data. These simulations will be used for public outreach and comment and will give the public

a realistic simulation
of a project's ultimate build out. 2. The Public Will Benefit From Decreased Congestion Of The NAS. The S1000+ UA is battery powered and serves as a safe, efficient, and economical alternative

to the manned aircraft traditionally utilized to obtain aerial data. By reducing the amount of manned aircraft needed to perform aerial acquisitions,

an exemption allowing the use of an S 1 000+ would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution,

as well as increase the safety of life and property
in the air and on the ground. Furthermore,
by reducing the number of manned aircraft operating
in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The
S 1 000+ UA does not require an airport to takeoff or land. Likewise,

a reduction of manned aircraft conducting aerial survey missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 3. The Public Will Benefit From The Safety And Efficiency Of The 81000+. Conducting aerial acquisitions with the S1000+, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial survey flight operations. By using battery power and electric motors, the S 1 000+ produces no air pollution, and is the most viable environmentally conscious alternative

to the cabin class, six cylinder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The S 1 000+ UA, while 21reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution,

asthe UAis propelled by battery powered electric motors,rather than aninternal combustion engme. By using the S 1 000+to perform aerial data capture,the substantial risk tolife and property
in the air and onthe ground, which
is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crewmembers located onboard the aircraft, the S1000+ UA (maximum grosstake-off weight of approximately

25 pounds,

adiameter of 41.1 inches and height of20 inches) has less physical potential for collateral damage
tolife and propertyonthe ground, andin the air, compared

tothe manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with
awingspan
of approximately

40 feet,
alength of 34 feet, and afuel capacity of 180 gallons). 4. Performing Aerial Data Acquisition Operations With The SlOOO+ Will Benefit The Economy. Inaddition
to being safe and efficient, the S1 000+is also aneconomical alternative

to using manned aircraft toconduct aerial acquisitions.
As such, operation of the S1 000+ will allow United States based companies, like NTI,toremain competitive and contribute

to growth of the U.S. economy. Specifically, with the rising costof aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing outleaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

in order toremain competitive. Operating the battery powered S1 000+is onesuch technology that not only allows companies greater operational flexibility compared

tomanned aircraft, but provides such flexibility without the high operational costof atraditional manned aircraft. 22By operating the S1000+, companies such as NTI can remain competitive and profitable, and therefore, provide greater job stability
to employees and contractors, which will ultimately contribute

to growth of the U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe S1000+, provides

a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies

to invest in research and development

in order to remain competitive both in the United States and abroad. 5. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, NTI'

s proposed operation of the S 1 000+ will not implicate any privacy issues. Specifically, the S 1 000+ will be operated
in accordance with all Federal Aviation Regulations, including the minimum altitude requirements

of 14 C.F .R
.§ 91.119. Most significantly, the S 1 000+ UA will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly involved
in the operation unless: (a) Barriers or structures are present that sufficiently protect nonparticipating person from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating person remain under such protection.

If a situation arises where nonparticipating person leave such protection and are within 500 feet of the UA, flight operations must cease immediately

in a manner ensuring the safety of nonparticipating persons; and (b) The owner/controller

of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made

a safety assessment
of the risk of operating closer to those objects and determined that it does not present an undue hazard. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide
A Level Of Safety At Least Equal To That Provided By The Rule From Which NTI Seeks Exemption. 1. Reasons Why The SlOOO+ Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 23Inconsideration

of the size, weight, speed, and limited operating areaassociated with the unmanned aircraft and its operation, NTI's operation ofthe S1000+ meetsthe conditions ofFMRA Section 333, and will not require anairworthiness certificate
in accordance with14R.Part 21, Subpart H. Section 333 provides authority for aUASto operatewithout airworthiness certification and setsforth requirements
for considering whether

aUAS will create

a hazard tousersof the NASorthe public, orotherwise pose
athreat tonational security. Specifically, FMRA Section 333 statesthe following,

in part: (a)In General.--Notwithstanding

anyother requirement
of this subtitle

,and not later than 180 days after the date of enactment of this Act,the Secretary of Transportation shall determine
if certainunmanned aircraft systems mayoperate safely inthe national airspace system before completion of the plan and rulemaldng required by section332 of this Actorthe guidance required by section334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--ln making the determination under subsection (a),the Secretary shall determine,
ataminimum-- (1)) which types of unmanned aircraft systems,if any,asaresult of their size, weight, speed, operational capability, proximity

to airportsand populated areas

,and operation within visual line of sight do notcreate

a hazard tousersof the national airspace systemorthe public orpose
a threat tonational security

