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Gowdy Brothers Aerospace, LLC 8170 Old Carriage Court N., Suite #200, Shakopee, MN 55379 

www.GowdyBrothersAerospace.com 763-496-9551

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AeroVision Services, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM

THE REQUIREMENTS OF THE FAA REFORM ACT AND

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on August 9, 2015

AeroVision Services, LLC.

5030 Village Lane Ct

Traverse City, MI		49685

AeroVision Services’ Consultant

Gowdy Brothers Aerospace, LLC

8170 Old Carriage Court N. Suite #200

Shakopee, MN 55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com
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Table of Contents

GLOSSARY OF ABBREVIATIONS...........................................................................................3

INTRODUCTION AND INTERESTS OF THE PETITIONER..............................................4

Executive Summary .................................................................................................................4

Expeditious Summary Grant Approval Request......................................................................4

Description of Type, Make and Models of sUAV/UAS Requested:.............................................5

Commercial (Mission, Operation) Purpose:........................................................................................5

Regulations from which the Exemption Relief is requested:.......................................................6

The name and address of the Petitioner: .............................................................................................7

Background...........................................................................................................................................7

Commitment to Safety..................................................................................................................................8

Expertise & Experience................................................................................................................................8

The Exemption Request .........................................................................................................9

Operator Requirements ................................................................................................................ 10

Aircraft and Equivalent Level of Safety.................................................................................... 13

Specific Uses Public Benefits ....................................................................................................... 18

Equivalent Level of Safety............................................................................................................. 18

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................20

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................20

14 C.F.R. §91.121 Altimeter Settings...................................................................................................20

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................21

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections.....................................................................................................................................................21

Federal Register Publication............................................................................................. 22

Privacy and National Security........................................................................................... 23

Summary................................................................................................................................... 23

APPENDIX A - EXEMPTION PATTERN....................................................................................... 25

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS............................................ 26

APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA PREVIOUS

APPROVED EXEMPTION NUMBERS........................................................................................... 27

APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION NUMBERS.... 28

APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED EXEMPTION

NUMBERS............................................................................................................................................ 29

APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG............................................. 30

APPENDIX G – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS MANUAL

VERSION 1.0....................................................................................................................................... 31
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

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, AeroVision Services, LLC., (“AeroVision

Services”) Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer

on-demand commercial UAS operations for a host of industries and applications and to

perform the purposes listed below, hereby applies for an exemption from the listed

Federal Aviation Regulations (“FARs”) to allow commercial operation of its

sUAV’s/UAS, so long as such operations are conducted within and under the conditions

outlined herein or as may be established by the FAA in an exemption granted under

either Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the operation of a

UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3)

would provide safety enhancements in the fields in which it will operate, which now

depend upon conventional aircraft or humans climbing high on dangerous structures,

walking in insect laden swamps, and working adjacent to treacherous infrastructure.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements

for the safe operation of such aircraft systems in the national airspace system.” Section

333(c) of the Reform Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this application.

Petitioner has provided in a confidential document attachment labeled as petitioner

proprietary information, specific exemption numbers whereby the FAA has already

granted a previous exemption similar or identical to each and every request, herein.

For the FAA’s benefit, Petitioner’s Consultant, Gowdy Brothers Aerospace, LLC, has

researched, categorized and arranged all 631 exemptions granted as of June 23, 2015 into

a usable searchable database, based upon the following criteria: date submitted, date grant

																																																							

1		AeroVision Services relies upon the following exemptions where specific

reference to an exemption is not provided: Exemptions 11062 thru 11067, 11080,

11109 through 11112, 11114, 11213, 11062 and as recent as 11857.
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issued, time to petition grant, petitioner, petitioner’s state, exemption number, sUAV

equipment type, grant purpose (mission/operation), along with other supporting data. 

