November 11 th , 2015

U.S. Department of Transportation Docket Operations, M
- 30 1200 New Jersey

Avenue, SE Room W12
- 140, West Building Ground Floor Washington, DC 20590
- 0001 Re: **Petition of Aerospec Technologies, LLC**  **for an Exemption Pursuant to Section 333 of**  **the FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System**  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, Aerospec Technologies, LLC (“Aerospec Technologies”) hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the following aircraft:

 Yuneec T yphoon Q500  Sense Fl y eBee RTK  3DR Solo  Delair
- Tech DT 18  Precision Hawk Lancaster Hawkeye Mark III  Microdrone MD4
- 200  Aeryon Scout  Aeryon Sky

ranger Where all equipment is being referenced they will be referenced as (“THE EQUIPMENT”). **I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED**  Aerospec Technologies requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;  14 C.F.R Part 27;  14 C.F.R § 45.11 ;  14 C.F.R § 45.23(b);  14 C.F.R. § 45.27(a);  14 C.F.R § 61.113;  14 C.F.R § 91.7(a);  14 C.F.R § 91.9(b)(2);  14 C.F.R § 91.9(c);  14 C.F.R § 91.103; 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;  14 C.F.R § 91.121;  14 C.F.R § 91.151(a) ;  14 C.F.R § 91.203 (a) & (b);  14 C.F.R § 91.405(a);  14 C.F.R § 91.407(a)(l);  14 C.F.R § 91.409(a)(2);  14 C.F.R § 91.417 (a) & (b). **II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS**  This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft sy stems into the national airspace sy stem.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft s ys tem where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national security based on the following consideratio ns:

 The size, weight, speed and operational capability ;  Operation in proximity to airports and populated areas; and  Operation within visual line of sight of the operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency ’s safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701
- 44716, et seq. A party requesting an exemption must explain the reasons wh y the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81. **III. DESCRIPTION OF**  **AEROSPEC TECHNOLOGIES AND ITS S**  **ERVICES** Aerospec Technologies intends to conduct operations for filmmaking , aerial photograph y and inspections in various industries including utilit ies , railroad transportation , pipeline transportation , oil
- field services , petro/chemical/manufacturing, construction, and agriculture. The contact information for the petitioner, Aerospec Technologies , is as follows: Lance Li Co
- founder and CEO PO BOX 16032 Sugar Land, TX 77496**IV. DESCRIPTION OF PROPOSED**  **UAS OPERATIONS** 

Aerospec Technologies is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to utilize UAS to conduct aerial operations for our clients including data gathering, inspection, survey services and others. We will equip our UAS with various sensors and cameras that will allow them to broadly and more efficiently optimize and maintain the quality of our clients' operations. We will operate our UAS in support of the operations in various industries in cluding oil and gas, renewable energy, infrastructure, construction, agriculture, minerals, photography, filmmaking and others. **A. The**  **Aircraft** Aerospec Technologies hereb y applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the following aircraft:

 Yuneec T yphoon Q500 (“Q500”)  Sense Fl y eBee RTK (“eBEE”)  3DR Solo (“SOL O”)  Delair
- Tech DT 18 (“DELAIR”)  Precision Hawk Lancaster Hawkeye Mark III (“HAWKEYE”)  Microdrone MD4
- 200 (“MD4”)  Aeryon Scout (“SCOUT”)  Aeryon Sky

ranger ( “ RANGER”) **Yuneec Q500 Typhoon** The Q500 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone s ys tems. The Q500 UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. It is manufactured b y Yuneec, Inc. and has the manufactur er ’ s model designation Q500 Ty phoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that is not to be used for flight by the PIC. The UAS has the ability

to link with a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. 1. Aircraft a. Dimensions i. Height 240mm (9.45 in) ii. Width 420mm (16.54 in) iii. Diagonal Length W\O Rotor Blades 565mm (22.2 in)iv. Propeller/Main Rotor Diameter 330mm (13.0 in) b. Flight Time up to 25 minutes c. Weight with B attery

and Payload 60.0 oz (1700g) d. Weight without Battery and Payload 40.0 oz (1130g) e. Battery 5400mAh 3S 11.1V L iPo (included) f. Charger 3S 11.1V L iPo DC Balancing Smart Charger with AC Adapter (included) g. Transmitter 10
- channel 2.4GHz with 5.8GHz video down link (included) h. 3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home i. Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the Ty

phoon GUI) j. Maximum Rotation Rate 65°/s k. Maximum Roll Angle 35° l. Operating Temperature Range −5° C to 80°C m. Radio Control Frequency Band 2.4GHz n. Max. Descent Speed 2m/s o. Max. Flight Speed 8m/s 2. Gimbal a. Ty pe CGO3 b. Weight 6.9oz (195g) c. Focusing Sy stem Aerial Optimized Fixed Focus d. Field of View 115° e. Video Transmission Range i. FCC Compliance: Up to 600m (1968.5 ft) ii. CE Compliance: Up to 300m (984.252 ft) with ST10 f. Video Resolution i. UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS ii. FULL HD: 1080p at 24/25/30/48/50/60/120FPS g. Photo Resolution 12 Megapixels h. Storage (memory) microSD Class 10 ~ 4 to 128 GB i. Control Angle Ac curacy ±0.02° j. White Balance Automatic or manual settings k. Transmission Band 5.2GHz

