**Richard G. Wright**

**Commercial Pilot Certificate 2205920 Rotorcraft** 

**- Helicopter; Instrument Helicopter**  **President /Lead Pilot**  **Just Make A Difference Inc. DBA Aerobods**  **1021 Ballew Circle Fairview, TN 37062**  **Phone: 615**

**- 200** 

**- 5112**  **Email: pilot@aerobods.com**

**October 2**  **, 2015** 

**U. S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140**  **1200 New Jersey Ave, SE Washington, DC 20590** 

**Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 of the**  **Federal Aviation Regulations from: 14 CFR 61.23(a) & (c) ;**  **14 CFR 61.101 (e) (4) & (5) ;**  **14 CFR 61.113 (a)**  **; 14 CFR 61.315 (a)**  **; 14 CFR 91.7 (a)**  **; 14 CFR 91.1**  **19 (c) ;**  **14 CFR 91.121 ;**  **14 CFR**  **91.151 (a) (1) ;**  **14 CFR 91.405 (a) ;**  **14 CFR 91.407 (a) (1) ;**  **14 CFR 91.409 (a) (1) & (2) ;**  **14 CFR**  **91.417 (a) & (b)**

**Dear Exemption Manager, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the**  **Reform A**  **ct) and 14 C.F.R. Part 11 , Just Make A Difference, Inc., DBA Aerobods**  **herein after also known as**  **Aerobods or the operator**  **, is an operator of small Unmanned Aircraft Systems (sUAS) or Unmanned Aircraft (UA).**  **Aerobods is a photography, surveying, mapping,**  **technology and services company that plans to exploit the capabilities of UA to offer a multitude of services, including:** 

• **Aerial surveying, mapping and data collection**

• **Remote sensing**• **Educational and research oper ations** 

• **Wildlife and forestry monitoring**

• **Aid in disaster and emergency management and monitoring, civil first response, communications relay, search and rescue, monitoring fire hazards, cleanup effort**  **supervision, damage assessment and estimation**

• **Aid civ il engineering: waterways and shipping, forestry, fishery protection,**  **pollution control and air sampling and crop performance**

• **Railroad and motor vehicle**  **road inspection**

• **Telecommunications infrastructure inspection**

• **Utility, Energy systems and electrical engineering inspections and asset management** 

• **Agricultural surveying and produce field management**

• **Livestock management and accountability**

• **Unmanned aircraft flight school**

• **Aerial filmmaking and photography**

• **Construction site inspections and monitoring**

• **Oi l and gas pipeline inspection/patrolling and oil-field inspection** 

• **Real estate and marketing**

• **Aerial event security, surveillance and crowd management**

• **Aerial imagery evidence for property insurance claims**
**Aerobods hereby applies for an exemption from the listed Federal Aviation Regulations**  **(FARs) to allow commercial operation of their UA, with full understanding that operations are conducted within and under the conditions outlined herein or as may be established b**  **y the FAA as required by Section 333. As described more fully below, the requested**  **exemption would permit the operation of small, unmanned and relatively inexpensive UA under controlled conditions in the National Airspace System (NAS) regulated by the**  **Fede ral Aviation Administration (FAA). Approval of this exemption would thereby**  **enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “.**  **..establish requirements for the safe operation of such aircraft syste ms**  **in the national airspace system. ” Section 333(c) of the Reform Act.** 

**The name and address of the applicant is: Richard G. Wright**  **Commercial Pilot Certificate 2205920 Rotorcraft** 

**- Helicopter; Instrument Helicopter**  **President/Lead Pilot Just Make A**  **Difference Inc. DBA Aerobods**  **1021 Ballew Circle Fairview, TN 37062**  **Phone: 615**