Petitioner has identified four previous approved exemptions for each of the Petitioners

FAA submission requests:

• Commercial (mission/operation) purposes;

• Type of sUAV’s (UAS);

• Title 14 Exemptions (exemption pattern referenced in appendix A)2

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAV’s makes and

modes as follows:

DJI - Phantom 2, DJI - Phantom 3, DJI - Inspire 1, DJI – Spreading Wings S800, DJI –

Spreading Wings S900, DJI – Spreading Wings S1000, DJI – Matrics 100, Cinestar 8

Octo, Altavian Nova F6500, Blade 350 QX3, AgEagle, 3DRobotics X8, 3DRobotics Iris,

3DRobotics Solo, SenseFly eBee, Yuneec Q500 Typhon, DraganFlyer X4-ES, Trimble

UX5, Microdrones MD4

Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment.

Equipment operation manuals for each sUAV are included for your reference and are

considered confidential information for each respective company’s UAS and are affixed

separately in these documents labeled Appendix.

Commercial (Mission, Operation) Purpose:

This exemption request, once granted would allow the petitioner to operate a small

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge

Inspections, flare stack inspection, utility-power generation system inspections and

patrolling, aerial inspection, photography and videography of residential and commercial

real estate, weddings, aerial inspection, photography and videography of utility

infrastructure including but not limited to electrical power lines, wind turbines and cell

towers, pipeline inspection and patrolling, filmmaking, cinematography, and

videography, precision agriculture with on board sensors, wildlife and forestry

monitoring and mosquito and insect control, aerial surveying, construction site inspection

																																																							

2 Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).
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and monitoring, public entity support operations, Aerial imaging for safety, monitoring

and comparing work efforts and completion percentages, and security of controlled

environment of various sites, aerial video and live video feed to assist with search and

rescue operations under the authority and support of local authority officials, aerial video

and photography for public and private use including television, public events, and

cinematography live feed and live newsgathering, training to persons individually or

belonging to both private and public organizations to increase awareness and improve

safety for current and future UAS operations within the NAS, special events: including

high schools. colleges, professional sports, open air events and fairs, research, risk

management and assessment, motion picture production3, surface mining, closed set

filming4, disaster and catastrophe events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

See Appendix E

																																																							

3 Motion Picture and Television Flight Operations Manual is herein attached as

Appendix G.

4 Motion Picture and Television Flight Operations Manual for closed set filming is

herein attached as Appendix G.
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The name and address of the Petitioner:

AeroVision Services, LLC.

Attn: Joe Van Antwerp and Edward Ellul, Jr.

5030 Village Lane Ct

Traverse City, MI		49685

Please direct any question or comment regarding this petition to Petitioners

Consultant: Gowdy Brothers Aerospace, LLC.

8170 Old Carriage Court N., Suite #200

Shakopee, MN 55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com

Background

The Petitioner, AeroVision Services is under Joe Van Antwerp and Edward Ellul, Jr.’s

direction. Joe Van Antwerp and Edward Ellul, Jr. are highly accomplished, capable,

experienced and trusted professionals.

AeroVision Services is a startup company comprising of two members of the LLC: Joe

Van Antwerp and Ed Ellul, Jr. 

Joe’s background consists mainly of sales management in multiple fields including but

not limited to surgical instruments, copiers, and construction. The last 7 years Joe has

been in the Landman business, negotiating contracts with landowners for Oil and Gas

rights, Wind Turbine rights, solar energy, and Overhead Transmission right of ways

among other functions. The last 4 of those 7 years Joe has owned and managed his own

company comprised of 4 independent agents and one office manager. 

Joe and Ed have used small commercial level drones and dual blade helicopters and will

be trained and certified on any and all vehicles we choose to put into operation. 

AeroVision Services is committed to the overall safety of its employees, clients, and the

public in general. We are committed to operate in a manner that is consistent with FAA

requirements as well as any state and local requirements. Safety precautions will be a

major part of our operations as we begin to operate the sUAS vehicles taking into account

any and all persons involved with flying the vehicles as well as those in the vicinity.
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Commitment to Safety

As part of its commitment to safety and innovation, AeroVision Services is asking for

this exemption in part, to reduce the risk of injury to its employees and contractors who

participate in the proposed activities the petitioner requests, including but not limited to

damage to agriculture, natural habitat, buildings and other structures within the United

States.