– 5.8GHz l. Input/Operating Voltage 12V m. Working Temperature −10°C

– 50°C n. Storage Temperature −20°C

– 60°C o. Angular Vibration Range ±0.02° p. Control Range i. Pitch: between −90° and 0° ii. Yaw: between 0° and 360° q. Microphone Yes r. Camera Lens 0.6in (14mm)/f2.8 (1.4in/35mm)

— No distortion s. Sensor 1/2.3 ′′ CMOS 3. Personal Ground Station a. Ty pe ST10+b. Operating S ys tem AndroidTM c. Number of Channels 10 d. Control Transmission Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual L ine of Sight of Aircraft at All Times e. Robust Radio Control Modulation Yuneec Protocol f. Video L ink Frequency Band 5.8GHz g. Video Transmission Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual L ine of Sight of Aircraft at All Times h. Flight S ys tems Telemetry Data On Screen Di splay Yes i. LED Backlit L CD Screen Capacitive Multi
- touch 5.5 ′′ j. Tactile (Vibrating) and Audible Feedback Yes k. Built
- in L iPo Battery

Voltage / Capacity 3.6V/5200mAh 18.72Wh l. Screen Resolution 854 × 480px m. Camera Settings White balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take pictures The Q500 has been approved for commercial operations in Exemption Nos. 12360, 12730 , 12684, 12680, 12637, 12833, 12923, and 12697
. **Sensefly eBEE** The Sensefl y eBee is a small (37.8 inches wingspan) an d ultra
- light (maximum take
- off weight of 1.7 pounds) platform made of flexible foam that performs pre
- programmed precision aerial mapping missions thanks to the on
- board GPS and the related flight management software (eMotion) that allows the operator to safel y and efficiently plan a mission, and then monitor it in real
- time. Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of high
- definition still images that are used later to generate maps and contour l ines of the surveyed area. The four main characteristics of the Sensefl y eBee are: 1. Very light weight The eBee is so light that the operator can launch it by hand and let it land on almost any surface without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a controlled emergency landing) also significantl y reduces the risk of hazardous situations. Finally , the wings of the eBee are detachable and made of flexible foam with no sharp or hard edges and almost no int ernal strengthening structure. 2. Electric
- powered The eBee is electric powered. A brushless engine technology makes it silent and reliable. The propeller is attached with a rubber band to the body of the plane so that it can easil y flex away in case of conta ct with any object. 3. Semi
- automatic flight The artificial intelligence incorporated within the eBee autopilot sy stem continuously anal yz es data from the In ertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator. 4. Option for m anual controlAdditionally , the eBee provides an override capability that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automat ed operations and take manual control of the aircraft should it become n ecessary to respond emergent circumstances, thanks to the remote controller provided with the sy stem. Technical S pecifications A. Hardware a. Weight (inc. supplied camera) Approx. 0.73 kg (1.61 lb) b. Wingspan 96 cm (38 in) c. Material EPP foam, carbon structure & composite parts d. Propulsion Electric pusher propeller, 160 W brushless DC motor e. GNSS/RTK receiver L1/L2, GPS & GLONASS f. Battery 11.1 V, 2150 mAh g. Camera (supplied) WX (18.2 MP) h. Cameras (optional) S110 RGB, S110 RE, S110 NIR i. Carry case dimensions 55 x 45 x 25 cm (21.6 x 17.7 x 9.8 in) B. Operation a. Maximum flight time 40 minutes b. Nominal cruise speed 40
- 90 km/h (11
- 25 m/s or 25
- 56 mph) c. Radio link range Up to 3 km (1.86 miles) d. Maximum coverage (single flight) 8 km /3 mi (at 974 m/ 3,195 ft altitude AGL) e. Wind resistance Up to 45 km/h (12m/s or 28 mph) f. Ground Sampling Distance (GSD) Down to 1.5 cm (0.6 in) per pixel g. Relative orthomosaic/3D model accuracy 1
- 3x GSD h. Absolute horizont al/vertical accuracy (no GCPs) Down to 3 cm (1.2 in)/ 5 cm (2 in) i. Multi
- drone operation Yes (inc. mid
- air collision avoidance) j. Automatic 3D flight planning Yes k. Linear landing accuracy Approx. 5 m (16.4 ft) The eBEE has been approved for commercial operat ions in Exemption Nos. 12710, 12673, 12656, 12647, 12619, 12571, 12577, and 12697
. **3DR SOLO** The SOLO is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone s ys tems. The SOLO UAS is equipped with four main electric powered rotors driven by L ithium Poly

