Bruce Barton 

### T: +15706883181 director@rescueinternational.org 

### July 10 2015 

# u.s. Department of Transportation Docket Management System 1200 New

Jersey Ave., SE Washington, DC 

### 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R
. 45
. 23(b); 14 CFR Part 21; 14 CPR 61.113 (a) 

### & (b); 91.7 

### (a); 91.9(b) (2); 91.103 (b); 91.109; 91.119; 91
. 121; 

### 91
. 151 (a); 91
. 203(a) & (b); 91
. 407(a) 0); 91
. 409 (a) (2); 91
. 417 ( a) & 

### Cb)
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Rescue International , developer, educator and operator of small Unmanned Aircraft Systems (" UAS") equipped to conduct aerial Search and Rescue Operations in the US have seen 

### higher success rates on (SAR) operations and help prevent contamination of lands if there was a manned aircraft accident , hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial/public safety flights of UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by 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 UAS under controlled conditions in airspace that is 

### 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in SAR missions presently using conventional aircraft. Approval of this exem ption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrat or's) responsibilities to establish requirements for the safe operation of such aircraft systems in the national airspace sys tem
. " RI will be working to promote safe use of UAS for public safety and specific Search and Rescue applications thru the development of training materials and training classes for UAS pilots, Observers and flight support staff

. A s the current FAA pilot certifications are too restrictive for UAS operations with many requirements like , actual manned flight hours including cross country flights, that have very little application to safe UAS operations, RI asks that a PIC exception fo r public safety operations, as current PIC certifications were not intended for UAS operations and place an unreasonable burden on the development and deployment of public safety , lifesaving use of UAS , this being in the best interest of the public be made till FAA rules for UAS operations are developed
. W e request an exception to PIC rules or issuance of a special temporary certification for PS UAS PIC operations to allow Public Safety flight and educational development and legal and safe deployment of UA S for life saving rescue and recovery use. We request that this application be expedited by the FAA to all extent possible as its approval is in the public’s best interest. The name and address of the applicant is: Rescue International, Inc Attn: Bruce Barton , Director of Operations Ph: 

### 570
- 688
- 3181 Email: director@rescueinternational.org Address: Po Box 544

Delaware Water Gap PA 18360

## The conditions proposed by the applicant are drawn **in part from order 8900.1 CHG 0**  **&**

**exemption 11282** Regulations from which the exemption is required 14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61
. 113 (a) 

### & (b) 14 C.F.R. 91
. 7 (a) 14 CFR 91
. 9 (b) (2) 14 C
. F.R. 91
. 103 14 C.F
. R. 91
. 109 14 C.F
. R. 91
. 119 14 C.F.R
. 91
. 121 14 CFR 91
. 151 (a) 14 CFR 91
. 203 (a) & (b) 14 CFR 91
. 405 (a) 14 CFR 407 (a)(l) 1 4 CFR 409 (a) (2) 14 CFR 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress ’s 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 safely in the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UAS s size, weight, speed, and operational capability  Operation of the UAS in close proximity to airports and populated areas; and  Operation of the UAS within visual line of sight of the operator. Reform Act Section 333 (a)
. Lastly, if the Secretary determines that such vehicles " may operate safely in the national airspace system, the Secretary s hall establish requirements for the safe operation of such aircraft in the national airspace system. " ID Section 333( c) (emphasis added) The Federal Aviation Act expressively grants the FAA the authority to issue exemptions. This statutory authority by its term s includes exempting civil aircraft, as the term is defined under section 4 0101 of the Act, that includes UAS ’ s, from the requirement that civil aircraft must have a current airworthiness certificate. 