Expertise & Experience

AeroVision Services and Joe Van Antwerp and Edward Ellul, Jr. due to their professional

experience and are considered an up-and-coming subject matter expert in the Traverse

City, Lansing and Detroit metro areas for UAS of all types, models and makes.
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The Exemption Request

AeroVision Services proposes the use of the sUAV’s will be for capture of high

resolution imagery and video of residential or commercial applications and purposes to a

level of quality that allows the Petitioner to use the imagery to identify, record,

memorialize events and objects according to the purposes noted.

The imagery and video will be used to identify the condition of landscapes, agriculture,

events, disasters and infrastructure to conduct bridge inspections, flare stack inspection,

utility-power generation system inspections and patrolling, aerial inspection, photography

and videography of residential and commercial real estate, weddings, aerial inspection,

photography and videography of utility infrastructure including but not limited to

electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling,

filmmaking, cinematography, and videography, precision agriculture with on board

sensors, wildlife and forestry monitoring and mosquito and insect control, aerial

surveying, construction site inspection and monitoring, public entity support operations,

aerial imaging for safety, monitoring and comparing work efforts and completion

percentages, and security of controlled environment of various sites, aerial video and live

video feed to assist with search and rescue operations under the authority and support of

local authority officials, aerial video and photography for public and private use

including television, public events, and cinematography live feed and live newsgathering,

training to persons individually or belonging to both private and public organizations to

increase awareness and improve safety for current and future UAS operations within the

NAS, special events: including high schools, colleges, professional sports, open air

events and fairs research, risk management and assessment, motion picture production,

surface mining, closed set filming, disaster and catastrophe events.

The UAS will be operated by AeroVision Services and or contracting operators on

occasion to capture high-resolution imagery/video of large structures (wide and tall) such

as warehouses, high rise buildings, bridges, and construction sites, as well as “birds eye”

views of fire and explosion sites. Given the small size of the sUAV’s involved, no more

than 55 lbs., majority of the speed of operation be between 5-15 mph and the restricted

environment within which they will operate, the Petitioner falls squarely within that zone

of safety (an equivalent level of safety) in which Congress envisioned that the FAA must,

by exemption, allow commercial operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of

Transportation to consider whether certain unmanned aircraft systems may operate safely

in the national airspace system (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’ size, weight, speed, and operational capability;
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• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, 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) (emphasis

added).5

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: 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) This authority to grant exemptions reaches such issues as authorization of

commercial operation of aircraft without an FAA issued pilot’s license.

AeroVision Services in filing this application is requesting that the FAA combine the

grant of the Section 333 exemption with a standard Certificate of Operation (COA) that

will allow commercial operations of its AeroVision Services’ sUAV without the

necessity of filing for a COA for each flight, unless such flight is to be conducted in an

area not approved in the exemption. Compliance with the conditions agreed to herein and

that may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide

the separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer

than 5 nautical miles of the geographic center of an airport as denoted on a current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management

is obtained, AeroVision Services requests that operations over congested or densely

populated areas be allowed. The new sUAV’s do have GPS geo-fencing, it will operate at

a very low altitude, within confined areas, at low speed and weighs no more than 55 lbs..

Such operations will only be under-taken with the approval of the land or home owner, as

set forth herein, and will comply with the requirements that operations be no closer than

500 feet to the adjacent building unless the land owner has provided permission, and the

Operator has made a safety assessment of the risk from such operations.

Operator Requirements

																																																							

5 Applicant interprets this provision to place a duty on the Administrator to not only

process applications for exemptions under section 333, but for the Administrator to craft

conditions for the safe operation of the UAS, if it should be determined that the

conditions set forth herein do not fulfill the statutory requirements for approval.
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Given the sUAV proposed by AeroVision Services, Operators should not be required to

hold a private pilot license. AeroVision Services believes that 1) the operator, instead of

understanding how to operate a passenger carrying aircraft, should have knowledge and

experience that enables the safe operation of a small, remotely piloted sUAV should

understand airspace restrictions and know how to ensure separation from other aircraft as

well as non-participants and property; 2) the sUAV has built-in technical capabilities that

limit the potential for unsafe operation and 3) there are other security screening

mechanisms already in existence that AeroVision Services will utilize to ensure the

operators are acting consistently with national security interests.