;and (2)) whether

acertificate of waiver, certificate of authorization,

or airworthiness certification under section44704 of title 49, United States Code,
is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--Jfthe Secretary determines under this sectionthat certainunmanned aircraft systems mayoperate safely inthe national airspace system,the Secretary shall establish requirements for the safe operation of such aircraft systems
inthe national airspace system

. In seeking this exemption, NTIsubmits that the S 1 000+ canoperate safelyin the NAS pursuant
toFMRA Section 333,asdemonstrated
by: (a)the characteristics

of the S 1 000+; (b) the pilot certification requirement; and (c)the specific operating 24limitations.

a. The Specifications
Of The SlOOO+ Demonstrate
Its Safe Characteristics. The S1000+ does not create

a hazard to users of the NAS or the public, or otherwise pose
a threat to national security considering
its size, weight, speed, and operational capability.

i. Technical Specifications
Of The SlOOO+. The technical specifications

of the S 1 000+ are set forth on page 22 and 23 of the "S1000_Plus_User_Manual_v1.2_en.pdf,"
attached hereto as Exhibit A. ii. The SlOOO+ Autonomous Flight And Navigation Modes Enable The UAS To Remain Within
A Defined Operational Area. A complete description
of the autonomous modes and methods of navigation of the S 1 000+ is provided
in Section

2 "Basic Flying" and Section

4 "Advanced Features" of the "A2 _Quick_ Start_ Guide_ v1.22 _en. pdf' attached hereto

as Exhibit B. iii. The SlOOO+
Is Designed For Automatic Return To Launch In The Event Of Loss Of The Control Link Or Navigation. A complete description
of the S1000+'s automatic return to launch function
in the event of a break in communication

or loss of telemetry data is set forth in Section 3.1 of the "A2_Quick_Start_Guide_v1.22_en.pdf'
attached hereto as Exhibit B. b. Flight Operations Of The SlOOO+ Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. NTI will only utilize certificated pilots who possess an airline transport, commercial, private, recreational,

or sport pilot certificate. The PIC must also hold
a current FAA airman medical certificate
or a valid U.S. driver's license issued by a state, 25the District of Columbia, Puerto Rico,

a territory,

a possession,

or the Federal government. Additionally,

a safety observer will assist all pilots. Prior to operations conducted for the purpose of aerial data acquisition (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR
§ 61.51 (b), a minimum of200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with
a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained
in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under this grant of exemption

to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants,
and the PIC must operate the UA. c. Flights Of The 81000+ Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, NTI proposes
to commercially operate the S 1 000+ for the special purpose of conducting aerial data capture over areas of the United States, pursuant
to the following specific operating limitations: 1) Operations authorized by this grant of exemption are limited to the following aircraft described
in the operator's manual which
is an eight rotor aircraft weighing less than 55 pounds: DJI S1000+ Unmanned Aircraft System. 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 52.14 knots. 3) The UA must be operated
at an altitude of no more than 500 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. 264) The UA mustbe operated within visual line of sight (VLOS) of the PICatall times. This requires
the PICtobe able tousehuman vision unaided by anyde vice other than corrective lenses, asspecified onthe PIC'sFAA

-issued airman medical certificate
orU.S

.driver's license. 5)All operations mustutilize

avisual observer (VO). The VO may be used to satisfy the VLOS requirement,

aslong asthe PIC always maintains VLOS capability. The VO and PIC mustbe able tocommunicate verbally
atall times

.The PIC mustbe designated before the flight and cannottransfer his or her designation
for the duration of the flight. 6) The operator's manual and this grantof exemption mustbe maintained and made available

tothe Administrator upon request.
If a discrepancy exists between the conditions and limitations

in this exemption and the procedures outlined
in the operator's manual, the conditions and limitations herein take precedence and mustbe followed. Otherwise, the operator mustfollow the procedures

asoutlined
in its operator

'smanual. The operator mayupdate orrevise its operator's manual.

It is the operator's responsibility

to track such revisions and present updated and revised documents

tothe Administrator upon request.The operatormustalso present updated and revised documents

if it petitions for extension
oramendment.