mer batteries. Specifications: 1. General a. Weight: 3.3 lb / 1.5 kg. b. With Solo Gimbal and GoPro: 4 lb 2. Performancea. Maximum Speed : 55 mph / 88.5 km/h b. Maximum Altitude : 400' / 121.9 m AGL c. Flight Time : Up to 25 minutes 3. Flight Control Sy stem a. Model : Pixhawk 2 b. Software : APM flight control software and GPS 4. Handheld Transmitter a. Display : Color Screen for menu and live flight telemetry b. Battery : Lithium
- poly mer Capacity: 5200 mAh . Voltage: 14.8 VDC L ife: Up to 4 hours c. The 3DR Solo remote controller has an operating frequency of 2.4 GHz for telemetry and control. d. Maximum transmission distance: up to 2,500 ft (outdoors and unobstructed) 5. Mobile App a. Sy stem Requirements: Wi
- Fi enabled iOS or Android mobile device b. Wi
- Fi Range : Up to 2640' / 805 m (depending on environment) 6. FPV and Monitoring a. Video Downlink Latency: 180 ms b. Connectivity : 1 x HDMI output on Transmitter 7. Components a. Rotors : 4 x 10 x 4.5" / 25 .4 x 11.4 cm self
- tightening props b. Motors Velocity

Constant: 880 kV c. Gimbal Compatibility : Solo Gimbal for HERO3+ and HERO4 GoPro Camera 8. Flight Battery a. Model : Solo Battery

Voltage14.8 VDC b. Lithium
- poly

mer Capacity

5200 mAh The 3DR Solo has been approved for commercial operations in Exemption Nos. 12462, 12494, 12441, 12544, 12433, and 11935
. **DELAIR DT -**  **18** The DT
- 18 was conceived and manufactured by Delair
- Tech. Over ten DT
- 18 have been sold to date. Globall y, the DT
- 18 has completed 521 flights for a total of 231 flight hours and 12,600 km covered. The DT
- 18 is hand launched and lands on its belly. It typicall y lands with a 5m precision. Every aspect of the landing is automatic. It is the first and only UAS certified b y the Direction Ge nerale de l’Aviation Civile (DGAC) for flight beyond line of sight (BLOS) up to 15km from the base station in the French civilian airspace (Scenario S4). However, flights pursuant to the requested exemption will be operated within visual line of sight (VLO S) of the pilot in command (PI C).3 The DT
- 18 is equipped with six control surfaces. It has one aileron on each wing, one flap on each wing, and two ruddervators located on the empennage. The flaps are only used on landing. They are also automatically

depl oyed in case of an over speed to act as speed brakes
.1. Ty pe of Motors Brushless, outrunner 2. Cruise Speed 31 mph (50 km/h) 3. Max speed 49.7 mph (80 km/h) 4. Power 4S 8900mAh L i
- Po, 270W Max Power 5. Weight 4.4 lbs (2kg) 6. Maximum Endurance 120 minutes 7. Wingsp an 5.9 ft/1.8m 8. Fuselage length 3.9 ft/1.2 m 9. Takeoff/landing Hand or catapult/belly or net 10. Wind resistance 31 mph (50 km/h) 11. C2 range 25 mi/40 km (857 MHz) 12. Data link range 9.3mi/15 km (5.8 Ghz) The DT
- 18 Ground Control Station (GCS) serves as the operator interface, coordinating the mission and communication functions including mission planning, near real
- time mission progress, video display , and function monitoring. The GCS consists of a laptop and mission planning/execution software (SolApp), a case with a built
- in joystick and slider, a back
- up controller, a steerable command and control link antenna, and a steerable data link antenna. The SolApp program conducts mission planning for the DT
- 18, with complete route planning to include way

points, identify

No
- Fl y zones, and take into consideration the terrain height. All of the takeoff and landing is planned in SolApp. The mission planning information is up
- loaded to the DT
- 18 prior to flight. SolApp also has the ability to change and upload all mission planning during flight via the Command and Control link. As part of the mission execution, SolApp has a check
- list that confirms the following:

 DT
- 18 assembl y  Internal sensor (magnetometer, GPS, etc) calibration  Payload functionality  Weather input s  Carrying case controller (joy stick and slider) calibration  Antennae placement and calibration  Uploading of mission information to DT
- 18  During flight, SolApp provides complete management of the DT
- 18 mission.  The following is provided during flight to the operator:

o Moving map showing the location of the DT
- 18 o Speed o Heading o Altitude o Climb rate o Link status o Battery

status o All safety s ys tems and alarmsThe DT
- 18 s ys tem operates under autopilot during missions, or can be controlled by the joy stick and slider built into the GCS. The joy stick and slider operate through the command control link of the GCS. The DT
- 18 sy stem also includes a back
- up controller, which operates on a separate link from the GCS. The operator can b ypass the DT
- 18 autopilot with the back
- up controller. The command and control and data link antennae are part of the GCS. The two antennae are mounted on a motorized steerable mount that will automatically track the location of the DT
- 18. The main command and control link between the DT
- 18 and the GCS operates at a frequency of 915 MHz (I SM Band). This link provides all the DT
- 18 flight information back to the GCS and provides any updates to the mission from the GCS to the DT
- 18. The DT
- 18 uses the XBee
- Pro 900HP Modem, which has FCC re gulato ry approval. The data link on the DT
- 18 allows for the payload information to be transmitted in near real
- time between the DT
- 18 and the GCS. The data link operates at a frequency of 5.8 GHz
. The DELAIR has been approved for commercial operations in Exemption No
. 11524
. **The HAWKEYE** The Precision Hawk Hawkeye Lancaster MK
- III UAS is a single electric motor fixed wing aircraft. Wing span is 1.5 m and power is delivered with a 28 cm propeller. Power source is a 12.6 volt, L ithium
- Poly

