1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION OF EXEMPTION OF:

AEROLENS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE
CODE OF FEDERAL REGULATIONS SECTIONS:

CONCERNING COMMERCIAL OPERATION OF THE “DJI INSPIRE 1” UNMANNED
AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 9 5)

Submitted: June 7

, 2015

By: TOM CASKA, CEO AEROLENS & MATT DUNN, AEROLENS2 

## GLOSSARY

ATO

– Air Traffic Organization

COA

– Certificate of Authorization

ESC

– Electronic Speed Control

FCC

– Federal Communications Commission

UAS

– Unmanned Aerial System

NAS

– National Air Space

PIC

– Pilot in Command

SVFR

– Special Visual Flight Rule

VFR

– Visual Flight Rule

VMC

– Visual Meteorological Conditions

VO

– Visual Observer3 

## TABLE OF CONENTS

I. DE SCRIPTION OF PETITIONER p 5

II. DESCRIPTION OF PROPO zat OPERATIONS p 6

A. Closed

- set Filmmaking and Cinematography

B. Aerial Survey & Inspection of Industrial/Construction Sites, Utility Power Generation Facilities & Infrastructure

C. Aerial Analysis & Inspection for the Agriculture & Insurance Industry

D. Aerial Imaging for the Real Estate Industry

E

. Research and Development

III. RELEVANT STATUTORY AUTHORITY p 9

IV. AEROLENS’ PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT p 10

A. Approval is Warranted Based on the UAS ’ Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Aerolens Operational Manual s

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED p 14

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §91.203(a)(1)

B: 14 C.F.R. §21.191 (a) and (b) : Research and Development & Showing Compliance with Regulations

C . 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

D . 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

E . 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

F . 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

G . 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

H . 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 144



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

I . 14 C.F.R. § 91.103: Preflight Action

J . 14 C.F.R. § 91.109(a): Flight Instruction

K . 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

L . 14 C.F.R. § 91.121: Altimeter Settings

M . 14 C.F.R. § 91 .151(a): Fuel Requirements for Flight in VFR Conditions

VI. DRUG AND ALCOHOL PROGRAM p 22

VII. PUBLIC INTEREST p 23

VIII. PRIVACY p 24

IX. FEDERAL REGISTER SUMMARY p 25

X. CONCLUSION p 26

APPENDIX A. p27

APPENDIX B. p28

APPENDIX C. p29

APPENDIX D. p305

I. DESCRIPTION OF PETITIONER

Based in Australia, Aerolens (Petitioner) is an aerial imaging company dedicated to providing technologically
driven and innovative solutions to a variety of industr ies . Its founders, Tom Caska (CEO) and Matt Dunn (Chief Remote Pilot) each have wide

- ranging experience in the aviation industry. Tom has experience in
aviation business and holds an Airline Transport Pilot Licence . He has actively flown with an international
Australian airline for a number of years

. Matt is a professional aviation weather observer and has performed this role for a period of 8 years with the Australian Government . He has had a hands

- on role using remote sensing techn ologies at a number of locations throughout Australia. Tom and Matt are graduates of the University of New South Wales and hold Honours Degrees in Aviation (Flying) and Aviation (Management) respectively.

Building upon this extensive and varied aviation e xperience, Aerolens seeks an exemption to allow

commer cial operations of small UAS to provide aerial photography

, video and analysis services across a wide range of industries including:

 Film & Television;

 R eal E state ;

 S urveying, B uilding and C onstructio n ;

 Agriculture;

 Insurance;

 Utilities & P ower

- G eneration ; and,

 E nvironmental.

The contact information for Petitioner is as follows:

Tom Caska CEO Aerolens Terrigal, NSW, Australia Phone: ( +61 ) 422 150 144 Email: tom@aerolens.com.au6

II. DESCRIPTION OF PROPOSED OPERATION

Aerolens seeks an exemption pursuant to Section 333 of th e Reform Act to operate the DJI Inspire 1 UAS for the proposed operations discussed below. All UAS operations will occur under tightly c ontrolled conditions

on property where Aerolens has received permission to operate fr om the landowner, controller or authorized representative. The proposed UAS operations will be conducted in a ccordance with the conditions and limitations of this Petition for Exemption and the Aerolens Operational Manual s which are made up of the Aerolens Operations Manual, the Aerolens Flight Manual

– DJI Inspire 1 and the Aerolens Maintenance
Manual

– DJI Insp ire 1

.