If the operator determines that anyupdate orrevision would affect the basis uponwhich the FAA granted this exemption, then the operatormust petition for amendment totheir exemption. The FAA's UAS Integration Office (AFS-80) maybe contacted
if questions arise regarding updates orrevisions
tothe operator

's manual. 7) Prior toeach flight the PIC must inspect the UAS toensure

it isin acondition for safe flight.If the inspection reveals

acondition that affects the safe operation of the UAS, the aircraft
is prohibited from operating until the necessarymaintenance has been performed and the UASis found tobein a condition for safe flight. The Ground Control Station mustbe included
in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraft records. 8) Any UAS that has undergone maintenance

oralterations that affect the UAS operation
orflight characteristics (e.g. replacement
of aflight critical component), must undergo

afunctional test flightin accordance with the operator

'smanual. The PIC who conducts the functional test flight mustmake an entryin the UAS aircraft records of the flight. The requirements and procedures for afunctional test flight and aircraft record entrymustbe added tothe operator's manual.

279) The preflight inspection mustaccountfor all discrepancies,
i.e. inoperable components, items, or equipment, notcovered
in the relevant preflight inspection sections of the operator's manual. 10) The operatormustfollow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention
to flight critical componentsthat maynot be addressed
in the manufacturer's manuals. 11) NTImust carryouttheir maintenance, inspections, and record keeping requirements

in accordance with the operator's manual. Maintenance, inspection, and alterations mustbe notedin the aircraft logbook, including total flight hours, description
of work accomplished, and the signature of the authorized UAS technician
orPIC returning the UAS toservice. 12) NTIUAS technicians mustreceive and document training referenced

in the operator's manual. 13) Each UAS operated under this exemption must comply with all manufacturer System and Safety Bulletins. 14) NTI maintenance personnel mustmake

arecord entryin the UAS logbook
or equivalent document

of the corrective action taken against discrepancies discovered between inspections. 15) The PIC must possesseither

asport, recreational,

orprivate pilot certificate

aswell asathird-class airman medical certificate
oravalid U.S. driver's license issued by astate,the District of Columbia, Puerto Rico,

aterritory,

a possession,

orthe Federal government.The PIC mustalso meetthe flight review requirements specified
in14 C.P.R.

§ 61.56in anaircraft in which the PICis rated onhis orher pilot certificate. 16) The operator maynot permit anyPICto operateunless that PIC has demonstrated, through the training and currency requirements
setforthin the operator's manual, that the PICis able to safely operatethe UASin amanner consistent with how the UAS will be operated under this exemption, including evasive and emergencymaneuversand maintaining appropriate distances from people, vessels, vehicles and structures. 2817) UAS operations may not be conducted during night, as defmed
in 14 C.F.R.

§ 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 18) The UA may not operate within

5 nautical miles ofthe airport reference point as denoted on a current FAA-published aeronautical chart unless

a letter of agreement with that airport

' s management

is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available
to the Administrator

or any law enforcement official upon request. 19) 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 PIC. 20) 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 operator's manual. 21) The PIC must abort the flight in the event ofunpredicted obstacles or emergencies

in accordance with the operator's manual. 22) The PIC is prohibited from beginning

a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) there is enough power to fly to the first point of intended landing prior to utilizing battery reserve power. 23) The operator must obtain an Air Traffic Organization (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator
to request issuance of a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 24) All aircraft operated
in accordance with this exemption must be identified by serial number, registered
in accordance with 14 C.F.R. Part 47, and have identification
(N- Number) markings
in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable. 25) 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. 26) The documents required under 14 C.F.R. 91.9 and 91.203 must be available
to the PIC 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 29law enforcement official upon request. 27) The UA must remain clear and yield the right of way to all other manned aviation operations and activities

at all times. 28) vehicle. The UAS may not be operated by the PIC from any moving device or 29) The UA may not be operated over congested
or densely populated areas. These 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 PIC's responsibility

to maintain the minimum safe altitudes required by § 91.119. 30) Flight operations must be conducted

at least 500 feet from all nonparticipating persons (persons other than the PIC or VO), 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 operator must 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 must cease immediately and/or; b. the aircraft
is operated near vessels, vehicles
or structures where the land owner/controller
has granted permission and the PIC has made