mer battery with a 3900 mah capacity. Payl oad will be various cameras and sensors. Gross weight will remain below 6 lbs regardless of payload. Flight is controlled b y two (2) on board computers with one dedicated to vehicle control and stability with the second computer dedi cated to mission control and vehicle status monitoring. The aircraft is equipped with a global positioning sy stem (GPS), Inertial Measurement Unit (IMU), and Compass that work in unison to stabilize the aircraft and render safety features. The aircraft can be programmed to not fl y above 400 feet AGL and to not fly outside of a pre
- determined flight zone. These s ys tems will also initiate the failsafe function. If the aircraft loses the signal from the transmitter, the GPS sy stem will automatically initiate the failsafe mode and fly the aircraft back to a pre - determined location and land automatically
. The HAWKEYE has been approved for commer cial operations in Exemption Nos. 11273 , 1 1573 , 11551 , and 11345. **MD4** The microdrones md4
- 200 UAV is a miniaturised VTOL aircraft (Vertical Take Off and Landing). It can fl y b y remote control or automatically using our GPS Waypoint navigation software
. The md4
- 200 aerial vehicle consists of a carbon fiber body , boasts a fl yi ng time of 30 minutes and can carry

a load of up to 250 g. Rain, snow and dust pose no particular problem for microdrones UAVs.The ultra
- lightweight robust and weather

– resistant carbon fibre body enables the md4
- 200 to reach an operating height of up to 1000 met er s - ideal for aerial photography an d aerial inspections. 1. Technical Specifications a. Vehicle mass: 800g b. Payload mass (recommended): 150g c. Payload mass (maximum): 250g d. Maximum take
- off weight: 1100g e. Battery : 4S L iPo, 14.8V, 2300mAh f. Climb rate: 7.0 m/s g. Cruising speed: 8.0 m/s h. Peak thrust: 15. 5N i. Endurance: i. up to 30 min ii. Endurance can alway s vary with wind/weather, payload and age of battery iii. with 150g payload the average is 15min j. Flight radius: i. max. 500m on C&C ii. max. 6000m on WP k. Service ceiling: 2000m ASL 2. Operational Conditions a. Temperature ran ge: - 10..40°C b. Humidity : max 90% r.H. c. Wind tolerance: i. steady pictures up to 4 m/s ii. max. up to 8 m/s d. Dimensions i. Diameter: 540mm ii. Height: 230mm The MD4 has been approved for commercial operations in Exemption No. 11171A
. **Aeryon SCOUT**  **and RANGER** The Scout and Sky

Ranger are quad
- copter typ e vertical takeoff and landing small UAS, with four rotors mounted on booms and four legs. Payloads are mounted underneath the fuselage on a gimbal mount. Communications use common frequencies and are digitall y encry pted, which reduces the risk of hijacking and video interception. The aircraft are controlled with a tablet based interface, reducing pilot fatigue and workload. The aircraft are piloted by

the use of a stylus, pointing to an area on a moving map display . Alt itude is controlled by

using a slider bar on the touch screen interface to command the aircraft to climb or descend.The sy stem is full y stabilized and GPS guided. Custom or commerciall y available map data in

several formats may

be used for operator orientation. The aircraft can be flown real
- time by the operator or pre - programmed to fly a series of GPS way

points. While the aircraft is fl yi ng its pre
programed flight path, the operator alway s has full control of the vehicle and can change its flight path o r altitude immediately . Flight information such as position, altitude, environmental conditions, signal link strength, GPS signal strength, battery voltage, and other flight data is displayed to the operator in real time. The aircraft itself is constantly monitoring environmental and sy stem conditions and will alert the operator to any abnormalities. The aircraft have many built in failsafe mechanisms that will allow return to the point of origin and vertical landing if an emergency condition exists. The aircraft and payloads are gy ro stabilized, allowing for exceptional imaging and resolution quality at safe distances from infrastructure, which is essential for safe and effective inspections. The aircraft have a quick
- change payload interface with common interfaces including USB and Ethernet, which allows custom payloads to be developed. The sy stem is able to detect the type of payload connected, and configure it and operate it appropriatel y. The payload capacity of the s ys tem is 250 g (0.55 pounds). Offered payloads include gimbal
- mounted digital still and video cameras, a near IR camera for remote sensing, a FLIR night
- vision camera, and a stabilized 10x Optical Zoom camera. **Aeryon Scout Technical Specifications**
• Deploy