As detailed in the Aerolens Operational Manual s, all UAS operations will be limited to daytime VFR
conditions , within visual line

- of

- sight (VLOS ) of the operator, in uncontrolled airspace, and will occur at least 5 miles away from an airport. The de tails cont ained with the Aerolens Operational Manual s incorporate redundant safeguards to en sure the aircraft does no t travel outside the controlled area of UAS operations, including through the use of GPS technologies.

A. Closed

- set Filmmaking and Cinemat ography

Aerolens seeks to use small UAS for the purpose of conducting scripted, closed

- set filming for the motion picture, television, and web industry. Aerolens has tailored its operations to meet the requirements established by the FAA in prior grants of exemption authorizing commercial use of UAS in the motion picture and
television filmmaking industry, including:

 Astraeus Aerial (Exemption No. 11062)

 Aerial MOB, LLC (Exemption No. 11066)

 Dronair Solutions (Exemption No. 11671)

 Pictorvision, In c. (Exemption No. 11067)

 HeliVideo Productions, LLC (Exemption No. 11065)

 Snaproll Media, LLC (Exemption No. 11063)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying

- Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

All UAS filmmaking operations will occur on private prop erty in a controlled area, away from spectators and persons not involved in the filming. I n addition, aerial filming will be conducted during daylight, VFR
conditions and at altitudes belo w 400' AGL. As set forth below, all Aerolens operations provide an equivalent
level of sa fety that is superior to performing the same work using conventional fixed

- wing aircraft or helicopters.

B. Aerial Survey & Inspection of Industrial /Construction Sites, Utility Power

- Generation Facilities and
Infrastructure

Aerolens seeks to use small UAS for the purpose of condu cting aerial imaging for safety monitoring of controlled access industrial and construction sites, utility power

- generation

, transmission and distribution
facilities

, and infrastructure. Traditi onal methods of inspecting these type s of infrastructure, including flare7

stacks, elevated pipelines an d power lines, tanks, and steep rooftops, expose inspecting engineers to risk of
harm or serious i njury. Inspectors need to climb tower or otherwise perform work at elevated heights , which

e xposes them to the risk of dangerous falls. In addition to this , depending on the nature of the inspection, proximity to equipmen t often involves a risk of exposure to hazardous chemicals or oxygen

- deficient

atmos pheres, burns from steam or hot equipment, and other mechanical hazards associated with in dustrial
sites and construction facilities. The use of small UAS mitigates these hazards and enables a much safer
method of performing these types of inspections.

The use of s mall UAS for inspection is also sa fer than traditional mann ed aircraft performing the same function. Conventional operations using rotorcraft and fixed

- wing aircraft in lo w level operations present risks associated with vehicles weighing t housands of pounds and carrying large amounts of fu el. Small UAS inspection is more reliable, and allows for the collection , dissemination, and storage of visual and other sensory data with greater precision and du ration. Small UAS will also be capable of accessing and inspecting
areas that would otherwise be inaccessible using conventional aircraft or other inspection methods.

C. Aerial Analysis & In spection for the Agriculture & Insurance Industr ies

Aerolens seeks to use small UAS for the purpose of conducting aerial analysis and inspection of si tes for the agriculture and insurance industr ies

. Aerolens has tailored its operations to meet the requirements established by the FAA in prior grants of exemption authorizing commercial use of UAS in insurance industry including:

 OpenSky Drones (Exemptio n No. 11 691 )

 Principia, Inc (Exemption No. 11 633 )

 AgEagle LLC (Exemption No. 11480)

 T&K LLC (Exemption No. 11619)

 UAV Field Services Inc (Exemption No. 11512)

 HAZON Solutions, LLC (Exemption No. 11487)

 Erie Insurance Group (Exemption No. 11293)

The use of small UAS for aerial analysis and inspection s is safer than traditional manned aircraft performing
the same function at very low altitudes . Conventional operations using rotorcraft and fixed

- wing aircraft in low level operations present risks associated with vehicles weighing thousands of pounds and carrying large amounts of fuel. Small UAS inspection is more reliable, and allows for the col lection, dissemination, analysis and storage of visual and other sensory data with greater precision and duration. Small UAS will also be capable of accessing and inspecting areas that would otherwise be inaccessible or too costly using
conventional aircra ft or other inspection methods.

D. Aerial Imaging for the Real Estate Industry

Aerolens seeks to use small UAS for the purpose of conducting aerial analysis and inspection of private and
commercial sites for the real estate industry. Aerolens has tailored its operations to meet the requirements established by the FAA in prior grants of exemption authorizing commercial use of UAS in the real estate industry.

