August 27, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Bardha Air for Grant of Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER Bardha Air ATTN: Ilir Bardha 3300 Lone Pine Road West Bloomfield, MI 48323 (248) 722-3747 elebardha@gmail.comAugust 27, 2015

Page 2 I. PETITION SUMMARY Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general exemption authority under 49 U.S.C. § 44701(f), Bardha Air ("Petitioner") hereby petitions for exemptions from 14 C.F.R. Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)(1) 91.409(a)(2), 91.417(a)-(b). The proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds or less for the purpose of closed-set filming of motion pictures, music videos, web videos, corporate videos,television programs and commercials, wedding and entertainment venue videos, aerial videography and photography for real estate and still photography. Based on the small size of Petitioner's UAS, the qualifications and experience of Petitioner's UAS operators, and the restricted, sterileAu g ust 27, 2015

Pa g e 3 enviromnent within which Petitioner will operate, the re q uested exetnptions fall s q uarel y within the zone of safet y envisioned b y Con g ress and set forth in Section 333. Additionall y , the enhanced safet y achieved b yreplacin g si g nificantl ylar g er manned aircraft carr y in gcrew and flammable fuel widi small UAS cart y in g no passen g ers or crew and operated under the specific g uidelines and procedures proposed b y Petitioner g ives the FAA g ood cause to find that the UAS operations enabled b y the instant Petition are in the public interest. Because the

re q uested exemption would not set precedent, and because an ydela yin actin g on this Petition would be detrimental to Petitioner, g ood cause exists for g rantin g this Petition on an expedited basis pursuant to the FAA!s streamlined "Summar yGrant" process. In addition, g ood cause exists for fore g oin g a published summat yof the petition in the Federal Re g ister. Thus, Petitioner respectfWl y re q uests that the FAA g rant this non-precedent settin g exemption on an expedited basis.Au g ust 27, 2015

Pa g e 4

H. STATUTORY AUTHORITY A. Section 333 Section 333, titled "Special Rules for Certain Unmanned Aircraft S y stems," provides a mechanism for seekin gexpedited FAA audiorization of safe civil UAS operations in the National Airspace S y stem ("NAS"). Section 333(a) states that the FAA "shall determine if certain unmanned aircraft s y stems ma yoperate safel yin the national airspace s y stem before completion of the [comprehensive] plan and rule makin g re q uired b y section 332(b)(1) of this Act or the g uidance

re q uired b y section 334 of this Act." In Section 332(b)(1), Con g ress made it clear that Section 333 provides a mechanism for "expedited operational authorization." The FAA has committed to compl y in g with this mandate b y g rantin gseveral petitions almost identical to the one at hand. See, e. g ., Exemption No. 11062, Re g ulator yDocket No. FAA-2014-03 52 ( g rantin g re g ulator y exemptions to Astraeus Aerial forAu g ust 27, 2015

Pa g e 5 operation of unmanticd aircraft s y stems for the purpose of filmin gfor the motion picture and television industr y ). Section 333 ( b) identifies several factors that the FAA should consider in determinin gwhether commercial UAS operations should be approved. These include UAS that, "as a result of their size, wei g ht, speed, operational capabilit y , proximit y to airports and populated areas, and operation within visual line of si g ht do not create a hazard to users of the (NAS) or the public or pose a direat to national securit y ." See Section 333(b). B. Section 4470 1 (f) In addition to the specific authorit yconfeffed b ySection 333, the FAA Administrator has g eneral authorit yto g rant exemptions from the FAMs safet y re g ulations and minimum standards when the Administrator decides a re q uested exemption is in the public interest. See U.S.C. § 44701(f).Au g ust 27, 2015