**- 200** 

**- 5112**  **Email: pilot@aerobods.com Regulations from which the exemption is requested:** 

• **14 CFR 61.23 (a) & (c)**

**– Medical certificates: Requirements and duration** 

• **14 CFR 61.101 ( e) (4) & (5)** 

**– Recreational pilot privileges and limitations** 

• **14 CFR 61.113 (a)**

**– Private pilot privileges and limitations: Pilot in command** 

• **14 CFR 61.315 (a)**

**– What are the privileges and limits of my sport pilot certificate?** 

• **14 CFR 91.7 (a)**

**– Civil aircraft airworthiness** 

• **14 CFR 91.119 (c)**

**– Minimum safe altitudes: General** 

• **14 CFR 91.121**

**– Altimeter settings** 

• **14 CFR 91.151 (a) (1)**

**– Fuel requirements for flights in Visual Flight Rules (VFR)**  **conditions**

• **14 CFR 91.405 (a)**

**– Main**  **tenance required**

• **14 CFR 91.407 (a) (1)**

**– Operation after maintenance, preventative maintenance,**  **rebuilding, and alteration**

• **14 CFR 91.409 (a) (1) & (2)**

**– Inspections** 

• **14 CFR 91.417 (a) & (b)**

**– Maintenance records** 

**Regulatory Basis for Exemption Requ est**  **This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of**  **Transportation to consider whether certain unmanned aircraft systems may operate saf ely**  **in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to**  **determine which types of UA do not create a hazard to users of the NAS or the public or**  **pose a threat to national security in light of the following:**

• **The UA’s size, weight, speed, and operational capability ;** 

• **Operation of the UA in close proximity to airports and populated areas**

• **Operation of the UA within visual line of sight of the operator.** 
**The aircraft intended for u se by the operator includes the**  **DJI Phantom 2, DJI Phantom 2 Vision+ (Plus) & DJI S1000. All of these aircraft have previously been approved by the**  **FAA in other applicant’s Section 333 exemptions. Exemptions N os. 11278, 11275, 11267,**  **11260, 11253 and 11230. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate**  **safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(**  **c) (emphasis added).**  **The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined** **under §40101 of the Act, which includes UA, from the requirement that all civil aircraft** 

**must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed**  **under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the**  **Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a)**  **; 49 USC §44704; 14 CFR §91.203 (a) (1).**
**Aerobods’ UA are rotorcraft, weighting 55 or fewer pounds including payload. The UA**  **operate under norma l conditions at a speed of no more than 50 knots and have the**  **capability to hover and move in the vertical and horizontal plane simultaneously. The UA will be operated only in line of sight and will be operated only within a predetermined and**  **protected fli ght area under the permission of the property representative. The UA will be**  **operated under the below listed limitations and conditions to which the operator agrees to be bound when conducting commercial operations under an FAA issued exemption, as well** 

**a s any other limitations the FAA may place on future operations. Such operations will**  **insure that the UA will “not create a hazard to users of the national airspace system or the public as per the Reform Act Section 333 (b).** 
**Given the clear direction in Se ction 333 of the Reform Act, the authority contained in the**  **Federal Aviation Act, as amended ; the strong equivalent level of safety surrounding the**  **proposed operations, and the significant public benefit, including enhanced safety, reduction in environment**  **al impacts, including reduced emissions associated with allowing UA for aerial data collection, the grant of the requested exemptions is in the public interest.**  **Accordingly, the applicant respectfully requests that the FAA grant the requested exemption wit**  **hout delay. The FAA has issued grants of exemption in circumstances similar in material respects to**  **those presented in this petition. In Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 1110**  **9**

**Aircraft and Equivalent Level of Safety 14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the**  **procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). The Federal Aviatio**  **n Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an**  **airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports**  **and populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness**  **certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer**  **, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.** **The UA to be operated hereunder are rotorcraft weighing less than 55 pounds including**

**payload, carries neither a pilot nor passenger. Carries no explosive materials or flammable**  **liquid fuels, and operates exclusively within visual line of sight of the pilot in command (PIC) and a visual observer (VO). They operate at a speed of less than 50 knots and have**  **t he capability to hover and move in the vertical and horizontal plane simultaneously within**  **a predetermined and protected flight area as described below. Such operations will insure that the UASs will not create a hazard to the users of the national airspac**  **e system. Unlike other civil aircraft, operations under this exemption will be tightly controlled and**  **monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of ope**  **ration. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree**  **of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21**  **, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed**  **by the UA, due to its size, speed of operation, location of operation, lack of explosive**