The use of small UAS for aerial photography is safer than traditional manned aircraft performing th e same function. Conventional operations using rotorcraft and fixed

- wing aircraft in low level operations present risks associated with vehicles weighing thousands of pounds and carrying large amounts of fuel. Aerolens is committed to upholding privacy law s and regulations associated with aerial imaging, particularly in suburban
locations where sensitivities to the use of small UASs exist.8

E . Research and Development

Aerolens seeks to use small UAS for the purpose of furthering its research and development aspirations. As part of Aerolens’ vision, the organi z ation is committed to developing innovative ways in which to use current technologies for the purposes of enhancing the livelihoods of the gene ral public, widespread communities and industries throughout the United States. Research and development using the proposed small UAS will have the potential to assist industries including agriculture, emergency response, construction and surveying,
enviro nmental monitoring and other government agencies.9

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Se ction 333(a) through (c) of the FAA Modernization and Reform Act of 2012 ("Reform Act") . Cong ress has directed the FAA " to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system ." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to oper ate in the National Air Space (NAS ) where it is safe to do so based on the following considerations:

● The UAS 's size, weight, sp eed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Ad ministrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting

exemp tions from §§ 44701(a), (b) and §§ 44702

– 44716, et seq.).

A party requesting an exemption m ust explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to
the existin g rules). See 14 C.F.R. § 11.81 (petitions for exemption).10

IV. AEROLENS 'S PROPOSED UA S OPERATIONS MEET THE REQUIREMENTS OF SECTION
333 OF THE REFORM ACT

The small UAS operations proposed by Aerolens in this Petitio n for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as eac h of the statutory criteria and relevant factors are sati sfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the DJI Inspire 1 due to its size weight, speed, and operational capability.

 The DJI Inspire 1 ha s been approved for use in prior Section 333 Grants of Exemption from the FAA.

 The DJI Inspire 1 weighs less than 10 pounds, including payload.

 The DJI Inspire 1 will not be flown at a ground speed in excess of 50 knots.

 Al titude information will be generated by equipment on

- board the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, o r any combination thereof. This information will be transmitted to the pilot via telemetric d ata feed.

 The UAS will have system redundancies and independent functionality to ensure the overall safety and predictability of the system. If connection to the remote control or ground control station is lost, failsafe systems will permit the UAS to retu rn to a predetermined location and safely land without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Fede ral Communications Commission (FCC ) and other appropriate government oversight agency requirements. The operating frequenc ies for the DJI Inspire 1 are 2.4 GHz (ground to air) and 5.8 GHz (ground to ground) for communications.

B. Approval is Warranted Based on the Operat ional Restrictions Set Forth in the Aerolens Operational
Manual s

The Aerolens Operational Manual s and the DJI Manufacturer's Manual for the selected UAS will contain all the procedures and limitations necessary to safe ly and successfully perform the operations specified in this Petition for Exemption. To as sist the FAA in m aking a safety assessment of Aerolens ’ proposed operations, below is a summary of operational limitations and conditions that Aerolens will adhere to, and which will

ensure a n equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs less than 10 pounds, fully loaded.
2. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/c ontroller or authorized representative will be obtained for each flight operation.
3. All UAS operated under the Grant of Exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.
4. Minimum crew for each flight operation will consis t of a pilot, who will be Pilot i n Command (PIC )
of the UAS , and one or m ore Visual Observers (VO ) as necessary to saf ely conduct the mission.
5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which
the PIC is rated on his or her pilot certificate.11

6. The UA S shall be operated within VLOS of the PIC and VO at all times. The PIC must use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued
medical certificate.

7. The PIC and VO desig nated for any operation will be able to communicate verbally at all times.
8. Electronic messaging or texting will not be permitted during flight operations.
9. The additional requirements identified in the Grant of Exemption shall be added to the Aerolens Operational Manual s. The Operational Manual s will be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and Aerolens Operational Manual s, the conditions and limitations in the Grant of Exemption shall take precedence and must be followed. Otherwise, Aerolens shall follow the procedu res outlined in their Operational Manual s. 10. Aerolens may update or revise its Operational Manual s. Revisions will be tracked an d a revised copy of the Manual will be provided to the Administrator upon request. Aerolens will also present updated
and revised Operational Manual s if it petitions for extension or amendment to its Grant of Exemption. If an update or revision would affec t the basis upon which the FAA grants the exemption, Aerolens will seek an amendment to its Grant of Exemption. Aerolens will contact the FAA’s UAS Integration Office (AFS