a safety assessment
of the risk of operating closer to those objects and; c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per§ 91.119(a). 31) 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 prior to the beginning
of every flight. 32) 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. 302. Reasons WhyAn Exemption From The Requirements
Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. NTIsubmits that the equivalent level of safety established
by Section 61.113(a) and (b) will be maintained because noPIC will be allowed
to operatethe S1 000+ unless that PIC has demonstrated, through the S1 000+ training and currency requirements, that the PICis able to safely operatethe S1 000+in amannerconsistent with this exemption, including evasive and emergencymaneuversand maintaining appropriate distances from people, vessels, vehicles and structures. Considering NTI'

sproposed areaof operations, and the operating limitations
set forth-above; the parallel natureof private pilot aeronautical knowledge requirements

tothose of commercial pilot requirements (See Exemption No.11 062); and the airmanship skills necessary

to safely operatethe S1000+, NTIsubmits that the additional manned airmanship experience
of a commercially certificated pilot would notcorrelate
tothe airmanship skills necessaryfor NTI'

sspecific proposed flight operations. The S 1 000+ has been the subject of aprevious Grants of Exemption from Section 61.113(a) and (b). Additionally,
theFAAhas previously granted relief from Section 61.113(a) and (b) specific
to UAS,in circumstances similar, in all material respects,
tothose presented herein(e.g.ExemptionNos.11062, 11063,11064,11065,11066,11067,11080,11109, 11110, 11112, 11136, 11138). Asin Exemption No. 11109, NTIwill notallow anyPICto operatethe SIOOO+ unless that PIChas demonstrated through the S1 000+ training and currency requirements, that the PICis able to safely operatethe S 1 000+in amannerconsistent with this exemption, including evasive and emergencymaneuversand maintaining appropriate distances from people, vessels, vehicles and structures.

31Prior to operations conducted for the purposeof aerial data acquisition (or similar operations), the PIC musthave accumulated and logged, in amannerconsistent with 14 CFR
§ 61.51(b),

aminimum of200 flight cycles and 25 hours of total time asaUAS rotorcraft pilot and atleast tenhours logged
asaUAS pilot with

asimilar UAS type (single blade ormultirotor). Prior documented flight experience that wasobtained
in compliance with applicable regulations maysatisfy this requirement. Training, proficiency, and experience- building flights canalso be conducted under this grantof exemption

to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all personsnotessential for flight operations areconsidered nonparticipants,
and the PIC must operatethe UA. 3. Reasons WhyAn Exemption From The Requirements
Of Section 61.315 Would Not Adversely Affect Safety. NTIsubmits that the equivalent level of safety established
by Section 61.315 will be maintained because noPIC will be allowed
to operatethe S1 000+ unless that PIC has demonstrated, through the S1 000+ training and currency requirements, that the PICis able to safely operatethe S1 000+in amannerconsistent with this exemption, including evasive and emergencymaneuversand maintaining appropriate distances from people, vessels, vehicles and structures. Considering NTI'

sproposed areaof operations, and the operating limitations
set forth-above; the parallel natureof sport pilot aeronautical knowledge requirements

tothose of private pilot requirements and commercially certified pilot requirements; and the airmanship skills necessary
to safely operatethe S 1 000+, NTIsubmits that the additional manned airmanship experience
of a commercially certificated pilot would notcorrelate
tothe airmanship skills necessaryfor NTI'

sspecific proposed flight operations. 32The S 1 000+ has been the subject of a previous Grants of Exemption from Section 61.113(a) and (b). Additionally,
the FAA has previously granted relieffrom Section 61.113(a) and (b) specific
to UAS, in circumstances similar, in all material respects,
to those presented herein (e

.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). NTI will not allow any PIC to operate the S 1 000+ unless that PIC has demonstrated through the S 1 000+ training and currency requirements, that the PIC is able to safely operate the S 1 000+ in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Prior to operations conducted for the purpose of aerial data acquisition (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b),

a minimum of200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with

a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained
in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under this grant of exemption

to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants,
and the PIC must operate the UA.