ment : Vertical Take
- off and Landing
• Operation : Range 1 Mile
• Operational Duration : Up to 20 Minutes
• Operational Velocity : Up to 30 mph
• Wind L imits : Up to 30 mph (Gusts up to 50 mph)
• Dimensions : 31.5 in. x 31.5 in x 7.9 in
• Max Weight : 3.4 pounds
• Power Source : 11. 1V Intelligent LiPo Battery **Aeryon Sky Ranger Technical Specifications**
• Deploy

ment : Vertical Take
- off and Landing
• Operation Range : 2 Miles
• Operational Duration : Up to 50 Minutes
• Operational Velocity : Up to 30 mph
• Wind L imits : Up to 40 mph (Gusts up to 55 mph)
• Dimensions : 40 in. x 40 in. x 9.3 in.
• Max Weight : 5.3 pounds
• Power Source : 14.8V Intelligent LiPo Battery **Command and Control Systems**The Aeryon Ground Control Station allows the operator simultaneous control over aircraft and

payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. Displayed on GCS:
• Position
• Navigation Route
• Altitude
• Heading
• Battery

voltage and time remaining
• GPS signal strength
• Radio link strength
• Aircraft status to include error messages or failures
• Date/time
• Sensor position and orientation relative to sUAS On
- board Flight Instruments

– The sUAS is equipped with an Inertial Navigation Sy stem (3
- axis gy roscope, magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement. On

– board computer s ys tems

– The sUAS is equipped with on
- board computer sy stems to monitor (sensors, battery , etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry , etc.). On
- board guidance and navigation equipment

– The sUAS can operate autonomously ; it does not require any input from ground
- based e quipment, or from the pilot to hover in place. Frequency

Allocations

– 900 MHz and 2.4 GHz. Fly away protection

– To prevent a “fl y away” or other potentially dangerous situations, the aircraft emplo ys a s ys tem of fail
- safes that will either return the aircraft to its home origin point or land the aircraft in its present position
. Takeoff and Landing

– The sUAS has vertical lift autonomous launch and recovery . A Landing Zone (“LZ”) is designated b y the operators and identified in the GCS software. For l aunch procedures the aircraft will take off and hover 3 meters directl y above the LZ and hold until further operator instruction is given. The aircraft will automatically adjust for wind during this period. Navigation Sy stem

– Specific maps, such as air sectional and geographic maps, can be downloaded to the display screen and overlaid with GPS positional data. Way points can be created before and during flight operation creating specific locations and sequences for the aircraft.Redundant Sy stems

– The s UAS combines the input from a multitude of sensors.

Even though the data from all sensors is required for optimal sy stem performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. **Em ergency Procedures and System Failures**  Engineered Failsafe Mechanisms Lost Communications The sUAS does not need constant signal from the tablet to continue fl yi ng. Communication outages are detected b y the sy stem and are reported to the pilot. During the communication outage the aircraft will hover in place, climb to a pre
- set safe altitude, and then fly to its takeoff location. If communication is still not established the aircraft will descend slowly and make a landing at the point of takeoff. All of this is accomplished without input from the operator. If the aircraft receives interference or another overpowering signal, the s ys tem will simply go into its lost communication procedure as stated above. It will climb to a safe altitude, fly home and land. Communications Data Security All communication links are encry pted. The communication sy stem and protocol is designed in such a way

that control of the aircraft cannot be taken over by accident. The video feed is also encry pted. An y unauthorized perso n attempting to receive the video would see a scrambled picture. Battery L ife The battery

voltage and flight time remaining are displayed to the operator throughout the flight. When 3 minutes of flight time is remaining, a warning is given to the operator
. If the operator does not bring the aircraft home, the sy stem will return home (takeoff point at a safe transit altitude) on its own. The sUAS is equipped with an intelligent battery monitoring s ys tem that will allow it to leave its present position and f ly home with reserve battery power to make a safe landing under current environmental conditions. Ignition Source Resistant The aircraft are equipped with a sealed LiPo battery pack and is operated b y 4 brushless electric motors. The brushless motors, by their design, do not spark or arc while being operated. The operating temperature of the motors and the battery is extremel y low. Potential Component Failures The aircraft have highl y engineered s ys tems monitoring software. Examples include battery health and temperature, voltage going to the motors, GPS accuracy , magnetic anomalies, vibration sensing, and yaw detection. There is a warning prior to any major failure, giving time to safel y manage the situation. If the failure is considered “non
- fatal,” it will return home and land. If it is considered “fatal,” it will set down immediately at its present position. Automatic pre - flight checks prevent the UAS from taking off if problem conditions are present.Defined “No Fl y Zones”

T he navigation software all ows for preplanning No Fly Zones which can allow the operator to maintain clearance from any “prohibited areas.” The Scout and Sky Ranger will operate with geo - fencing. This technology allows the operator to effectivel y put a GPS based perimeter around the area of operations which will keep the aircraft in a designated “operational box” regardless of normal or emergency operations. The geofence is custom designed and can be adjusted based on each location of operation. Visual L ine
- of