- 80) if questions arise regarding updates or revisions to the operating documents.
11. Ae rolens Operational Manual s and its Grant of Exemption will be available to the PIC at the ground control station anytime the UAS is operating.
12. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.
13. Maximum total flight time for each operational flight using the DJI Inspire 1 will be limited to 20
minutes or the am ount of time the UAS can be flown and still maintain a reserve battery power of no less than 25%, whichever occurs first.
14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable controlled airspace without prior written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the struc ture.
15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that su fficiently protect nonparticipating persons from the
UA and/or debris in the event of an accident. The operator must ensure that nonparticip ating persons remain under such protection. If a situation arises where nonp articipating persons
leave such protecti on and are within 500 feet of the U A, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC ha s made a safety
assessment of the risk of operating closer to those objects and determi ned that it does not
present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those pe rsons per § 91.119(a).

16. The UA S may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.12

17. The UA S may not operate within 5 nm of an airport reference point as denoted on a current FAA

published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the Aerolens COA. The letter of agreement with the airp ort management will be made available to the Administrator upon
request.
18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. The pre

- flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. The PIC shall not operate the UAS if the inspection reveals a condition that affects the safe operation of the UAS until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The ground control station shall be included in the pre

- flight inspection. All maintenance and
alternations must be properly documented in the UA S records as required by the Aerolens Operational
Manual s. 19. Aerolens will carry out its maintenance, inspections, and record keeping requirements in accordance
with the Operational Manual s. Maintenance, inspection, and alterations will be noted in the UAS

r ecords, including total time in service, description of work accomplished, and the signature of the
authorized person returning the UAS to service.
20. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight
in accordance with the Aerolens Operational Manual s. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and UAS record entry shall be included in the Aerolens Operational Manual s. 21. The UAS will be operated and maintained according to the Manufacturer's Manuals and any required
manufactur er Safety/Service Bulletins.
22. Prior to the operation, a Mission Packet will be created in accordance with the requirements o f the
Aerolens Operational Manual s. 23. Aerolens will obtai n an Air Traffic Organization (ATO ) issued Certificate of Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in accordance with airspace requirements in the ATO issued COA includ ing class of airspace, altitude
level and potential transponder requirements.
24. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate government al agencies.
25. If the UAS loses communication with the pilot, it will have the capability to return to a pre

determined location within the operational area and land safely.
26. Contingency plans will be in place to safely terminate flight if there is a loss of communication
between the PIC and the VO

. 27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or emergencies.
28. All PICs and VOs will have at least a current Class III Medical Certificate.
29. Prior to conducting operatio ns for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.
30. P rior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR § 61.51(b), a minimum of 10 hours as
UAS pilot operating the make and model of the UAS to be utilized fo r operations under the exemption
and three take

- offs and three landing in the preceding 90 days.13

31. Operations shall occur during daytime V isual Meteorological Conditions (VMC) ; flights under special visual flight rules ("SVFR") shall not be conducted.
32. The UA S shall remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).
33. UAS Operations under Instrume nt Flight Rules, at night, or beyond VLOS are prohibited.
34. The UAS will not be operated from an elevated platform or moving device/vehicle.
35. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.14

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil a ircraft, as the term is defined under § 40101 of the Act, including UAS

, from its safety re gulations and minimum standards when the Administrator decides a re quested exempt ion is in the public interest.

Aerolens seeks an exemption from several interrelated pro visions of Title 14 of the Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a
UA S . Listed below are: (1) the sp ecific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better
than o r equal to the rules from which exemp tion is sought.

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H

– Airworthine ss Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from th is section if a finding is made under the Reform Act
that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same applicati on. These criteria are met, and therefore no exemption is needed. If, however, the FAA
determines that there are some characteristics of the chos en UAS that fail to meet the req uirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Aerolens ' use of the DJI Inspire 1 is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description of proposed operations in Section IV (A), the DJI Inspire 1 weighs
less than 10 pounds, including payload and will not be fl own at a ground speed in excess of 50 knots. This
UAS is also equipped with safety feature s that will allow Petitioner to operate the UAS safely after experienc ing any unexpected in

- flight contingencies or failures.