334. Reasons Why An Exemption From The Requirements
Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established
by Section 91.7 (a) will be maintained because prior to every flight, NTI will ensure that the S 1 000+ is in an airworthy condition based upon the UA's compliance with its operating documents (i.e., the S1000+ Flight Manual), and as stated in the conditions and limitations herein. The S 1 000+ has been the subject of previous Grants of Exemption from Section 91.7(a). Additionally,
the FAA has previously granted relief from Section 91

.7(a) specific
to UAS, in circumstances similar,
in all material respects,
to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112, 11136, 11138). 5. Reasons Why An Exemption From The Requirements
Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established
by Section 91.121 will be maintained because the altitude information
of the S 1 000+ UA will be provided

to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring
of the flight path. This altitude information, combined with NTI'

s operation of the S 1 000+ UA within visual line of sight, at or below 500 feet AGL, will ensure

a level of safety equivalent

to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight,

a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. The S 1 000+ has been the subject of previous Grants of Exemption from Section 91.121. Additionally,
the FAA has previously granted relief from Section 91.121 specific
to UAS, in circumstances similar, in all material respects,
to those presented herein (e.g. Exemption Nos. 11062, 11063, 3411064,11065

,11066,11067,11080,11109,11112

,11136, 11138). 6. Reasons WhyAn Exemption From The Requirements
Of Section 91.151(b) Would Not Adversely Affect Safety. A grantof this exemption would ensurean equivalent level of safety established
by14 C.F.R. Section 91.151(b)

asaresult of (1)the technical specifications

of the S1000+; (2)the limitations
onthe proposed flight operations; and (3)the location of the proposed flight operations. Accordingly, NTIwill ensurethat it cansafely operatethe battery powered

S1 000+ UA during daylight hours

,in VFR conditions, for atotal flight duration of nomorethan 20 minutes, resulting
in alanding with five minutes of battery power remaining. Here,asin Exemption No. 11109, the technical specifications

of the S1000+

; the limitations
onthe proposed flight operations; and the location of the proposed operations

, will ensurethat NTI maysafely operatethe battery powered S1000+ UA during daylight hoursin VFRconditions for atotal duration of notmorethan 20 minutes, and landing with five minutes of battery power remaining. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics
and operating limitations
of the UAS areconsidered. Relief has been granted for manned aircraft to operate
atless than the minimums prescribed

in Section 91

.151, including Exemption Nos

. 2689,5745, and 10650

.Moreover,the FAA has previously granted relieffrom Section 91.151 specific
to UAS,in circumstances similar, in all material respects,
tothose presented herein (e.g. Exemption Nos

.8811, 10808

,10673, 11042

,11062

,11063, 11064, 11065, 11066, 11067,11080,11109

,11110,11136, 11138). 357. Reasons WhyAn Exemption From The Requirements
Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l)

& (a)(2), And 91.417(a)

& (b) Would Not Adversely Affect Safety. In seeking this exemption, NTIsubmits that the equivalent level of safety with regard tothe regulatory maintenance and alteration requirements established
by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b) will be metbecause NTIwill useits trained technicians

to perform maintenance, alterations,

or preventive maintenance

onthe unmanned aircraft system using the methods, techniques, and practices prescribed

in the manufacturer's maintenance manual. Furthermore, NTIwill document and maintain all maintenance records for the S1 000+. Since the S1000+ will be inspected

asprescribed by the manufacturer's maintenance manual, NTIwill maintain the equivalent level of safety established
by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). The Flight Manual for the S1000+ setsforth airworthiness requirements
for the UA, including preflight and post flight inspections. Maintenance schedules and check lists arereferenced

in "Pilot Operating Handbook-S1000.pdf' attached hereto asExhibit C. Likewise, the exemption sought will not adversely affect safety because NTIwill perform maintenance, alterations
or preventive maintenance
onthe UAS using the methods, techniques, and practices prescribed
by the manufacturer's maintenance manual. The Flight Manual for the S1000+ details procedures for each component
of the UA, including the components
of the propulsion system,avionics system,and payload system. Furthermore,
the exemption sought would maintain an equivalent level of safety established
by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance

of the S1 000+ will be performed by NTItrained technicians, who will document and maintain 36maintenance records for the S1 000+. In consideration

of NTI'

sproposed operating limitations, the mostrecent

S1 000+ Flight Manual, and the technical aspectsof the S1 000+, NTIsubmits that safety will notbe adversely affected by granting exemption from14 C.P.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAAhas previously granted relief specific
to UASin circumstances similar, in all material respects,
tothose presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11110, 11112, 11136, 11138).
8. The FAA MayPrescribe Any Other Conditions ForSafe Operation. Inaccordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and14 C.P.R.