Given the sUAV safety features outlined below, AeroVision Services proposes that its

operations under this Exemption request 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 private pilot ground instruction and passed the FAA

Private Pilot written examination or FAA-recognized equivalents; have completed

AeroVision Services’ training program for operation of the UAS.

AeroVision Services notes that 1) the FAA has found that safety factors permitted

operation of sUAV’s by Operators with these qualifications in the case of operations

pursuant to public COAs when the mandatory operating conditions specified above were

present; and 2) that the Notice of Proposed Rulemaking entitled Operation and

Certification of Small Unmanned Aircraft Systems, 80 F.R. 9544 (February 23, 2015)

(“NPRM”), does not require the operator to hold a private pilot license or a third class

medical.

Advanced sUAV’s has a navigation and control system and auto-pilot that allows it to

execute very accurate pre-programed flights. Flights are pre-programmed with GPS

waypoint to establish perimeters beyond which the aircraft will not operate. Flights under

auto-pilot are not directed by positive manual input, but through pre-programmed flight

parameters that are executed by the auto-pilot. In the case of unplanned events, the

Operator inputs preprogrammed evasive maneuvers from the control unit, and the

autopilot executes those maneuvers. Pre-programmed Operator interventions include:

initiation of holding at present position; suspension of mission; fly back to launch point;

abort mission and land immediately; and emergency power cut off and land (flight

termination system). Additional automated safety functions and safety enhancing features

of the advanced sUAV’s may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate

landing,

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels. Low power below 10% triggers an immediate landing,

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold

position at its current location for 5 seconds and if the signal is not restored,

execute a return to home and land,
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4) Redundant “kill switches” that enable completely shutting the aircraft down in

flight in the event of a loss of control or un-commanded deviation from the flight

path,

5) The aircraft, weighs less than 55 lbs., fully loaded,

6) The motors are driven by pulse width modulated signals, not analog signals,

7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging)

nor above 200 feet above the structure (imaging altitude) or a maximum of 400

feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems

(UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has determined in

Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the

requirements for private pilot knowledge and the knowledge required for a commercial

pilot, that knowledge associated with a private pilot license, and therefore private pilot

ground school, was sufficient to allow private pilots to operate sUAV’s under those

exemptions.

Based upon that analysis, AeroVision Services believes successful completion of FAA

private pilot ground school is a suitable predicate to operating the sUAV under this

exemption. AeroVision Services proposes that the Operator accumulate required sUAV

flight training hours through the operation of sUAV’s rather than flight hours in

conventional aircraft. Those hours are more relevant to the operations proposed herein

than hours gained in obtaining a private pilot’s certificate in conventional or rotor

aircraft. Those aircraft are orders of magnitude heavier than the sUAS and carry not only

the pilot himself, but also passengers and fuel, none of which is carried in the sUAS.

These conventional aircraft fly over all sorts of airspace without the permission or

knowledge of the landowner.

A handheld radio controller controls the sUAV and the vehicle is operated within the line

of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107

(private flight proficiency), to the extent they are relevant to UAS operations, can be

taught in the training proposed herein. As a review of the requirements of part 61.127 and

107 demonstrate, the issues presented as they relate to a 55 pound aircraft, operating at

less than 30 mph during filming operations are those taught in ground school and in flight

training with the particular UAS and not gained from accumulating flight hours in a fixed

wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take

offs and landings at controlled and uncontrolled airports.

As to national security review of pilots, each of AeroVision Services’ pilots/operators

will obtain internally provided certified training (Ground and Practical) from AeroVision

Services to operate the sUAV. This review and certification could reasonably vet the

Operators against any known terrorist or no fly listings that are relevant and publically

available.