Pa g e 6 III. REQUESTED EXEMPTIONS

Petitioner re q uests relief from the followin g re g ulations: Part 21 prescribes, in pertinent part, the procedural re q uirements for issuin gand chan g in g desi g n approvals, production approvals, airworthiness certificates, and airworthiness approvals. Section 61.113 prescribes that "no person who holds a private pilot certificate ma yact as a pilot in command of an aircraft that is can y in g passen g ers or propert y for compensation or hire ; nor ma ythat person, for compensation or hire, act as pilot in command of an aircraft," (see Section 61.113 ( a)), and that "a private pilot ma y , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or emplo y tnent if: ( 1) The fli g ht is onl yincidental to that business or emplo y tnent ; and ( 2 ) The aircraft does not carr y passen g ers or propert yfor compensation or hire," (see Section 61.113(b)).Au g ust 27, 2015

Pa g e 7 Section 61.133(a) sets forth privile g es for persons holdin g commercial pilot certificates, includin ga provision impliedl y limitin gto persons holdin g a commercial pilot certificate the abilit yto act as pilot in command of an aircraft "[flor compensation or hire." Section 91.7(a) prescribes, in pertinent part, that no person ma y operate a civil aircraft unless it is in an airworth ycondition. Section 91.9(b) ( 2 ) prohibits operation of U.S. re g istered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Fli g ht Manual, approved manual material, markin g s, and placards, or an ycombination thereof Section 91.103 ( b)(1) prescribes, in pertinent part, that each pilot in command shall, before be g innin g a fli g ht, become familiar with all available infortnation concernin gthat fli g ht, to include, "For an y fli g ht,

runwa y len g ths at airports of intended use, and the followin g takeoff and landin g distance infortnation:

... For civil aircraft for which an approved Airplane or Rotorcraft Fli g ht Manual containin g takeoff and landingAu g ust 27, 2015

Pa g e 8

distance data is re q uired, the takcoff atid latiditi g distaticc data cotitaiticd therein." Section 91.119(c) prescribes that, except when necessar y for takeoff or landin g , no person ma yoperate an aircraft below the followin g altitudes: "Over other than con g ested areas. An altitude of 500 feet above the surface, except over open water or sparsel ypopulated areas. In those cases, the aircraft ma ynot be operated closer than 500 feet to an y person, vessel, vehicle, or structttre." Section 91.121 re q uires, in pertinent part, each person operatin gan aircraft to maintain cruisin galtitude b y reference to an altimeter that is set 'lo the elevation of the departure airport or an appropriate altimeter settin gavailable before departure." Section 91.151 (a) prescribes that no person ma ybe g in a fli g ht in an airplane under VFR conditions unless (considerin gwind and forecast weadier conditions) there is enou g h fuel to 

### fl y to the first point of intended landin g and, assumin gnormal cruisin g speed, (1) durin g theAu g ust 27, 2015

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da y , to 

### fl y after that for at least 30 miiitites; or ( 2) at ni g ht, to 

### fl y after that for at least 45 minutes. Section 91.203 prohibits, in subpart ( a ) , an y person from operatin g a civil aircraft unless it has within it (1 ) an appropriate and current airworthiness certificate ; and (2 ) an effective U.S. re g istration certificate issued to its owner or, for operation within the United States, the second cop y of the Aircraft Re g istration Application as provided for in § 47.31(c). Section 91.203 prescribes, in subpart ( b), that no person ma y operate a civil aircraft unless the airworthiness certificate or a special fli g ht authorization issued under § 91.715 is displa y ed at the cabin or cockpit entrance so that it is le g ible to passen g ers or crew. Section 91.405(a) re q uires, in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in subpart E of the same part and shall, between re q uired inspections, except as provided in para g raph ( c) of the same section, haveAu g ust 27, 2015