§ 21.16 entitled Special Conditions, NTI requeststhat the FAA prescribe special conditions for the intended operation of the S1000+, which contain such safety standards that the Administrator finds necessary
toestablish

alevel of safety equivalent tothat established
by14 C.P.R. Part 21, Subpart H,and14 C.F.R §§ 61.113(a)

& (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b). Such special conditions will permit safe operation of the UAfor the limited purposeof conducting aerial acquisitions overcertain areasof the United States. FMRA Section 333 setsforth the requirements
for considering whether

aUAS will create

ahazard tousersof the NAS or the public, orotherwise pose
athreat tonational security; and further, provides the authority for such UASto operatewithout airworthiness certification

in accordance with any requirements that mustbe established for the safe operation of the UASin the NAS. Likewise, the Administrator may prescribe special conditions pursuant
to14 C.F .R. § 21.16, for operation of the S1000+, since the airworthiness regulations
of14 C.P.R. Part 21do notcontain adequate
or appropriate safety standards, due tothe novel orunusual 37design features of the aircraft. Section 21.16, entitled Special Conditions, statesthe following: If theFAA finds that the airworthiness regulations
of this subchapter
do notcontain adequate
or appropriate safety standards for anaircraft, aircraft engine, orpropeller because of anovel orunusual design feature of the aircraft, aircraft engine or propeller,
he prescribes special conditions and amendments thereto for the product. The special conditions areissuedin accordance with Part11of this chapter and contain such safety standards for the aircraft, aircraft engine orpropeller
astheFAA finds necessary
toestablish

alevel of safety equivalent

tothat established

in the regulations. See14 C.F.R.

§ 21.16. Therefore,

in accordance with FMRA Section 333 and14 C.F

.R. § 21.16, theFAA may prescribe special conditions for NTI'

sintended operation of the S1 000+, which contain such safety standards that the Administrator finds necessary

toestablish

alevel of safety equivalent

tothat established
by14 C.F

.R.Part 21, Subpart H,and14 C.F.R Sections 61.113(a)

& (b), 61.315 (a), (b) & (c), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b). F.
A Summary That Can BePublished
InThe Federal Register, stating: The Rules FromWhich NTISeeks Exemption: NEEDMORE TOWERS, INC,seeks exemptionfrom

the requirements
of14 CF.R Sections 61.113(a)&(b)

,61.315 (a), (b), & (c)

,91

.7(a)

,91.121, 91.151(b)

,91.405(a), 91.407(a)(l)

,91.409(a)(l)

& (a)(2), and 91.41
7 (a)& (b)
. ABrief Description Of The NatureOf The Exemption NTISeeks: This exemptionwill permit NEEDMORE TOWERS

,INC

,to commercially operate anUnmanned Aircraft System (UAS) for the purposeof conducting aerial data acquisitionoverareasofthe United States. 38G. Any Additional Information, Views, Or Arguments Available To Support NTI's Request. This Petition

is made pursuant
tothe FAA Modernization
and Reform Actof 2012 (FMRA) Section 333, which directs the Secretary of Transportation

todetermine

if certain UAS mayoperate safelyin the NAS. As such, NTI's requestfor exemption may be granted pursuant
tothe authority ofFMRA Section 333 and14 C.P.R. Part 11, asset forth above. FMRA Section 333 setsforth the requirements
for considering whether

aUAS will create

ahazard tousersof the NAS orthe public, orotherwise pose
athreat tonational security; and further, provides the authority for such UASto operatewithout airworthiness certification. As discussed
in detail above, NTIwill operatethe S1 000+ safelyin the NAS, without creating

ahazard tousersof the NAS, orthe public, orotherwise pose

athreat to national security. CONCLUSION Assetforth herein, Needmore Towers,Inc.seeks an exemption pursuant
to14 C.P.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the DJI Innovations Spreading Wings S 1 000+ Unmanned Aircraft commercially, without anairworthiness certificate, for the limited purposeof conducting aerial acquisitions overareasof the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization
and Reform Actof 2012, while also advancing the interests of the public, by allowing NTIto safely, efficiently, and economically operatethe S1 000+ commercially within the NAS.

39WHEREFORE,

in accordance with the Federal Aviation Regulations and theFAA Modernization
and Reform Actof 2012, Section 333, NTI respectfully requeststhat the Administrator grantthis Petition for an exemption from the requirements

of14 C.F.R Sections 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b), and permit NTIto operatethe S1000+ commercially
for the purposeof conducting aerial data capture

. Dated: June 8, 2015 NEEDMORE TOWERS, INC. MarkA. Ekse Hagen,Wilka
& Archer, LLP Attorneys for Petitioner cc:Eric Taylor

40