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July 6 , 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and specified parts under 14 CFR, 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 CFR . Part 11, Sully Enterprises , LLC, an operator of Unmanned Aircraft Systems (“ UASs ”) for aerial im age acquisition hereby applies for a n exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs

. On or about July

2, 2015 , the FAA granted exemptions to seven hundred thirty
-three UAS operators. It is in good faith and without consul that this exempt ion request will follow the same outline of the exemptions granted for the same general intents and purposes to commercially operate UASs. This application is submitted by: Company: Sully Enterprises, LLC Owner : Wi lliam Sullivan, Jr Address: 441 Ridge Brooke Drive Douglasville, GA 30134 Phone: 404.790.4451 Em ail: billsul@mindspring.com Sully Enterprises , LLC's requested exemption would permit the operation of UAS under controlled and secure conditions that is: (i ) lim ited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safety in connection with aircraft o perations. As established by the exemptions already granted by the FAA, approval of Sully Enterprises , LLC's exemption would enh ance 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.” Section 333(c) of the Reform Act. Regulations from which the exemption is requested: 14 CFR 21 14 CFR 91.119 14 CFR 91.407 (a)(1) 14 CFR 45.23(b) 14 CFR 91.121 14 CFR 91.409 (a)(2) 14 CFR 45.27 14 CFR 91.151(a) 14 CFR 91.417(a) & (b) 14 CFR 45.29 14 CFR 91.203 14 CFR 91.715 14 CFR 61.113(a) and (b) 14 CFR 91.205 14 CFR 91.9 (b)(2) 14 CFR 91.215 14 CFR 91.103 14 CFR 91.405 (a) 14 CFR 91.109
UASs operated by Sully Enterprises , LLC weigh less than 55 pounds, including the payload (i.e. cam era, lens, and gimbal ). They operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Sully Enterprises , LLC will only operate its UASs in line of sight operations . Such operations will insure that the UAS will “not create a hazard to users of the national airspace s ystem or the public.” Given the small size of Sully Enterprises , LLC's UASs and the restricted secure environment within which they will operate, Sully Enterprises , LLC's UAS operations adhere to the Reform Act’s safety requirements.

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Additionally, due to the size of the UASs , permission from relevant property owners or other applicable parties, and the limited areas in which they will operate, approval of this application presents no national s ecurity issues. Based on the substantial level of safety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant of the requested exemption is in the public interest. Accordingly, Sully Enterprises , LLC respectfully requests that the FAA grant the requested exemption. Aircraft a nd Equivalent Level Of Safety The operating limitations proposed by Sully Enterprises , LLC provide for at least an equivalent or higher level of safety because operations further enhance safety of aerial image collection using conventional aircraft. The limitations and conditions include:

• Owner holds a BA from Embry
- Riddle Aeronautical University in Fixed Based Operations (FBO).

• The UAS will weigh less than 55 pounds

. • Flights will be operated within line of sight of a pilot and/or observer.

• Maximum flight time for each operational flight will be no more than 30 minutes. Flights will be terminated at no less than 25% battery power reserve should that occur prior to the 30 minute lim it.

• Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will co nsist of the UAS Pilot, the Visual Observer, and the Camera Operator.

• A UAS pilot will be Pilot in Command (PIC).
 A briefing will be conducted for planned UAS operations prior to each day’s flight. All personnel performing duties within the boundaries of the safety perimeter are required to attend.
 The Pilot and observer must be trained in UAS operations.
 The Observer and pilot will be in communicat ions at all times.

• All appropriate permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

• If the UAS loses communications or loses its GPS signal, th e UAS will have the capability to return to a pre
- determined location within the secure perimeter and land.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or em ergencies.
14 CFR 21: Certification Procedures F or Produ cts and Parts This regulation is designed for manned aircraft. It is not suitable for off

– the
- shelf or production UAS . All parts come from the manufacturer. Substantive replacement parts (i.e. motors, propeller blades, radio transmitters, etc.) also come from the manufacturer or an authorized vendor with approved after
- ma rket com ponents and will ensure correct equipment is used to replace substantive parts of the UAS craft

. 14 CFR 45.23(b): Display of Marks; general Normally, a small decal or sticker label with non
-standard alphanumeric markings (as me ntioned in 14 CFR 45.29) should be able to be affixed the UAS in some location. However, if unable to affix some kind of label with the vehicle’s registration number on it, other identifiable num bers will be used from the craft, such as manufacturer’s serial number and/or a designated vehicle number from the operato r, Sully Enterprises , LLC , Inc. that can be used to cross reference the UAS to the registration number as assigned by the FAA. A cross reference of said num bers will be d ocumented by the operator and available in the operator’s private records

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14 CFR 45.27 : Location of marks; nonfixed
-w ing aircraft Specificall y , §45.27(a) states that for Rotorcraft: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23.Because this is neither a passenger rotorcraft nor contains a cabin, book, or tail in the traditional sense, displaying any type of registration marking cannot be accomplished. Therefore, the next best location will be used to place the UAS aircraf t registration number, this will be determined by the operator to ensure balance, mechanical motion, and radio/GPS signal Reception is not hindered. As guidance, a typical ideal location may be the booms for the motor arms or on the landing gear assembly