Operations conducted under this exemption will be clos ely controlled and monitored by the operator and will be conducted in compli ance with local public safety requirements, to provide security for the area of operation. Aerolens will al so provide the FAA with advance notice of all operations via NOTAMs as required by the applicab le COA. In all cases, operation of the DJI Inspire 1 u nder the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UAS do es not need a means to communic ate with other aircraft or ATC, because those capabilities
will b e possessed by the PIC and VO , who are not on

- board the UAS

. In addition, no sense

- and

- avoid technology is necessary for the UAS because it will be operated at all times in VFR conditions and within VLOS of the PIC and Operator.

B. 14 C.F.R. §21.191 (a) and (b): Research and Development & Showing Compliance with Regulations

Aerolens seeks an exemption in relation to the research and development requirements contained in 14 C.F.R. §21.191 (a) and (b)

.

 14 C.F.R. §21.191 (a) Research and Development , states :15

Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

 14 C.F.R. §21.191 (b) Showing Compliance with Regulations

. states:

Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function an d reliability requirements of the regulations.

The experimental certificate can be used for commercial purposes in terms of developing new operating techniques to gather aerial imaging.

Equivalent Level of Safety

The UAS will not carry persons, fuel, and all operations will adhere to the flying restrictions and limitations referred to previously. All flights will be conducted in accordance with the Aerolens Operational Manuals and will require the PIC and VO at all times. The DJI Inspire 1 operated by Aerolens weighs less than 10 pounds and is constructed primarily of carbon fibre and plastic. It is therefore proposed that this UAS will be at least as safe and most likely safer than a larger commercial fixed

- wing ai rcraft or helicopter performing the same aerial operations.

C . 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Aerolens ’ small UAS would otherwise require certification under Part 27, Petitioner se eks an exemption from Part 27's deemed unsafe or unnecessary to fly over. The petitioner
states further th at the UAS has built

- in intelligent fault handling which allows the DJI Inspire 1 to detect a
system fault while in the air and automatically fly back to its take

- off location and land. Faults that can be detected include: loss of communication; exceeding pre

- set range thresholds; and low battery levels.

All flight operations are global positioning syst em (GPS) controlled, making the system easy to navigate. At any point if the operat or is not explicitly commanding the system to move, the system automatical ly hol ds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed an d others to ensure stability so long as wind thresholds
are not exceeded. Also a fligh t termination link

– to prevent a 'fly away' or other potentially dangerous
situation

– is available to the operator.

D . 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Aerolens seeks an exemption from the aircraft marking and identif ication requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Ma rking and Placard requirements, provides that:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter

.
● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited,

rest ricted or light

- sport categor y aircraft or experimental or provisionally certificated a ircraft, the operator16

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less
than 2 inches n or more than 6 in ches high, the words "limited," "restricted," "light

- sport, "e xperimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabi n, fuselage, boom , or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determine d that exemption from these requirements was warranted provided that the aircraft "have ide ntification (N

- Number) markings in accordance with 14 C. F.R Part 45, Subpart C if the markings are as large as practicable."10

Equivalent Level of Safety

All UA S flown by Aerolens will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.11 1 0 FAA Docket No. FAA

- 2014

- 0352.

E . 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a) (1) and (2); 91.417(a) and (b): Maintenance Inspections

Aerolens seeks an exemption from the maintenance inspe ction requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each

owner or operator of an aircraft "[s] hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter" ).
An exem ption from these regulations is needed because Part 43 and these sections only apply to aircraft wit h
an airworth iness certificate, which the UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because m aintenance and inspections will be performed in
accordance with the Manufacturer 's Manua l and any required manufacturer Safety or Service Bulletins. Further, as required by the Aerolens Operational Manual s, the PIC will conduct a pre

- flight inspection of the
UAS and all associat ed equipment to account for all discrepancies and/or inoperable components.
Maintenance wi ll be performed and verified to address any conditions potentially affecting safe operation of
the UAS and no flights will occur unless, and until, all flight critical components of the UAS have been found
to be airwort hy and in a condition safe for operation. A functional test flight will be conducted following the replacement of any flight

- critical components. As required by the Aerolens Operational Manual s, the PIC who conducts the functional test flight will make an entry in the UAS aircraft records of the flight.