Pa g e 10 discrepancies repaired as prescribed in Part 43 of the chapter. Section 91.407(a)(1) prohibits, in pertinent part, an y person from operatin gan aircraft that has under g one maintenance, preventative maintenance, rebuildin g , or alteration unless it has been approved for return to service b ya person audiorized under § 43.7 of the same chapter. Section 91.409(a)(2) prescribes, in pertinent part, that no person

ma y operate an aircraft unless, within the precedin g 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. Section 91.417 ( a) and (b) prescribes, in pertinent part, that - (a) Each re g istered owner or operator shall keep the followin g records for the periods specified in para g raph (b) of this section: ( 1) Records of the maintenance, preventativeAti g ust 27, 2015

Pa g e 11 inaintenance, and alteration and records of the 100-hour, annual, pro g ressive, and other re q uired or approved inspections, as appropriate, for each aircraft ( includin g the airframe) and each en g ine, propeller, rotor, and appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the work performed ; and (ii) The date of completion of the work performed ; and (iii) The si g nature, and certificate number of the person approvin gthe aircraft for return to service.

(2) Records containin gthe followin ginforination:

(i) The total time in service of the airframe, each en g ine, each propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, en g ine, propeller, rotor, and appliance.Au g ust 27, 2015

Pa g e 12 (iii) The time since last overhaul of all items installed on

the aircraft which are re q uired to be overhauled on a specified time basis. (iv) The cun•ent inspection status of the aircraft, includin g the time since the last inspection re q uired b ythe inspection pro g ram under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives includin g , for each, the method of compliance, the AD or safet y directive number and revisions date. If the AD or safet y directive involves recurrin gaction, the time and date when the next action is re q uired. (vi) Copies of the forms prescribed b y§ 43.9(d) of this chapter for each major alteration to the airframe and cuffentl y installed en g ines, rotors, propellers, and appliances.Au g ust 27, 2015

Pa g e 13 ( b ) The owner or operator shall retain the followin g records

l'or the periods prescribed: (1) The records specified in para g raph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for I y ear after the work is perforined. (2) The records specified in para g raph ( a)(2) of this section shall be retained and transferred with aircraft at the time the aircraft is sold. (3) A list of defects fumished to a re g istered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return

IV. PETITIONER'S PROPOSED OPERATIONS SATISFY SECTION

A. Unmanned Aircraft S y stem The UAS to be operated undcr this rc q ucst arc Icss than 55 lbs.Au g ust 27, 2015

Pa g e 14 full yloaded, will be operated at a speed of no more than 50 knots, carr y neither a pilot nor passen g er, carr y no explosive materials or flainmable li q uids, and operate exclusivel ywithin a secured area. Petitioner's UAS use a radio fre q uenc yspectrum for operation and control that complies with Federal Communications Commission ("FCC") re q uirements, and Petitioner has inte g rated safet yfeatures into the UAS, as described in Petitioner's Fli g ht Operations and Procedures Manual ("FOPM") and Motion Picture and Television Fli g ht Operation Manual ("MPTFOM") (collectivel y , "operations manuals" ) .'

Petitioner's UAS are e q uipped with redundant safet ymechanisms allowin g thetn to operate safel yafter experiencin gcertain in-fli g ht failures. If a lost-link event occurs, includin g the loss of g round I The MPTFOM and FOPM will be submitted separatel yand confidentiall yunder 14 C.F.R. 11.35(b), as the manuals contain proprietar yinformation that the applicant has not and will not share with others. The manuals contain operatin gconditions and procedures that are not available to die public and are protected from release under the Freedom of InforFnation Act, 5 U.S.C. §§ 552, et seq.Au g ust 27, 2015

Pa g e 15 communications and/or the loss of a GPS si g nal, Petitioner's UAS have the abilit y to perform a pre-coordinated, predictable, automated fli g ht maneuver and return to a predeterinined location within a desi g nated securit yperimeter for landin g . The UAS fi