AeroVision Services additionally asks that the exemption be issued without the

requirement for a visual observer. As set forth herein, an equivalent level of safety is
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provided by the size, speed and control capabilities of the aircraft, as well as the

operational procedures that will be applicable to all flight hereunder. These obviate the

need for the visual observer.

The Operator will be operating the aircraft, always within line of sight. He or she will

walk and follow the aircraft around the inspection area so that while it is flying it’s preprogramed and at times, manual flight path, the UAS will always be directly in his or her

line of sight. The Operator will not be distracted by viewing the pictures taken during the

flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the

flight of the UAS over the structure and intervene to address flight path deviations or

other issues that arise during the flight. The functions that an observer performs where

the aircraft is flown at long distances from the launch area will not be necessary as the

Operator will always have the aircraft in his or her direct sight. The observer also will not

be necessary because the Operator will conduct a pre-flight inspection of the area, will

and if needed, cordon off the area and will perform frequent visual scans of the area

while the vehicle is operating.

AeroVision Services again notes that the NPRM does not require the use of a visual

observer. Given the clear direction in Section 333 of the Reform Act; the authority

contained 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, reduction in environmental impacts, including reduced emissions

associated with allowing battery powered sUAV’s for these functions instead of turbine

or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot

license, the grant of the requested exemptions is in the public interest. 6

Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These

limitations provide for at least an equivalent or even higher level of safety to operations

under the current regulatory structure because the proposed operations represent a safety

enhancement to the operations conducted with conventional aircraft or with humans

climbing up and around structures. These conditions are drawn from Exemptions 11136,

																																																							

6 Should the FAA determine that it cannot grant such an exemption for operations

without a FAA licensed private pilot, despite the showing made herein, under the

statutory authority the FAA already has, AeroVision Services will operate its aircraft

with pilots holding at least a private pilot certificate issued by the FAA. In that event,

AeroVision Services requests that the exemption be granted with conditions similar to

those contained in numbered paragraphs 14-15 in Exemption 11136
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11138, 11172, 11174 and 11177, 11062, 11109, 11112, and 11213 and as recent as

11857.

These limitations and conditions to which AeroVision Services (referred to as

“Operator”) agrees to be bound when conducting commercial operations under an FAA

issued exemption include:

1) Operations authorized by this grant of exemption are limited to the

aircraft described in the Operator’s manual, which is a multi-rotor

weighing up to 55 pounds: Proposed operations of any other aircraft

will require a new petition or a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30

mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet

above ground level (AGL), as indicated by the procedures specified

in the Operator’s manual. All altitudes reported to ATC must be in

feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the

Aircraft Operator at all times. This requires the Aircraft Operator to

be able to use human vision unaided by any device other than

corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all

conditions and limitations required by the FAA. The Manuals must

be maintained and made available to the Administrator upon request.

If a discrepancy exists between the conditions and limitations in the

exemption and the procedures outlined in the Exemption Holder’s

Operator’s manual, the conditions and limitations in the exemption

take precedence and must be followed. Otherwise, the Aircraft

Operator must follow the procedures as outlined in its Aircraft’s

manual. The Exemption Holder may update or revise its Manuals. It

is the Exemption Holder’s responsibility to track such revisions and

present updated and revised documents to the Administrator upon

request. The Exemption Holder must also present updated and

revised documents if it petitions for an extension or amendment of

this exemption. If the Exemption Holder determines that any update

or revision would affect the basis upon which the FAA granted this

exemption, then the Exemption Holder must petition for amendment

to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to

ensure it is in a condition for safe flight. If the inspection reveals a

condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been
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performed, and the UAS is found to be in a condition for safe flight.

The Ground Control Station must be included in the preflight

inspection. All maintenance and alterations must be properly

documented in the aircraft records.

7) 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 Exemption holder’s Manuals. The Aircraft

Operator 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 aircraft record entry must

be added to the Exemption Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection,

and life limit requirements, with particular attention to flight critical

components that may not be addressed in the manufacturer’s

manuals.