Aerolens ' Operational Manual s also includes the requirement to follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacem ent, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ESCs), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Aerolens ' Operational Manual s also includes procedures to document and maintain a record of the UAS maintenance, prevent ative maintenance, alterations, the status of replacement /overhaul component parts, and the total time in service of the UAS u sed under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in Aerolens ’ Operational Manual s ensure that an equivalent or higher level of safety will be achieved.17

PILOT

- IN

- COMMAND OF THE UAS

F . 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Aerolens seeks exemption from 14 CFR § 61.113, which rest ricts private pilot certificate holders from flying aircraft for compen sati on or hire, and wo uld also require a second class medical certificate. T he purpose of
Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part of a commercial operation, it carries neither pas sengers nor cargo. In the Grant of Exemption to Astraeus Aerial12, the FAA determined that the unique characteristics of
UAS operation outside of controlled airspace did not warr ant the addition cost and restrictions attendant with requiring a the PIC to have a Commercial Pilot C ertificate and Class II Medical Certificate. The fulfilment of the additional requirements for a pr ivate pilot to become qualified as a commercial pilot w ould not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions Aerolens has placed on its UAS operations meet or exceed the restrictions similarly imposed
on Astraeus Aerial. Aerolens will operat e on private property away from persons and property not involved in the operation. Aerolens will also obtain an ATO issued COA prior to conducting any operations under this
Grant of Ex emption. All operations will be conducted in accordance with airspace requirements in the ATO
issued COA includi ng class of airspace, altitude level and potential transponder requirements. A NOTAM will
also be issued as required by the applicable COA.

In addition to these flight restrictions, Aerolens will f urt her ensure safe operation by requiring that any PIC be thoroughly versed not only in ai rspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. As set forth in the Operational Manual s, pilots will h ave experience not only
in UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf of Aerolens . The pilot qualification, training, and currency requirements in the Operational Manual s ensure that Aerolens ' pilots are competent and proficient in the UAS they are operating. Aerolens ' training and qualification requirements are consistent with those contained in prior FAA S ection 333 Gra nts of Exemption, and will provide a higher level of competency and proficiency fo r its pilots and will ensure at least an equivalent level of safety.

OPERATING PARAMETERS OF THE UAS

G . 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS

, Aerolens seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exempt ion is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner requests that the requirements for § 91.7(a ) be treated in
accordance with Section V(A), supra.

H . 14 C.F.R. § 91.9(b)(2): Civ il Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying C ivil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b ) require the operator to carry airworthiness documents and
other aircraf

t manuals on

- board the aircraft.18

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U .S.

- registered civil aircraft

– ...
(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless
there is available in the aircraft a curren t approved Airplane or Rotorcraft Flight Manual, approved
manual ma terial, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may ope rate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unles s the airworthiness certificate required by paragraph (a) of this section or a spec ial flight authori zation issued under § 91.715 is displayed at the cabin or cockpit

en trance so that it is legible to passengers or crew.

Given the small size and configuration of the UAS

, it would be impossible to keep airworthiness documents
and other aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC

- 220, it was acknowledged that th e intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating t he aircraft. As this

FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has acces s to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS

.

I . 14 C.F.R. § 91.103: Pre

- flight Action

Aerolens seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific
information before each flight, includi ng information contained in the FAA

- approved Flight Manual on board
the aircraft. While th e PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA

- app roved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aerolens ' Operational Manual s and the Manufacturer's Manual. The PIC will perform a s eries of checklists designed to identify any de fects or inoperable components in accordance with the Aerolens Operational Manual s, including checklists covering

Pre

- Flight, Launch, Landi ng, and Post

- Flight procedures. The PIC will also be required to review weather, flight requirements, battery ch arge, landing and take

- off distance, UA S performance data, and contingency
lan ding areas before the initiation of flight. Aerolens ' Operational Manual s and the Manufacturer's Ma nual will be kept at the ground control station and will be accessible to the PIC at all times while operating the
UAS

.19

J . 14 C.F.R. § 91.109(a): Flight Instruction

Aerolens seeks an exemption from 14 C.F.R. § 91.109(a), w hich provides in pertinent part that "[n]o person
may operate a civil aircraft (except a manned f ree balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. " UAS and remotely piloted aircraft, by their design, do not have
functional dual contr ols. Instead, flight control is accomplished through the use of a device that communica tes
with the aircraft via radio communications. Accordingly, an exemption will be requ ired for the flight
instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UAS that Aerolens intends to use, an equivalent level of safe training can still be performed without dual controls bec ause no pilot or passengers are aboard the UAS , and as required by the
Aerolens Operation al Manual s, all persons will be a safe distance away in the event that the UAS experiences any difficulties during flig ht instruction. Furthermore , as required by the Aerolens Operational Manual s, all
fl ight training will be conducted in a controlled and s terile environment. As a whole, the sa fety procedures provided for in Aerolens ’ Operational Manual s ensure that the proposed UAS oper ations provide an equivalent or higher level of safety than that provided by the flight instruction regulations.