. 14 CFR 45.29: Size of Marks There will be insufficient space to display aircraft registration numbers on this type of UAS and ma ke it visible as required by this section. A smaller decal or sticker label with non
-standard alphanumeric markings will be affixed to the UAS in some location in order to identify the craft

. 14 CFR 61.113(a) and (b): Private Pilot Privileges and Limitations : Sections 61.113 (a) and (b) limit private pilots to non
- comme rcial 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 requiring the Pilot in Command ( PIC) operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate a UAS . Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground
- based operator. The operational area is controlled and re stricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing UAS use by a sport pilot as the PIC exceeds the present level of safety sought by 14 CFR 61.113 (a) and (b). 14 CFR 91.9: (b) (2) The need to have an aircraft manual onboard does not apply. UAS aircraft information manuals will be kept by the operator

. 14 CFR 91.103: Preflight Action Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, flight battery requi rements, landing and takeoff distances, and aircraft performance data before commencement of flight

. 14 CFR 91.109: Flight instruction; Simulated instrument flight and certain flight tests At times, it will be necessary to certify and/or recertify other UAS operators in an instructional setting. There will be no persons onboard the UAS. Also, on the ground, only a single UAS transceiver controller will be monitored by the person giving instruction to the current UAS PIC receiving instruction and pilotin g the UAS craft.

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14 CFR 91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those ca ses, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.” Because Sully Enterprises , LLC requests authority to operate at altitudes no higher than 400 AGL , and not more than 200 above an elevated platform from which filming is planned, an exemption is needed to allow such operations. It may , however, be o perated in a restricted area within a security perimeter, where buildings and people will not be exposed to operations without their pre
-obtained consent. The equivalent level of safety 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 property owners or local officials. Because of the advance notice to the property owners and participants in the filming activity, all affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of flammable fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low
- altitude operations of the UAS will ensure separation between a UAS and conventional aircraft. 14 CFR 91.121: Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain c ruising 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 a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant to the Pre
- Flight inspection and Safety Check list , confirming the altitude of the launch site shown on the GPS altitude indicator before flight

. 14 CFR

. 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 least 30 minutes . . . .” The typical battery powering the Sully Enterprises , LLC ’s UASs provides less than 30 minutes of powered flight. To meet the 30
- mi nute reserve requirement in 14 CFR §91.151, UAS flight would not be possible. Given the limitations on the UAS ’s proposed fligh t area and its proposed operations within a predetermined location, a longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the UASs in a tightly controlled area where only people, property owners, or official repres entatives will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to a ddress. Sully Enterprises , LLC believes that safety can be achieved by limiting flights to 30 minutes or 25% of battery power, whichever occurs first. This restriction would be more than adequate to return the UAS to its pre
-determined landing zone from anywhere in its limited operating area

. 14 CFR 91.203 (a) and (b), and 91.715 Airworthiness Certificates Section 91.203(a) prohibits, in pertinent parts, any person from operating a civil aircraft unless it has within it:

### Page 5 (1) An appropriate and current airworthiness certificate; and (2) An effective U.S. registration certificate issued to its owner or, for operatio n within the United States, the second copy of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent parts, that no person may operate a civil aircraft unless the airworthiness certificate or a sp ecial flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. A UAS has no certificate nor does it have a cockpit door. Sully Enterprises , LLC is requesting an exemption from 91. 203 (a) and (b), and also 91.715 14 CFR 91.205 (b): Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements Section 91.205 pertains to cockpit instruments for manned aircraft occupied by at least one pilot. This is not applicable to UAS. However, to ensure an equivalent level of safety and information, transmitted telemetry will be sent to the PIC and displayed on a video screen indicating various parameters including, but not limited to, GPS al titude, GPS signal, battery power remaining, time in flight, UAS ground speed, etc 14 CFR 91.215: ATC transponder and altitude reporting equipment and use The UAS craft will have insufficient useful load and power suppl y to operate a transponder. Furthermo re, operations offered by the blanket COA will occur below ATC radar coverage. To ensure an equivalent level of safety, when operations exist within 3 miles of a public airport, the operator will n otify the local airport or ATC facility to advise them of the operation. If operations exist in an area not covered by the blanket COA, then a specific COA for that operation will be obtained by the local FSDO and specific case
- by
- case coordination with ATC will be made for the UAS flight

. 14 CFR 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 aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prov ided in paragraph (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 sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Sully Enterprises , LLC operations. Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because the UASs are limited in size, 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 AGL. T he operator will ensure that the UAS is in working order prior to fligh t, perform any required maintenance, and keep a log of any maintenance p erformed. Moreover, the operator is the person most fam iliar with the UAS and best suited to ma intain it in an airworthy condition

. Summary Sully Enterprises , LLC will adhere to all outlined safety precautions. T he unit itself weigh s fewer than 55 pounds and powered by batteries that eliminates virtually all of that risk given the small size and lack of fuel. S atisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Sully Enterprises , LLC’s requested exemption, allowing for Sully Enterprises , LLC's UAS operations.

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I f you have any questions or need any additional information, please contact the undersigned by phone at 404.7904451 or via email at billsul@mindspring.com

.
Sincerely ,

Wi lliam Sullivan, Jr Owner Sully Enterprises , LLC