**ma terials or flammable liquid fuels, a**  **nd inability to carry a substantial external load. The Secretary of Transportation has previously determined that these aircraft meets the**  **conditions of Section 333. Therefore, the FAA has found that request of relief from 14 CFR part 21, and any associa**  **ted noise certification and testing requirements of part 36, is not necessary. This has been stated in exemptions to this regulation in Exemptions Nos. 11280,**  **11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230 The applicant pr**  **oposes that the exemption requested herein apply to aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide**  **for at least an equivalent or even higher level of safety to operations under the curr ent**  **regulatory structure. These limitations and conditions to which the operator agrees to be bound when conducting**  **commercial operations under an FAA issued exemption include:** 1. **The UA ; DJI Phantom 2, DJI Phantom Vision+ and DJI S1000+ will weigh less**  **tha n 55 pounds including payload. Proposed operations of any other aircraft will**  **require a new petition or a petition to amend the exemption.** 2. **Operations for the purpose of closed set**  **mo tion picture and television filming**  **are not permitted.** 3. **The UA will not b e operated at a speed exceeding 87 knots (100 miles per hour).**  **The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA**  **be operated at airspeeds greater than t he maximum UA operating airspeed**  **recommended by the aircraft manufacturer.** 4. **The UA must be operated at an altitude of no more than**  **2 00 feet above ground**  **level (AGL). Altitude must be reported in feet AGL.** 5. **The UA must be operated within visual line of sig ht (VLOS) of the PIC at all**  **times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman**  **medical certificate or U.S. driver’s license** 6. **All operations must utiliz e a visual observer (VO). The UA must be operated**  **within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always**  **maintains VLOS capability. The VO and PIC must be able to communicate**  **verbally at all times ; electronic messaging or texting is not permitted during**  **flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must**  **ensure that t he VO can perform the duties required of the VO.**  7. **The exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in the grant**  **of exemption, are hereinafter referred to as the op erating documents. The**  **operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the**  **conditions and limitations in the exemption and the procedures outlined in the ope**  **rating documents, the conditions and limitations therein take precedence and must be followed. Otherwise, the operator must follow the procedures as**  **outlined in its operating documents. The operator may update or revise its operating documents. It is the o**  **perator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law**  **enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amen**  **dm ent to the grant of**  **exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must**  **petition for an amendment to its grant of exemption. The FAA’s UAS Integration O**  **ffice (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.**  8. **Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight criti**  **cal component,**  **must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC**  **with a VO and must remain at least 500 feet from other people. The functional test flig**  **ht must be conducted in such a manner so as to not pose an undue hazard to persons and property.**  9. **The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.**  10. **Prior to each flight, the PIC must conduct a pre-flight inspection and determine**  **the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment.**  **If the inspection reveals a condition that af fects the safe operation of the UAS,** **the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.**  11. **The operator must follow the UAS manufacturer’s maintenance, overh aul,**  **replacement, inspection, and life limit requirements for the aircraft and aircraft components.**  12. **Each UAS operated under the exemption must comply with all manufacturer's safety bulletins.**  13. **A PIC must hold either 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, the District of Columbia, Puerto**  **Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in**  **an aircraft in which the PIC is rated on his or her pilot certificate.** 14. **The operator may not permit any PIC to operate unless the PIC demonstrates**  **the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency**  **maneuvers and maintaining appropriate distances from persons, vessels, vehicles**  **and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training**  **the operator’s PICs and VOs (training, proficiency, and experience building** **) and determ** **ining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are**  **permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training ses**  **sions. During training, proficiency, and**  **experience building flights, all persons not essential for flight**  **operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR §**  **91.119.** 15. **UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be**  **conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.**  16. **The UA may not oper ate within 5 nautical miles of an airport reference point**  **(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted**  **on the current FAA-published aeronautical ch art, 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 enforcem**  **ent official upon request.** 17. **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.**18. **If the UAS loses communications or loses its GPS signal, the UA must return to a**  **predetermined location within the private or controlled access**  **property.** 19. **The PIC must abort the flight in the event of unpredicted obstacles or emergencies.**  20. **The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to**  **conduct the intended operation and to operate after that for at least five minutes or with the reserve pow**  **er recommended by the manufacturer if greater.** 21. **Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The**  **exemption holder may apply for a new or amended COA if it intends to conduct**  **operations that cannot be conducted under the terms of the attached COA.** 22. **All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have**  **identificatio n (N- 6 Number) markings in accordance with 14 CFR part 45,**  **Subpart C. Markings must be as large as practicable.** 23. **Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 m**  **ust 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 law enforcement official upon request.**  24. **The UA must remain clear and give way to all manned aviation operations and**  **activities at all times.** 25. **The UAS may not be operated by the PIC from any moving device or vehicle.** 26. **All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structu**  **res unless:**