K . 14 C.F. R. § 91.119(c): Minimum Safe Altitudes

Aerolens requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119(c). Section 91.119 prescribes the minimum safe alt itudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those
minimum altitudes w hen it can be operated " without hazard to persons or property on the surface," provided
that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA ."

An exemption is required because the proposed UAS o perations will normally need to occur below 400 feet
AGL. In circumstances where the UAS is us ed to inspect a structure whose height exceeds 400 feet AGL, the
UAS will not be operated more than 100 feet above the highest point on the structure, and within 50 feet
horizon tally of the s tructure. Additionally, due the nature of the proposed operations, the Pilot and/or VO(s) may need to be less th an 500 feet away from the UAS

.
Relief from § 91.119(a) will not be necessary because Petiti oner will be able to perform an emergen cy landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be

necessary.

Equivalent Level of Safety

Compared to flight operations with rotorcraft wei ghing far more than the maximum weights proposed herein, and given the lack of flammable fuel with the UAS , any risk associated with these operations is far less than those that pr esently exist wi th conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS , as well the controlled location where the operations will oc cur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 f eet AGL or below, or when20

inspecting a structure whose height exceeds 400 feet AGL, wi thin 100 feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operational Manual s, the UAS wi ll be operated in a r estricted area, and all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the UAS and any possible debris resulti ng from UAS failure. As required by the Operational Manual s, flights will be terminated if a nonparticipating person within 500 feet of
the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from ve hicles

or structure s unless the property owner/controller has granted permission and the PIC has made a safety
assessment of the risk of operating closer to those objects and, operations ne ar the PIC or VO will not present an undue hazard per § 91.119(a).

It is also noted t hat in Grant of Exemption No. 11138 (FAA

- 2014

- 0481 at 19) that If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations mus t cease immediately. When considering how to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and struct ures when the owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment of the risk of operating closer to those objects and determines that it do es not present an undue hazard. A dherence to the restrictions contained
in Aerolens' Operational Manual s will ensure all flying operations can be conducted without compromising safety.

L . 14 C.F.R. § 91.121: Altimeter Settings

Aerolens seeks an exemption from 14 C.F.R. § 91.121, wh ich requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UAS do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be
achieved in circumstances where:

(1) the UAS will be operate d below 400 feet AGL or below ;

(2) within VLOS ;

(3) where GPS based altitude information is relayed in real time to the operator at a ground

- based on

screen display and , and;

(4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the on

- board GPS.

The UAS that Aerolens intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Aerolens ' Operati onal Manual s, the PIC will be required to calibrate the aircraft's GPS compass prior to each f light operation. Like prior FAA Section 333 Grants of Exemption,
the UAS Aerolens intends to use, and the safety mitigation procedures contained in the Operationa l Manual s,21

both ensure tha t an equivalent level of safety will be achieved, and a Grant of Exemption to the require ments of § 191.121 is therefore appropriate.

M . 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Aerolens requests an exemption from 14 C.F.R. § 91.151(a) 's fuel requirements for flight in VFR conditions.
Section 91.151 states:

(a) No person may begin 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.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30

- minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required

.
Equivalent Level of Safety

In the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginni ng a flight with the DJI S1000 unless (considering wind and forecast weather conditions), t here was enough power to fly at normal cruising speed to the intended landing point and lan d the UA with 25% battery power remaining. The DJI S1000 is a physically lar ger sized and heavier UAS when compared to the DJI Inspire 1 that Aerolens will be operating.

Like the DJI S1000 , the DJI Inspire 1 used by Aerolens includes a low battery warning system an d the amount of battery reserve power remaining is transmitted to the PIC via telemetric data feed, which downlinks from
the UAS to a ground

- based

- on

- scr een display and provides an estimated remaining flight time in minutes and
seconds as well as a percentage of overall battery charge remaining

. As required by Aerolens ' Operational
Manual s, the PIC will promptly fly the UAS back to the home launch l ocation or pre

- determined abort
location where the UAS may safely land, while still maint aining a minimum of 25% reserve battery power.
Aerolens submits that the procedures re quiring fligh ts to be safely terminated once the batteries fall below 25% capacity, combined with the r equirement that flights only be conducted within a secure, isolated area, using a UAS weigh ing less than 10 pound s, and within VLOS of the PIC and VO(s)