### Applicant interprets this provision to place the duty on the Administrator not only process applicants for exemptions under section 333, but for the administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not 

### fulfill the statutory requirements for a pproval
.



### 2

## The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any s ections 44702
- 44716 of this title if the Administrator find s the exemption in the public interest
. 49 U.S.C
. Section 44701(f) see 

### also 49 USC Section 44711(a); 49 USC Section 44704; 14 CFR Section 91
. 203 (a) (1). Rescue Internati onal, Inc. , UASs are rotorcraft, and fixed wing UASs weighing 55 or fewer or lbs. including payload. They operate, under normal conditions at a speed of no more than 70 knots and in the case of our multirotors , they will have a capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate in a line of sight and will operate only within search areas determined to be save and these area s are mostly made up of farm land, rural lands, bodies of water and water ways . Rescue device deliveries will be limited to short line of sight delivers of rescue devices and rescue lines by trained 1 st 

### responders under rescue mission deployments and following written procedures and guidelines. Given the small size of the UAS ’ s involved and restricted operational environment within which the y will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption , allow commercial and public safety operations of UAS ’ s to commence immediately
. Also due to the size of the UAS ’ s and the restricted areas in which the relevant UASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced public safety , reduction in environmental impacts, including reduced emissions and chemical spills, e xemptions now associated with a l lowing UASs for agricultura l operations, the grant of the requested exemptions is in the public interest
. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. A s we are in active tornado season and face an active upcoming hurricane season were RI can deploy this resource to assist in SAR and disaster rescue and recovery operations with the use of SAR UAS from RI chapters in the USA.

### AIRCRAFT **AND EQUIAVLENT**  **LEVEL OF SAFETY** The applicant proposes that the exemption requested herein apply to aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regul atory structure because the proposed operations represent a safety enhancement to the already safe , law enforcement and public safety air response resources currently being used with conventional aircraft
. 1. The UA Ss will weigh less than 55 lbs. 2. Flights will be operated within line of s ight of a pilot and observer and they will at all times be able to communicate by voice 3. Maximum total flight time for each operational flight will be 30 mi nutes for multirotor application and 6 0 minutes for fixed wing operation. Flights will be terminated at a 1 5 % battery power reserve s hould that occur prior to the manufacturer recommended l imit for safe return
. 4. Flights will be operated at an altitude of no more than 2 00 feet AGL
. Meeting the March 2015 blanket COA requirement for flights no higher than 200 feet AGL 5. Minimum crew for each operation will consist of the UAS Pilot (UAS rated PIC) , and Trained Visual Observer. 6. UAS Pilot will be certified as a UAS pilot by taking an approved class developed and administered by Rescue International Training Academy (RITA) including a written test covering UAS flight operations, F AA required manuals, SOPs and Logs, FAA rules, Emergency Procedures , Operational Safety, Airspace requirements and restrictions , maintaining the UAS, FAA reporting requirements., a class of 20 hours of instruction and 8 hours of group hands on flight training with a UAS rated PIC , plus pre
- class 10 hrs. of logged RCC or UAS SAR fo rmal flight training, No medical certificate is required. A government driver’s license is required. 7. A RI TA certified or equivalent trained and tested UAS Pilot, will be pilot in command (PIC). Or other required FAA certificate as may be required by final ruling. 8. The 

### U AS will only operate within a conf irmed " safe area" and have a "Security Perimeter" for the aerial search flight operation area. UASs are covered by 1 million dollar liability policy 9. 

## A briefing will be conducted in regard to the planned UAS o perations prior to each search flight with staff assisting with flight operations . It will be mandatory that all personal who will be performing duties within boundaries of the safety perimeter be present for this briefing. 10. The operator will not need a FAA Form 7711
- 1 fil ed or its equivalent, as modified in light of the requested exemption s covering this action , as applicant will no t engage in Movie or TV production activities
. The FAA Blanket 200 Ft. COA as issued will be followed for all aerial search flights for lost or missing person
. 11. The operator will obtain the consent of all persons involved in the launch area and ensure that only consenting persons be allowed within 100 feet of the flight operation home point 12. The operator or agency staff will during an emergency flight conditions make a Plan of Activities to the FSDO 30 minutes before the proposed s earch flights if the operator needs to request a reduction of the 100 foot distance to a lower range. 13. Pilot and observer will have been trained in the operation of the UAS technical functionality and received up
- to - date information on the particular UAS is use
. PIC shall have the
. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual 14. Aerial search operations will be launched from and with w ritten /or oral permission from the relevant property holders will be obtain ed we re required
. 15. If the UAS losses communications with PIC ’s flight controller , the UAS will have capability to return to a pre - determined home location within the Security Perimeter and land. 16. The UAS will have advance flight capabilities to abort flight in case of unpredictable emergencies , encroachment on limitations to airports or los s of pilot’s data link or active control. 17. The UAS shall be marked by exception to 45.29 (f) with the markings of “RESCUE” in a noticeable manor and/ size and/or display a N number as may be required by the FAA 18. UASs to be used under this ruling are DJI Phantom 2 Plus, Phantom Three (3) and DJI Inspire series airframes and systems.