a. **Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator**  **must ensure that nonparticipating persons remain under such protection. If a situation a**  **rises where nonparticipating persons 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 struct ures 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. The PIC, VO, operator trainees or essenti**  **al persons are not considered nonparticipating persons under the exemption.**  27. **All operations shall be conducted over private or controlled access**  **property with permission from the property owner/controller or authorized representative.**  **Permission from prope rty owner/controller or authorized representative will be**  **obtained for each flight to be conducted.**28. **Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA** 

**m ust 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**

**. Unless otherwise specified in the**  **grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,**  **parts 45, 47, 61, and 91.**

**14 CFR § 61.23 (a) & (c): Medical certificates: Requirements and duration. This regulation sets forth medical certificate requirements for pilots-in-command of**  **aircraft in that a holder must have a first-class medical certificate when exercising the PIC privileges of an airline transport pilot certificate. Furthermore, the requir**  **ement states that the PIC must hold at least a second-class medical certificate when exercising PIC privileges**  **of a commercial pilot certificate, or must hold at least a third-class medical certificate when exercising PIC privileges of a private pilot cert** **ificate, recreational pilot certificate, or flight instructor certificate. It also states that a person must hold and possess either a medical**  **certificate issued under § 61.67 or a U.S. driver's license when exercising the privileges of a PIC of a sport pi** **lot certificate in a light-sport aircraft other than a glider or balloon. The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s**  **certificates (discussed above) to operate a UAS with a U.S. issued driver’s license, in l ieu of**  **an FAA-issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver’s**  **license. The FAA has issued the following exemptions to this r egulation: Exemption**  **Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.**

**14 CFR § 61.101 (e) (4) & (5): Recreational pilot privileges and limitations. This section limits recreational pilots to non-commercial operations and tha**  **t they may not act as pilot in command of a recreational aircraft for compensation or hire, or in the**  **furtherance of a business. Unlike a conventional aircraft that carries the pilot and passengers, the UA is remotely controlled with no living thing on boa**  **rd. The area of operation will be predetermined and in a protected flight area under the permission of the**  **property representative, and all flights are planned and coordinated in advance. The FAA has issued the following exemptions to this regulation: Exem**  **ption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.** **14 CFR § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command.**

**This section limits private pilots to non-commercial operations and that they may not ac t as**  **pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Unlike a conventional aircraft that carries the pilot and passengers, the UA is**  **remotely controlled with no living thing on board. The area of operation will be**  **predetermined and in a protected flight area under the permission of the property representative, and all flights are planned and coordinated in advance. The**  **FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 1**  **1269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.**

**14 CFR § 61.315 (a): What are the privileges and limits of my sport pilot certificate? This section limits sport pilots to non-commercial operations and that they may not act as**  **pilot in command of an aircraft that is carrying passengers or property for compensation or hire, or in the furtherance of a business. They also may not carry more**  **than one passenger, fly at night, and under other restrictions that are outside of the scope of**  **intended flights of the UA. Unlike a conventional aircraft that carries the pilot and passengers, the UA is remotely controlled with no living thing on board.**  **The area of operation will be predetermined and in a protected flight area under the permission of the**  **property representative, and all flights are planned and coordinated in advance. The FAA has issued the following exemptions to this regulation: Exemptio**  **n Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.** 