9) The Exemption Holder must carry out its maintenance, inspections,

and record keeping requirements in accordance with the Operator’s

Manuals. Maintenance, inspection, and alterations must be noted in

the aircraft logbook, including total flight hours, description of work

accomplished, and the signature of the authorized technician

returning the UAS to service.

10) The authorized technicians must receive and document training

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record

entry in the UAS logbook or equivalent document of the corrective

action taken against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have

logged at least 25 hours of total time as a UA rotorcraft pilot and at

least ten hours logged as a UA pilot with a similar UA type and 5

hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA

must return to a pre-determined location within the private or

controlled-access property and land or be recovered in accordance

with the Exemption Holder’s Manuals.
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15) The Aircraft Operator must abort the flight in the event of

unpredicted obstacles or emergencies, including unauthorized people

entering the flight area, in accordance with the Exemption Holder’s

Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight

unless (considering wind and forecast weather conditions) there is

enough power to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 10

minutes.

17) All aircraft operated in accordance with the exemption must 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 must be as large as

practicable.

18) Before conducting operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate

government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be

available to the Operator at the Ground Control Station of the UAS

any time the aircraft is operating. These documents must be made

available to the Administrator or any law enforcement official upon

request.

20) The UA must remain clear and yield the right of way to all other

manned operations and activities at all times (including, but not

limited to, ultra-light vehicles, parachute activities, parasailing

activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any

moving device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14

CFR 1.1.

23) All operations must be conducted under visual meteorological

conditions (VMC). The UA 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 Operator.

24) During operations the UA may not operate within 5 nautical miles of

the geographic center of an airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that
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airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM, if as required by the Operator’s COA.

The letter of agreement with the airport management must be made

available to the Administrator upon request.

25) The UA may not be operated over congested or densely populated

areas unless the conditions set for in #26 are satisfied. These

populated areas include but are not limited to the yellow areas

depicted on World Aeronautical Charts (WAC), Sectional

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC).

However, aeronautical charts may not reflect pertinent local

information. Ultimately, it is the Operator’s responsibility to

maintain the minimum safe altitudes required by § 91.119 (d) (1).

26) Flight operations must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from debris in the event of an

accident. The Aircraft Operator must ensure that

nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such

protection and are within 30 feet of the UA, flight operations

must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures

where the land owner/controller has granted permission and/or

the Aircraft Operator has made a safety assessment of the risk

of operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an undue

hazard to the Operator per § 91.119(a).

27) 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/controller or

authorized representative will be obtained for each flight to be

conducted.

28) Any incident, accident, or flight operation that transgresses the

lateral or vertical boundaries of the operational area as defined by

the applicable COA must be reported to the FAA’s UAS Integration

Office (AFS-80) within 24 hours. Accidents must be reported to the

National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov.
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Specific Uses Public Benefits

AeroVision Services proposes use of its sUAV provided equivalent or augmented levels

of safety for each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting the

roofs, agriculture land, buildings and large structures site surveys, wild life monitoring,

mosquito and insect control are now conducted by either humans wading through

swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or

otherwise hazardous or by the use of conventional aircraft.

The current procedures can result in significant injuries to the people who must climb on

the roofs or require the use of aircraft that are orders of magnitude greater in size than the

sUAV. Either method, manual inspection or large conventional aircraft, results in

increased risk of injury due to personnel falling off roofs or ladders, carrying heavy

ladders and dealing with confined and dangerous spaces, or increased risk from low

altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage

from storms or other disasters, such as earthquakes or fires. Such flights are, of course,

significantly more expensive than those undertaken with a sUAV.

The present system exposes those not only in the immediate area of inspection, but those

who are along the path of flight associated with the arrival and departure of the

conventional aircraft at the inspection site because the aircraft must be flown to and from

the site. By contrast, the sUAV is carried to the site and transits no other property.

Conventional aircraft carry flammable fuels that are not carried by the UAS and emit

pollutants associated with internal combustion engines. The sUAV’s proposed herein are

battery powered and have no emissions.

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the AeroVision Services’

sUAV 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.