### 14 C.F.R **. Part 21, Subpart H: Airworthiness ce**  **rtificates 14 C .**  **F.R .**  **Section 91.203 (a) (1)** Subpart H, entitled Airworthiness Certif i cates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR Section 91
. 203 (a) (1). Given the size an d limited operating area associated with aircraft to be utilized by the Applicant , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate , upon consideration of t he size, weight , speed, operational capability, proximity to airports and pop ulated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in a restricted environment and under the 

## conditions proposed will be at least as safe, or safer, than conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the retractions and conditions proposed. The UAS to be operated here under , is less than 55 lbs. fully loaded, carries neither a pi l ot nor passenger, c arries no explosive materials, flammable materials or liquid fuels, and operates exclusively within a secured launch area as set out in manual
. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and pursuant to the requirements, and in c ompliance to local public safety requirements, to provide security of the area of operation as is now done with conventional aircraft support to SAR missions . The FAA will have advance notice of required operations
. These safety enhancements, which already apply to civil aircraft operated in connection to SAR and public safety operations , provide a greater degree of safety to public an d property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F
. R
. Part 21, Su bpart H. Lastly, application of these same criteria demonstrates that t here is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels and inability to carry a substantial extern al load. **14 C.F.R. Section 45 .**  **23 (b). Marking of the aircraft** The regulation requires:

When marks include only the Roman capital letter ' 'N '' and the registration of the number is displayed on limited, restri cted or in a light
- sport category aircraft or experimental or provisionally certified aircraft, the operator must also display on the 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 spot , " "experimental," or "provi s i onal," as applicable
. Even though the U

AS will have no airworthiness certificate, and exemption may be needed as the 

### U AS will have no entrance to the cabin, cockpit or pilot station on which the word 

## " experimental" can be placed. Given the size of the UAS , the two inch lettering will be impossible. The word 

### "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety wi ll be provided by having the UA S marked on it ’s fuselage as required by §45.29 (f) 

### where the pilot, observer and others working with the UAV will see the identification of the UAV as " Experimental
. " Or if approved by this ruling the use of “RESCUE” as acceptable markings for the UASs under this exemption. This marking is in the best public interest as it provides a quick visual identification as to the public safety use of the UAV
. A FAA N number will be displayed as required in the largest reasonable manner possible, as/if required by the FAA ruling
. The FAA has i ssued similar exemptions to this regulation by Exemptions Nos. 10700, 8738, 10167A
.**14 C.F.R .**  **§ 61.113 (a)**  **& (b): Private pilots Privileges and Limitations: Pilot in Command** 
. 

### Sections 

### 61
. 113 (a) & (b) limit pilots to non
- commercial operations. Because the 

### U AS will not carry a pilot or passengers, the proposed operations can achieve th e equivalent level of safety of current operations by requiring the PIC operating the aircraft to have formal UAS training class of 20 hours and more than 10 logged flight hours of operation done under private use RCC rules of operation of small 

### U AS or by hours of supervised training under this exception by a qualified RITA or equivalent UAS rated pilot.

. Unlike a conventional aircraft that carri es a pilot and passengers, the UAS is remotely controlled with no living thing onboard. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth by in the S.O.P. The level of safety provided by the requirements included in the S.O.P exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associate d with the operation of the UAS are so diminished from the level of risk associated with the operation of a commercial operations contemplated with Part 