, ensure that the proposed

opera tion will provide an equivalent or higher level of safety to that provided by the regulations from which exemption is sought.22

VI. DRUG AND ALCOHOL PROGRAM

Aerolens will have policies in place to ensure that no person m ay participate in UAS flight operations if they are under the influence of alcohol or any drug.23

VII. PUBLIC INTEREST

The public interest will be served by granting Aerolens ' Petition for Exemption. Congress has established a national policy that favo u rs early integration of UAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfil Congress' goal in passing Se ction 333(a) through (c) of t he Reform Act

— the FAA Administrator's assessment of whether
certain UAS may operate safely in the NAS before completion of the s tatutorily required rulemaking. The proposed UAS operations in this Petition for Exempti on significantly improve safety and redu ce risk harm or serious injury to inspecting engineers. Tr aditional methods of inspecting monitoring industrial and construction sites, and utility power

- generation facilities and infrastructure requires inspectors to climb towers
or otherwi se perform elev ated work, which exposes them to the risk of dangerous falls. Inspectors are often exposed to hazardous chemicals or oxygen

- deficient atmospheres, burns from steam or from hot equi pment,
and other mechanical hazards associated with industrial sites and con struction facilities. The use of small UAS

can eliminate these hazards and is ultimately a much safer meth od of performing these types of inspections.

The use of small UAS also enhances safety and redu ces risk because, unlike manned aircraft weighing
thous ands of pounds, carrying crew in addition to flammable fuel, the UAS carry no passengers or crew. Further, in the unlikely event of an accident, Aerolens small battery powered UAS presents significantly less dange r to persons on the ground when compared to operations by conventional manned aircraft. It is noted that in the Grant of Exemption No. 11158 the Petitioner identified that manned helicopters performing similar aerial filming and imaging functions can weigh 6,000 pounds or more and are operated by a n onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAS will weigh less than 10 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly redu ces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. The risk to an on board pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation.

As Petitioner's UAS are battery powered, the public will also benefit from a reduction in ha rmful emissions
associated with conventional aircraft performing in the same functions proposed h erein. Lastly, as recognized by the FAA in prior Secti on 333 Grants of Exemption to filmmakers, UAS provide an additional tool for the aerial filming industry, adding a greater degree of fle xibility, which supplements the current capabilities offered by manned aircraft.2224

VIII. PRIVACY

All Aerolens UAS operations will be conducted in acco rdance with applicable federal, state, and local laws regarding privacy. All operations sha ll be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative w ill be obtained for each flight to be conducted.25

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal

Regulations:

Part 21, Subpart H; 21.191 (a) & (b) Part 27; 45.23(b); 45.27(a); 61.113 ; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a) ; 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general pu blic and property owners from the substantial hazards associated with performing equivalent film work

, aerial inspection s, and environmental monitoring of industrial sites, trans mission and storage facilities, construction facilities and precision aerial surveys with co nventional fixed

- wing aircraft, rotorcraft, or other methods.26

X. CONCLUSION

Aerolens ' Petition for Exemption sati sfies the criteria ar ticulated in Section 333 of the Reform Act of 2012 including weight, speed, operating ca pabili ties, proximity to airports and populated areas, operation within VLOS and national security. The proposed UAS operations will benefit the public as a whole by improving safety and red ucing risk by alleviating human exposure to danger. In considerati on of the foregoing, this
Peti tion for Exemption provides the FAA with more than adequate justification for granting th e requested exemptions allowing Aerolens to use small UAS for:

(1) scripted, closed

- set filming for the motion picture, television, and ;

(2) aerial inspection , surveying, environmental monitoring , monitoring of industrial sites, transmission and storage facilities, construction facilities and precision aerial surveys.

We thank you for your prompt consideration of our requested exemptions. Shou ld you have any questions, or if you need any additional infor mation to support the requested exemptions, please contact the undersigned.

Very truly yours,

Tom Caska,

CEO Aerolens27 APPENDIX A. AEROLENS OPERATIONS MANUAL

(Attached as separate document)28 APPENDI X B . AEROLENS FLIGHT MANUAL: DJI INSPIRE 1

(Attached as separate document)29 APPENDIX C . AEROLENS MAINTENANCE MANUAL

(Attached as separate document)30 APENNDIX D . DJI INSPIRE 1 OPERATIONAL MANUAL

(Attached as separate document)