AeroVision Services respectfully proposes that Operator requirements should take into

account the characteristics of the particular UAS. AeroVision Services’ sUAV has a high

degree of pre-programmed control and various built-in technical capabilities that strictly

limit the potential for operation outside of the operating conditions set forth in the

exemption application. The AeroVision Services’ sUAV has navigation and control

system comprised of a Ground Control Station (GCS) and auto-pilot system that can be
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pre-programmed to set operational boundaries. All flights are pre-programmed with

precision GPS guidance.. In the case of unplanned events, the Operator may input preprogrammed evasive maneuvers from the control unit, and the onboard autopilot executes

those maneuvers. Pre-programmed Operator interventions include initiation of holding at

present position; suspension of mission; fly back to launch point; abort mission and land

immediately; and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the AeroVision

Services’ sUAV’s may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and

10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will

hold position at its current location for 5 seconds and if the signal is not

restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft down

in flight in the event of a loss of control or un-commanded deviation from

the flight path.

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph (while

imaging) nor above 200 feet above the structure (imaging altitude) or a

maximum of 400 AGL.

Given these safety features, AeroVision Services proposes that Operators of the 

AeroVision Services’ sUAV 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 private pilot ground instruction and passed the FAA Private Pilot written

examination or FAA-recognized equivalents; have completed the manufacturer’s or

AeroVision Services’ training program for operation of the UAS.

AeroVision Services 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 where 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). Likewise, AeroVision Services

notes that the NPRM does not require that the Operator hold a private pilot license issued

by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the AeroVision Services’ sUAV without a private pilot’s certificate

or a commercial pilot’s certificate, under the conditions set forth herein.
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The risks associated with the operation of the AeroVision Services’ sUAV (given its size,

speed, operational capabilities, and lack of combustible fuel) are so diminished from 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 UA. Given the size of the aircraft and the requirements that the Operator has agreed

to as it relates to airworthiness, as contained in the manual, an equivalent level of safety

will be achieved by insuring compliance with the manuals prior to each flight. The FAA

has granted exemptions to conduct similar operations in Exemptions 11062 through

11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescribed for

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be

needed to allow such operations.

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 the property owner, facility owner, and/or local officials. Because of the

advance notice to the property owner and participants, all affected individuals will be

aware of the planned flight operations as set forth in the Manuals. Compared to flight

operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the

lack of flammable fuel, any risk associated with these operations is far less than those

presently presented by conventional aircraft operating at or below 500 AGL in the aerial

photography industry. In addition, the low-altitude operations of the sUAS will ensure

separation between these small-UAS operations and the operations of conventional

aircraft that must comply with Section 91.119. The FAA has granted exemptions to

conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings
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This regulation requires each person operating an aircraft to maintain cruising 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 the AeroVision Services’

sUAV, in manual or emergency mode, will not have a barometric altimeter display, but

instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to

the procedures set forth in the Manuals as indicated before flight, will achieve an

equivalent level of safety. The FAA has granted exemptions to conduct similar operations

in Exemptions 11062 through 11067, 11080 and 11110.

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

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under

VFR conditions unless (considering wind and forecast weather conditions) there is

enough fuel to fly to the first point of intended landing, and, assuming normal cruising

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be

limited to approximately 10 minutes in length. Given the limitations on the UAS’

proposed flight area and the location of its proposed operations within a predetermined

area, a longer time frame for flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly

controlled area where only people and property owners or official representatives who

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not

engender the type of risks that Section 91.151(a) was intended to alleviate given the size

and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to

30 minutes or 25% of remaining battery power whichever happens first. This restriction

would be more than adequate to return the sUAS to its planned landing zone from

anywhere in its limited operating area. Similar exemptions have been granted to other

operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062,

through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(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 provided in paragraph (c) of this section, have discrepancies repaired as
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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 the Petitioner. Maintenance will be

accomplished by the Operator or manufacturer pursuant to the flight manual and

operating handbook as referenced in the Manuals attached as confidential Exhibits An

equivalent level of safety will be achieved because these small UASs are very limited in

size and will carry a small payload and operate only in defined 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. As provided in the Aircraft Flight Operations Manual

the Operator will ensure that the UAS is in working order prior to initiating flight,

perform required maintenance, and keep a log of any maintenance performed. Moreover,

the Operator and manufacturer are most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

The FAA has granted exemptions for similar operations in Exemptions 11062 through

11067, 11080 and 11110.