### 61 when drafted, we request a exception from 61.113 allowing operations of the UAS as requested with a formally trained UAS pilot as the PIC , this we believe meets or exceeds the present level of safety achieved by 14 

### C.F .R
. §61 , 113 

### (a) & (b). for UAS flights and is in the publics best intrest
. **14** 

### C.F.R. **§91 .**  **7** 

### (a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthiness condition. As there will be no airworthiness certificate issue d for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the SOP for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. **14 C.F .**  **R.** 

### § **91 .**  **9 (b) (2): Civil Aircraft Flight Manual in the Aircraft** Section 91
. 9 (b) (2) provides: No person may operate a U S
- registered 

### civil aircraft ..
. (2) For which an Airplane or Rotorcraft Flight Manual is not required by §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 placard, or any combinati on thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot onboard, but because there is no room or capacity to carry such an item on the aircraft. The e quivalent level of safety will be maintained by keeping the flight manual at the ground contro l po int where the pilot flying the UAS will have access to it
. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 92 99, 9299A, 9565, 

## 9565B, 10167, 10602,32827, and 10700
.

6**14 C.F.R .**  

### § **91 .**  **103: Preflight action** This regulation requires each pi l ot in command to take certain actions before flight to insure the safety of the flight. As the FAA approved rotor craft flight manuals will not be provided as set forth in sections the SOP
. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight
. **14 C .**  **F .**  **R .**  **§91.109: Flight instruction** Section 91.103 provides that no person may operate a civil aircraft (except a manned free bal loon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs and remotely controlled aircraft, by their design do not have fully functioning dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exempti ons for flight training without fully functioning dual controls for a number of aircraft and for flight instruction in experi mental aircraft. See exemp tion Nos.5778K & 9862A
. The equivalent level of safety provided by that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. **14 C .**  **F.R. §91.119: Minim um safe altitudes**  Section 91
. 119 establishes safe altitudes for operations of civil aircraft. Section 91
. 119 (d) allows helicopters to be operated at less than the minimums prescribed provided the person operating the helicopter complies with any route or altitudes prescribed for heli copte r s by the FAA. As exemption is for the UAS that is a helicopter and the exemption requests authority to operate at altitudes of up to 2 00 feet AGL for rotorcraft and fixed
- wing, or not more than 200 feet above an elevated platform such as radio towers , an exemption may be needed to allow such operations. As set forth by herein, except for the limited conditions stated in the SOP, the 

### U AS will never operate higher than 2 00 AGL for rotorcraft and 200 AGL for fixed
- wi ng per the FAA March 2015 Blanket COA for flights up to 200 fe et
. UASs will however be operated in a restricted area with a security perimeter, where buildings and people will not be directly exposed to operations without their pre - obtained consent for routine flight operations and an exemption shall be implied by persons in need of rescue were a UAS will be deployed for location of persons at risk and delivery of rescue lines or devices to be used to save a life of persons at risk of injuries or loss of life. The equivalent level of safety will be achieved given the size, weight, speed of the 

### U AS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local offic i als
. Because of the advance notice if requir ed to the property owner and participants in the activity, al l affected individuals will be aware of the planned flight operations as set forth in the SOP. An exemption shall be implied by persons in need of rescue were a UAS will be deployed for delivery of rescue lines or devices to be used to save a life of persons at risk of injuries or loss of life. State laws as to rights of public safety 1 st responders shall apply as to access to private property during emergency responses and rescue operations. Com pared to flight operations with aircraft or rotorcraft weighing far mo re than the maximum 551bs. proposed herein and the lac k 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 UAS will ensure separation between these small UAS ' operations and the operations of conventional aircraft that must comply with Section 91
. 119. **14 C.F.R .**  **§ 91.121 Altim**  **eter 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 avail able before departure." As the UAS 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 l aunch and Safety Check list , confirmin g the altitude of the l aunch site w

### 4 C **. F.R. §91**  **. 1S1**  **(a): Fuel Requi rements for Flight in VFR**  **l Requirements for Flight in VFR Conditions** Section 91
. 151 ( a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed
- (1) During the day, to fly after that for at least 