**14 CFR § 91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy**  **condition. As there will be no airworthiness certificate issued for the aircraft, should this**  **exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of preflight actions as**  **prescribed by the aircr aft’s manufacturer prior to each flight, and given the FAA’s prior**  **approval of the same types of aircraft to be used in previous exemptions to this requirement (as set forth in Exemptions Nos. 11278, 11275, 11267, 11260, 11253 and 11230)**  **we believe we can maintain a high standard of safety and due regard as to the aircraft’s**  **airworthiness during flight operations. The FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252,**  **11240 and 1 1230.** 

**14 CFR § 91.119 (c): Minimum safe altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)**  **allows helicopters to be operated at less than the minimums prescribed, provided the person operating the h**  **elicopter complies with any route or altitudes prescribed for**

**helicopters by the FAA. As this exemption is for UAS that are rotorcraft and the exemption requests authority to operate at altitudes up to 200 feet AGL, an exemption may be needed**  **to allow such operations. As set forth herein, the UA will never operate at higher than 200**  **feet AGL, will always be operated under VLOS of both the PIC and VO, its area of operation will be predetermined and in a protected flight area under the permission of the**  **prope rty representative, all flights are planned and coordinated in advance and the UA will**  **remain clear of, and give way to all manned aviation operations and activities at all times. The equivalent level of safety will be achieved given the size, weight, spe**  **ed of the UA as well as the location where it is operated and under the conditions previously stated. Compared**  **to flight operations with aircraft or rotorcraft weighting far more than the maximum 55pounds proposed herein and the lack of flammable fuel, any**  **risk associated with these operations is far less than those presently presented with conventional aircraft operating at**  **or below 500 feet AGL. In addition, the low-altitude operations of the UA will ensure separation between these small- UAS operations a**  **nd the operations of conventional aircraft that must comply with Section 91.119. The FAA has issued the following**  **exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.** 

**14 CFR § 91.121: Al timeter Settings.**  **This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an**  **appropriate altimeter setting available before departur e.” As the UA may not have a**  **barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the**  **manufacturer’s published procedures and live flight data mon itoring, confirming the**  **altitude of the launch site shown on the GPS altitude indicator before flight. In the event that the GPS altitude read out system becomes none functional during flight, the UA will**  **also have a pre-programmed maximum flight limit of 200 feet programmed into them so**  **that they may not fly above unapproved altitude limits. The FAA has issued the following exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256,**  **11253, 11252, 11240 and 11230.**

**14 CFR § 9 1.151(a) (1): Fuel Requirements for Flight in VFR Conditions.**  **Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough**  **fuel to fly to the first point of intended landing, and, assuming normal cruis ing speed** 

**– (1)**  **During the day, to fly after that for at least 30 minutes ; or (2) At night, to fly after that for**  **at least 45 minutes.” The LiPo battery powering the DJI Phantom 2 & DJI Phantom Vision + UA provides** 

**approximately 20 minutes of powered flig ht while the LiPo battery powering the DJI S1000**  **provides approximately 30 minutes of flight. The PIC will not begin a flight unless there is enough available power for the UA to conduct the intended operation and to operate after**  **that for at least five mi nutes or with the reserve power recommended by the manufacturer**  **if greater. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of**  **prior exemptions, and that flight with less than 30 minutes of reserve fuel, does not engende**  **r the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Similar exemptions have been granted to other operations,**  **including Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 1124 0**  **and 11230.**

**14 CFR § 91.405 (a) ; 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections.**  **These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall**  **between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as**  **prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sect** **ions and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant.**  **An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and**  **operate only in restricted areas for limited periods of time. If mechanical issues arise the UA can land immediately and will be operating from**  **no higher than 200 feet AGL and within VLOS of the PIC and VO. Prior to each flight, the PIC must conduct a pre**  **-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable**  **components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary**  **maintenance has been performed and the UAS is found to be in a condition for safe flight. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacemen**  **t, inspection, and life limit requirements for the aircraft and aircraft components. The FAA**  **has issued the following exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.** 

**Privacy**
**All fl ights will occur over private or controlled access property with the property**  **representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming**  **will take place.** **All flights will occur in accordance with any state or local laws regarding privacy.**

**Additional Views, Information & Summary**
**Aerobods has 2 years of experience in unmanned aircraft flight operations a**  **nd currently hold**  **s a valid commerc**  **ial pilo**  **t certificate. We understand that safety is paramount, but we**  **also know that integrating and operating in congested airspace along with manned aircraft is possible without incident.**  **Aerobods was established January, 2012**