*********

Federal Register Publication

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:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge

inspections, flare stack inspection, utility-power generation system inspections and

patrolling, aerial inspection and photography of residential and commercial utility

infrastructure including but not limited to electrical power lines, wind turbines and cell

towers, pipeline inspection and patrolling, filmmaking, cinematography, and

videography, precision agriculture with on board sensors, wildlife and forestry

monitoring and mosquito and insect control, aerial surveying, construction site inspection

and monitoring, public entity support operations, aerial video and live video feed to assist

with search and rescue operations under the authority and support of local authority

officials, aerial video and photography for public and private use including television,

public events, and cinematography live feed and live newsgathering, training to persons

individually or belonging to both private and public organizations to increase awareness

and improve safety for current and future UAS operations within the NAS, special

events: including high schools, Colleges, professional sports, open air events and fairs,

research, risk management and assessment, motion picture production, surface mining,

closed set filming, disaster and catastrophe events.
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Privacy and National Security

All flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Inspection will be of inanimate objects in

areas where the owners will have consented to the inspections or otherwise have

agreed to allow the UAS and the Operator to be in the area where operations will

take place.		

The size of the UAS, its speed and restricted area of operation do not raise national

security issues.

Summary

Approval of exemptions allowing commercial operations of sUAV’s for petitioner to

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack

inspection, utility-power generation system inspections and patrolling, aerial inspection

and photography of residential and commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers, pipeline inspection and

patrolling, filmmaking, cinematography, and videography, precision agriculture with on

board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial

surveying, construction site inspection and monitoring, public entity support operations,

aerial video and live video feed to assist with search and rescue operations under the

authority and support of local authority officials, aerial video and photography for public

and private use including television, public events, and cinematography live feed and live

newsgathering, training to persons individually or belonging to both private and public

organizations to increase awareness and improve safety for current and future UAS

operations within the NAS, special events: including high schools. colleges, professional

sports, open air events and fairs, research, risk management and assessment, motion

picture production, surface mining, closed set filming, disaster and catastrophe events,

will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing people in

swamps, on roofs or tall, hazardous or weakened structures, exposes them to higher risks

than those created by use of a sUAV’S. Conventional aircraft that operate at extremely

low altitudes just feet from the subject being inspected and in extreme proximity to

people and structures present the risks associated with vehicles that weigh in excess of

6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters).

Such aircraft must fly to and from the project location. In contrast, a sUAV weighing

fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the

reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the

target area and not flown. The sUAV will carry no passengers or crew and, therefore, will

not expose them to the risks associated with manned aircraft flights.
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The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant

of the exemptions requested herein. These lightweight aircraft operate at slow speeds,

close to the ground, and in areas that are under the control of the customer for the

operations and, as a result, are far safer than conventional operations conducted with

turbine helicopters operating in close proximity to the ground and people or the use of

individuals to climb the structures to conduct the operations.

Satisfaction 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 for the grant of the requested exemptions allowing commercial operation of

Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions

already granted, including Exemptions number 11171 through 11174, 11176, 11177,

11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely,

Joe Van Antwerp and Edward Ellul, Jr.

AeroVision Services, LLC.

5030 Village Lane Ct

Traverse City, MI		49685

and

Stephen Gowdy

Chief Pilot,

Gowdy Brothers Aerospace, LLC

Consulting Agent for AeroVision Services, LLC.
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APPENDIX A - EXEMPTION PATTERN

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.
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APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain

proprietary confidential business information that is not released to the public and is protected

under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA

PREVIOUS APPROVED EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.
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APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION

NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.
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APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED

EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.
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APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.
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APPENDIX G – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS

MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the public and

is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act

Section 333 (b).

Submitted under separate cover.