### 30 minutes; or 

### (2) At night, to fly after that for at least 

### 45 mi nutes." The battery powering the UAS provides approximately 35 minutes of powered flight
. To meet the 30 minute reserve requirement in 14 

### CPR §91
. 151, UAS flights would be limited to approximately 

### 5 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night 

### VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91
. 15l(a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed or person in need of rescue display an implied consent to being rescued by the 1 st responders and a UAS , with less than 

### 30 mi nutes of reserve fuel, does not engender the type of risk that Section 91
. 151(a) was intended to alleviate given the size speed of the small UAS. Additionally, limiting UAS flights to 5 minutes would greatly reduce the utility for which the exemption wil l be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 15% of battery power whichever happens first
. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. Similar exempti ons have been granted to other operations, including Exemptions 2689F, 

### 5745, 10673 and 10808
. 

### 14 C.F.R **. §**  **91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration** The regulation provides in pertinent part: (a) Except as provided in §91
. 715, no person may operate a civil aircraft unless it

has within it the following: (1) An appropriate and current airworthiness certi ficate (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 coc kpit entrance so that it is legible to passengers or crew . The UAS full y loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or di splay them on the UAS
. An equivalent level of safety will be achieved by keeping these documents at the ground control po int where the pilot flying the UAS will have immediate access to them , to the extent they are applicable to the UAS. The FAA has issue d numerous exemptions to this 

### regulation. A representative sample of other exemptions includes
. Exemption Nos. 9565,9665,9789, 9789A, 9797,9816A, 10700. 

### 14 C.F **. R** **. §91**  **. 405**  **(a);** 

### 407 **(a)** 

### (2); 417 **(a)** 

### & (b) 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 oth ers shall inspect or maintain the aircraft in compliance with part 43.

### Given that this section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the application. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual
. An equivalent level of safety will be achieved because these small UAS ’ s are very limited in size and will carry a small payload and operate only in restricted areas or temporary areas of emergency response to an unplanned event for limited periods of time. I f mechanical issues arise the UAS can land immediately and will be operating from no higher than 2 00 feet AGL rotorcraft and 2 00 feet AGL for fixed
-wing. As provided in the SOP, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance preformed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety
. **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 C.F.R
. §21, subpart H; 14 C.F.R 45
. 23 (b); 14 C.F.R. §§ 61
. 113 (a) & 

### (b); 91
. 7 (a); 91
. 9 (b) (2);91
. 103 (b); 91
. 109; 91
. 119;91
. 121;91
. 151 (a); 91
. 203 (a) an d (b); 91
. 405 (a); 91
. 407 (a) (1); 91
. 409 (a) (2) and 91
. 417 (a) & 

### (b) to operate commercially a small unmanned vehicle (551bs or less) in the Agricultural 3d Mapping Service Operations. Approval of exemptions allowing commercial operations of UAS ’ s in the Agricultural 3 D mapping/scanning and tower inspection industry will enhance safety by reducing risk. Conventional operations using jet or piston aircraft, operate at extremely low altitudes just feet from the equipment and livestock and structures ; and present the risks associated with vehicles that weigh in the neighborhood of 3,000
- 5,000 lbs., carrying large amounts of J et A or other fuel in most cases helicopters operating with 140 gallon fuel tanks. The UAS will carry no passengers or crew and therefore , will not expose them to the risks associated with manned aircraft flights. The operations of small UAS ’ s, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the Part 21 

### and allowing commercial operations. These lightweight UA 

### S’ s operate at slow speeds, close to the ground and in sterile environment and as a result, are far safer than conventional operations conducted with a piston and or turbine aircra ft operating close to the ground. Public Acknowledgement/Privacy

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012,
- ' size, weight, speed, operating capabilities, proximity to populated areas and or close proximity to airports and operations within visual line of sight provides more than adequate justification for the grant of the requested exemptions allowing public safe ty /commercial operation of applicant's UAS. Sincerely

Bruce Barton Director of Operations, CEO, Rescue International Inc.



## cc: Board Members19.