**. As a public benefit**  **A erobods**  **will advance: -Research into future safety guidelines for the use of UAS,**  **-Reduction in dangers by limiting the use of larger rotorcraft or fixed-wing aircraft, -Reducing carbon emissions, &**  **-Advancement of science through advanced data coll ection** 
************* **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:**  **Applicant seeks an exemption from the following rules: 14 CFR 61.23(a) & (c)**  **; 14 CFR 61.101 (e) (4) & (5)**  **; 14 CFR 61.113 (a)**  **; 14 CFR 61.315**  **(a) ;**  **14 CFR 91.7 (a)**  **; 14 CFR 91.119 (c)**  **; 14 CFR 91.121**  **; 14 CFR 91.151 (a) (1)**  **; 14 CFR 91.405**  **(a) ;**  **14 CFR 91.407 (a) (1) ; 14 CFR 91.409 (a) (1) & (2) and 14 CFR 91.417 (a) & (b) to** 

**o perate commercially a small unmanned vehicle (55pounds or less) for the purpose of**  **aerial surveying, mapping and data collection ; remote sensing; educational and research**  **operations ; wildlife and forestry monitoring; aid in disaster and emergency managemen**  **t and monitoring, civil first response, communications relay, search and rescue, monitoring**  **fire hazards, cleanup effort supervision, damage assessment and estimation ; aid civil**  **engineering: waterways and shipping, forestry, fishery protection, pollution c ontrol and air**  **sampling and crop performance ; railroad and motor-vehicle road inspection;**  **telecommunications infrastructure inspection ; utility, energy systems and electrical**  **engineering inspections and asset management ; agricultural surveying and produce**  **field management**  **; livestock management and accountability; unmanned aircraft flight school; aerial filmmaking and photography**  **; construction site inspections and monitoring; oil and gas pipeline inspection/patrolling and oil-field inspection**  **; real estate an d marketing**  **; aerial event security, surveillance and crowd management and aerial imagery evidence for**  **property insurance claims. Approval of exemptions allowing commercial operations of UA in the listed industries will** 

**enhance safety by reducing risk. Conventional flight operations using jet, piston or multi-engine powered aircraft occasionally operate at extremely low altitudes to**  **complete some of the requested uses and in extreme proximity to people and structures. This**  **presents associated risks as these vehicles weigh in excess of 3,000 pounds and carry large amounts of jet A or other fuel. Such aircraft must fly to and from the m**  **ission location. In contrast, a UA weighing fewer than 55 pounds, powered by batteries, virtually eliminates**  **all of the above risks given the UA’s reduced mass and lack of combustible fuel carried on board. The UA is carried to the mission site. The UA wil** **l carry no passengers or crew, therefore, the UA will not expose them to the risks associated with manned aircraft flights.**  **The operation of small UASs, weighing less than 55 pounds, conducted in the strict conditions outlined above, will provide an equiv**  **alent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements**  **of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground but**  **under 200 feet AGL, and within visual line of sight of the pilot in command and a visual observer. As a result, the small UASs are far safer than**  **conventional flight operations conducted with large manned aircraft. Satisfaction of the criteria provided i**  **n Section 333 of the Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within**  **visual line of sight, national security and the significant public benefit as well as the positive economic im** **pacts**

**– provide more than adequate justification for the grant of the requested**  **exemptions allowing commercial operati on of applicant’s UA. Granting Aerobods**  **the above exemptions will allow for the expansion of UAS systems into the future, in a**  **professiona l, safety conscious cult**  **ure steeped in the tradition safe flight and general aviation. Aerobods**  **respectfully requests that the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by**  **Aerobods pursuant to the**  **Federa l Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").** 

**Sincerely,**

**Richard G. Wright President, Lead Pilot**  **Just Make A Difference Inc. DBA Aerobods**  **Commercial Pilot Certificate 2205920 Rotorcraft** 

**- Helicopter; Instrument Helicopter**  **1021 Ballew Circle**  **Fairview, TN 37062 Phone: 615** 

**- 200** 

**- 5112**