- Sight Loss All flight operations will be conducted with the sUAS within visual sight of the pilot. I f for some reason the pilot’s view becomes obstructed and line
- of
- sight is lost, the aircraft will hover in position until line
- of

- sight is reestablished. The SCOUT and RANGER h ave been approved for commercial operations in Exemption No s. 11209, 11240, 11265, 11252, 11259, 11436, 11576, 11673, 11665, 11830, 11230A, 12077, 11447B, 12140, 12387, 12195, 13076, 12658, and 11534
. Considering the programmability and safety features of these UAVs, it serves as the best option to protect the Public and NAS for the purposes of this petition. **Similarities, Distinctions and Differences** Aerospec Technologies is using UAV s that have the capability for taking off and landing at a single point, identical to a helicopter. There are no runway s, aided take off apparatuses, nor routes that need to be flown to operational areas , thus allowing for a reduced and more confined area of flight. The motors, rotors, propellers, body /frame, landing pads, etc. for the UAV s utilized in this petition are not complicated. Engineering and design allows lay man maintenance. Pre
- flight inspections for cracks, damage or other phys ical conditions that could hamper safe flight will be conducted prior to any and all missions. Post flight inspections will also be conducted in order to aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. Thorough inspection of the UAV s shal l be conducted and flight response tested should a hard landing or crash occur insuring that the UAV s can operate in a safe manner before conducting any further missions. Like the Astraeus Petition , Petitioner Aerospec Technologies requests waiver or e xemption for markings due to the small size of the fuselage for THE EQUIPMENT
. Petitioner Aerospec Technologies requests modification, waiver or exemption and clarification (within reason) concerning the S ection 91.119 prohibition of flight in congested areas. Petitioner Aerospec Technologies requests waiver for this condition to allow reasonable and responsible operations in congested areas of subdivisions and neighborhoods.In compliance with Section 9 0.151 (a) THE EQUIPMENT are battery operated UAV s /UAS s with battery

level monitoring capability . Full y charged battery flight time is rated at 18
- 120 minutes, with videos/photos taking much less time to record. Operator or PIC is warned when battery level is low. Petitioner Aerospec Technologies requests waiver/exemption from Section 91.203 (a) since p osting of special flight authorization would not be possible since THE EQUIPMENT ha s no cabin and are not large enough to carry a certificate. **B. Aerospec**  **Technologies ’**  **Proposed Operations Demonstrate an Equivalent Level of Safety**  **1. General Description of Proposed Flight Operations**  Aerospec Technologies proposes to operate within the limitations and performance specifications listed in the USER MANUAL S , which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory structure because the proposed operations represent a safety enhancement to the protocols. The propose d operations do not create any hazard to users of the national airspace s ys tem or pose a threat to national security
. THE EQUIPMENT are battery operated quad copter s and fixed
- wing aircraft with a maximum flight time of 18
- 120 minutes. THE EQUIPMENT weighs approximately 8

–25 pounds. It has vibration dampers and small frame air incline. THE E QUIPMENT ’s ground speed is a maximum of 2 5
- 56 mph but it will be operated between 2 and 2 5 miles per hour, and it will operate at or below 2 00 feet AGL. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. THE EQUIPMENT carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated b y the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of THE EQUIPMENT
. The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology , is mitigated b y placing limits on altitude, requiring stand
- off distance from clouds, permitting day time ope rations onl y, requiring that the aircraft be operated within visual line of sight , and requiring THE EQUIPMENT to yi eld right of way to all other manned operations. Additionally , the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 13
. The petitioner’s aircraft has the capability to operate safely

after experiencing certain in
- flight failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifically low battery RTH and failsafe RTH . The aircraft is also able to respond to a lost
- link event with a pre coordinated, predictable, automated flight maneuver.**2. Reasons why the exemption would not adversely affect safety or how the**  **exemption would provide a level of safety at least equal to the existing rule.**  Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, Aerospec Technologies proposed op erations using THE EQUIPMENT would “not create a hazard to users of the national airspace sy stem or the public or pose a threat to national security .” Reform Act Section 333(b ) ( 1). 1. The aircraft will be identified by serial number, registered with the FAA, and have identification (N
-Number) markings as large as practicable. 2. Flights will be operated within visual line of sight of the pilot in command (PI C). 3. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy

by PI C. 4. Maximum flight time for each operational flight will be approximately 15
- 20 minutes. 5. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. 6. The aircraft will be operated during daylight and in VFR conditions. 7. Flights will be operated at a lateral distance of at least 50 feet from any persons or property not associated with the operation who have not given prior permission. 8. Flights will be limited to a groundspeed of 5
- 25 mph. 9. Minimum crew for each flight will consist of a PIC and an Observer. 10. The PI C will possess at least a sport pilot certificate and a valid state driver’s license. 11. Any designee from Aerospec Technologies will have completed a Basic Operator Course for THE EQUIPMENT
. 12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 13. The flight operations will yield the right of way to other manned aircraft operations. 14. All persons who are not involved with flight operations w ill be required to stay 5 0 feet from the edge of the flight operation perimeter. 15. Aerospec Technologies will provide NOTAM details to the FAA 24 hours prior to each flight. 16. All required permissions and permits will be obtained from territory , state, county or city jurisdictions prior to flight. 17. Prior to commencing operations, Aerospec Technologies will obtain a Certificate of Waiver or Authorization (COA) from th e FAA if flying above 200 feet AGL. 18. If the aircraft loses communications, it will have the capability to return to a pre determined location within the operational area and land. 19. If the aircraft loses its GPS signal it will have the capability of being flo wn manually to a predetermined location within the operational area and land. 20. The flight will be aborted in case of unpredicted obstacles or emergencies. 21. Each flight will be recorded in an Operations L og Book. 24. Maintenance on the aircraft will be record ed in a Maintenance Lo g Book.**3. Flight Recovery, Lost Communications, and Lost GPS Procedures** 

The flight recovery , lost communications, and lost GPS procedures are fu lly documented in the User Manuals. **V. SPECIFIC FAR EXEMPTIONS REQUESTED**  Aerospec Technologies seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations. L isted below are (1) the specific FAR sections for which exemption is sought, and (2) the operat ing procedures and safeguards that Aerospec Technologies has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

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

**– Airworthiness Certific**  **ates and 14 C.F.R. § 91.203(a)(1)**  The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS s selected provide an equivalent level of safety when compared to aircraft normall y used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014
- 0352 at 13
- 14, 22. If, however, the FAA determines that there are some characteristics of THE EQUIPMENT that fail to meet the requirements of the Reform Act, an exemption is requested. **Equivalent Level of Safety:** THE EQUIPMENT are safe when taking into account its size, weight, speed, and operational capability
. THE EQUIPMENT weighs approximately 2.6
- 25 pounds and either wil l be flown at speeds of 5
- 25 miles per hour, and in visual line of sight of the operator . THE EQUIPMENT do es not carry pilots, passengers, explosive materials, or flammable liquid fuels. THE EQUIPMENT will be operated within the parameters of the User Manuals. Aerospec Technologies will also provide the FAA with advance notice of all operations via a NOTAM and coordination with the local Flight Standards District Office ( FSDO ) . The proposed operations will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

**B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Ro**  **torcraft** 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent THE EQUIPMENT would otherwise require certification under Part 27, Aerospec Technologies seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H. **C. 14 C**  **. F**  **. R**  **. §**  **45.11 :**  **Marking of Products**

— prescribes, in pertinent part, that the manufacturers of aircraft, engines and propellers mark such aircraft, engines, or propellers with an approved fireproof identification plate.Aerospec Technologies requests an exemption from 14 CFR 45.11. The Identified

Sy stem, due to its small size, does not have room for fireproof identification plates to be placed in it. **D. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and** 

**Identification Requirements** 14 C.F.R. §45.23(b), Markings of the Aircraft states: When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light
- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light
- sport, “experimental ,” or “provisional,” as applicable. 14 C.F.R. § 45.27(a) states: **Rotorcraft.** Each operator of a rotorcraft must display on that roto rcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. 14 C.F.R. § 91.9(c) states: No person may

operate a U.S.
- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N
-Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14. **Equivalent Level of Safety:** Aerospec Technologies will mark all THE EQUIPMENT with their N
- Number in a prominent spot on the fuselage with markings that are as large as practicable.

**E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations**  Aerospec Technologies seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class me dical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PI C matches the airspace in which the PI C will be operating, as well as requiring certifications if the pilot is carryi ng passengers or cargo for hire. While THE E QUIPMENT will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA
- 2014
- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airsp ace did not warrant the additional cost and restrictions attendant with requiring the PI C to have acommercial pilot certificate and a class II medical certificate. The FAA has also determined that

the required knowledge for a commercial pilot covers the s ame fundamental principles as a private pilot. The PI C will possess at least a sport pilot certificate , a valid US driver’s license, and w ill have completed a Basic Operator Course for THE EQUIPMENT
. The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety

factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS
- specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 18. The proposed operations can achieve an equivalent level of safety b y requiring the knowledge and experience in THE EQUIPMENT operations described above. The restrictions Aerospec Technologies has placed on THE EQUIPMENT operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA
- 2014
- 0352. Aerospec Technologies will operate in restricted areas (the s ites) away from persons and property not involved in the operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified s ites. A NOTAM will be issued at least 2 4 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.

**F. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness**  Aerospec Technologies seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworth y condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Ac cordingl y, Aerospec Technologies requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

**G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft;**  **14 C.F.R.**  **§§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration**  Pursuant to 14 C.F.R. § 91.9(b)(2): (b)No person may

operate a U.S.
- registered civil aircraft
-

... (2)For which an Airplane or Rotorcraft Flight Manual is required b y § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b):(a)Except as provide d in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1)An appropriate and current airworthiness certificate. (b)No person may

operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Aerospec Technologies does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PI C during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19
- 20, and Grant of Exemption No. 8607.

