

.14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

“ This regulation provides as follows: (a) . . . no person may operate a civil aircraft unless it has . . . 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 cabin or cockpit entrance so that it is legible to passengers or crew. The UAS 's fully loaded weighs no more than 55 lbs . As such, there is no ability or place to carry certification and registration documents or to display them on the UAS . In addition, there is no pilot on board the aircraft. 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. The FAA has issued numerous exe mptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. ” 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

“ Section 91.405(a) requires 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 . . . .” Section 91 .407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance wo rk that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. Maintenance of the UAS 's will be accomplished by the owner/operator pursuant to the manual. An equivalent level of safety will be achieved because the UAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached Maintenance Manual and the Safety Checklist, the operator of UAS will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. SUMMARY OF SECTION 333 EXEMPTION REQUEST **IMTP, LLC** “ hereby provides pursuant to Part 11 a summary of its exemption application to a llow commercial operation of : **DJI & 3D Robotics sUA** **S for aerial imaging, inspection,**  **survey ing and mapping**  **wo rk**  **.**
“ An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 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). ”