**H. 14 C.F.R.**  **§ 91.103: Preflight Action**  Aerospec Technologies se eks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA
- approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Under these circumstances, the FAA has stated that no exemption i s required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA
approved Flight Manual is required. **Equivalent Level of Safety:** An equivalent level of safety will be provided by following the User Manuals. The PIC will take all required preflight actions
- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas
- be fore initiation of flight. The User Manuals will be kept at the ground station ; with the operator at all times.

**I. 14 C.F.R.**  **§ 91.109(a): Flight Instruction**  Aerospec Technologies seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o perso n may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls.” UASs and remotel y piloted aircraft, by

their design, do not have functional dual controls. In stead, flight control is accomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with the aircraft via radio communications. **Equivalent Level of Safety:** When flight instruction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed of THE EQUIPMENT , an equivalent level of safe training can sti ll be performed without dual controls because no pilot or passengers are aboard the aircraft, and allpersons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. These flights will comply with the provisions in the User Manuals. Accordingl y, Aerospec Technologies proposed method of operation provides superior levels of safety. **J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas**  Aerospec Technologies requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already determined that relief from Section 91. 119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by Aerial Media International
. See Grant of Exemption No. 11062, p. 20
- 21. **Equivalent Level of Safety:** Compared to flight operations with rotorcr aft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presentl y exist with conventional aircraft. An equivalent level of safety will be ac hieved given the size, weight, and speed of THE EQUIPMENT , as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set forth in the User Manuals and herein, THE EQUIPMENT will be operated at s ites, away from persons or structures not involved in the operation. All persons who are not involved with Aerospec Technologies operations wi ll be required to be at least 50 feet from the flight operation perimeter.

**K. 14**  **C.F.R. §**  **91.121: Altimeter Settings** This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport. THE EQUIPMENT use both barometric pressure sensors and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that THE EQUIPMENT do not have a barometric altimeter setting. The altitude of the aircraft is monitored by the PI C on the ground control station and by the visual observer. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visua l line
- of
- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20
- 21. As the User Manuals indicate, THE EQUIPMENT will be operated at or below 400 feet AGL and compl y with the limitations in the Grant of Exemption No. 11062.
**L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Aerospec Technologies requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states:(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

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

after that for at least 45 minutes. (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly t o the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. Here, the technological limitations on THE EQUIPMENT battery power means that no meaningful flight operations can be conducted while stil l maintaining a 30 minute reserve. The aircraft is battery

powered with a maximum flight time of between 18
- 25 minutes. Aerospec Technologies proposes that the maximum flight time for each operational flight will be 18
- 2 5 minutes. The aircraft will be safe ly landed with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining. **Equivalent Level of Safety:** The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 2 1
- 22. The User Manuals providing an equivalent level of safety b y s afel y landing with no less than the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and otherwise compl yi ng with the flight restrictions above.

**M. 14 C**  **.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b):**  **Maintenance Inspections** Aerospec Technologies seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certif icate, which THE EQUIPMENT will not have. **Equivalent Level of Safety:** An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, an d inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014
- 0352, at p. 14
- 15.As provided in the Manuals, flights will not be conducted unless a flight operations checklist is

performed that includes all of the aircraft’s components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post - flight m aintenance. The Manuals set requirements for both annual maintenance and preventative maintenance. **VI. PUBLIC INTEREST**  Granting Aerospec Technologies petition for exemption furthers the public interest. National policy set b y Congress favors earl y integration of UAS into the NAS in controlled, safe working environments as proposed in this petition. By granting this petition, the FAA will fulfill Congres s’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 33 3 of the Reform Act. Aerospec Technologies will operate in a manner that will ensure the public’s safety and will set the example for others to emulate. It is well established that UAS provide an additional tool for the filmmaking industry , adding a greater degree of flexibility, which supplements the current capabilities offered b y m anned aircraft
. **VII. PRIVACY**  All flights will be conducted i n accordance with any federal, state or local laws regarding privacy
. All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images or video taken of individuals will have consented to bein g filmed or otherwise they will be made anony

mous. **VIII. NATIONAL SECURITY**  Given the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue. Furthermore, the security screening conducted b y the Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security. **IX. SUMMARY FOR FEDERAL REGISTER**  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: Aerospec Technologies seeks an exemption from the following rules in order to provide aerial imaging, asset integrity and data collection services to clients in various industries : 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27 ; 14 C.F.R § 45. 11 ; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) ; 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).The exemption will enhance safety b y reducing risk to the operator, the general public and

property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation, and flight operations. **X. CONCLUSION**  Satisfaction of the criteria provided in Section 333 of the Reform Act
- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security considerations
- provides more than adequate justification for the grant of the requested exemptions to permit Aerospec Technologies to operate THE EQUIPMENT
. Granting the requested exemption will benefit the public interest as a whole in many way s, including (1) significantly improving safety and reducing risk by

alleviating human exposure to danger; (2) improving the quality of services Aerospec Technologies c an provide to its customers; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft Respectfully

submitted, By : /s/ Lan ce Li Co
- founder and CEO Aerospec Technologies, LLC