► iher have the abilit yto abort a fli g ht in the event of unpredieted obstacles or einer g encies. All fli g hts will be terminated after a maximum of 30 minutes or with 25% remainin gbatter ypower, whichever occurs first. Thus, g ood cause exists for g rantin gPetitioner's

re q uested relief from 14 C.F.R. § 91.151(a) (settin g forth fuel

re q uirements for fli g ht in VFR conditions). Petitioner's UAS will be identified b yserial number, re g istered in accordance with 14 C.F.R. Part 47, and have identification ( N-Number) markin g s in accordance with 14 C.F.R. Part 45, Subpart C. Markin g s will be as lar g e as practicable.Au g ust 27, 2015

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Re g ardin g Petitioner's re q uested relief from 14 C.F.R. § 91.121 ( Altimeter Settin g s), Petitioner seeks such relief because Petitioner will not have a t y pical barometric altimeter onboard the UAS. Instead, altitude inforination will be provided to the UAS PIC via a di g itall y encoded telemetric data feed, which downlinks from the aircraft to a g round-based on-screen displa y . The altitude information will be g enerated b y e q uipment installed onboard the UAS, usin gGPS txian g ulation, di g itall y encoded barometric altimeter, radio altimeter, or

an y combination thereof Prior to each fli g ht, a zero altitude initiation point will be established and confirmed for accurac y b ythe UAS PIC. Thus, g ood cause exists for g rantin gthe re q uested relief from 14 C.F.R. § 91.121. Given the size, wei g ht, speed, and limited operatin garea associated with the aircraft to be utilized b ythe applicant, an exemptionAti g ust 24,2015

Pa g e 17 from 14 C.F.R. Part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is waffanted (if necessat y ) and meets the re q uiretnents for an e q uivalent level of safet y under 14 C.F.R. Part 11 and Section 333. The UAS operated without an airwordliness certificate in the restricted environment and under the conditions and limitations proposed b y Petitioner will be at least as safe, or safer, than a conventional aircraft (fixed win gor rotorcraft) operatin g with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the proposed limitations and conditions. Petitioner will strictl y compl ywith safet yand maintenance procedures included in all applicable UAS manufacturer's instructions and operatin g manuals. To the extent such infortnation is not included in the g uidelines developed b ythe manufacturers, Petitioners will develop and document maintenance, overhaul, replacement, and inspection

re q uirements, procedures to document and maintain maintenance records with re g ard to Petitioner's UAS, and UAS technicianAu g ust 27, 2015

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q ualification criteria. Petitioner's operations manuals will include maintenance re q uirements for Petitioner's UAS, includin g "onconditiote' maintenance and modifications. In li g ht of these miti g atin g factors, exemptions from 14 C.F.R. §§ 91.405(a ) , 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) are warranted.

B. UAS Pilot in Command Petitioner's UAS pilot in command ("PIC") shall hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC shall also hold a current FAA airman medical certificate or a valid U.S. driver's license issued b ya state, the District of Columbia, Puerto Rico, a territor y , a possession, or the Federal g ovemment. Since there are no standards for either private or commercial UAS pilot certificates, knowled g e of airspace re g ulations ac q uired from FAA g round school and dexterit yin the control and operationAu g ust 27, 2015

Pa g e 19 of the UAS ac q uired from actual operation of the aircraft will be the most important factors in establishin g an e q uivalent level of safet y . Accordin g to the FAA, "the FAA considers the overridin g safet yfactor for the limited operations proposed b y the petitioner to be the airmanship skills ac q uired throu g h UAS- specific fli g ht c y cles, fli g ht time, and specific make and model experience, culminatin g in verification throu g h testin g ." See Exemption No. 11062, Re g ulator y Docket No. FAA2014-0352, at p. 18. With those factors in mind, Petitioner's UAS PIC shall be re q uired to meet several conditions and limitations as outlined in the FOPM and MPTOM, includin gthe followin g : • The UAS PIC will have accumulated and lo gg ed a minimum of 200 fli g ht c y cles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours lo gg ed as a UAS pilot with a similar UAS t y pe ( sin g le blade or multirotor). • The UAS PIC will have accuinulated and lo gg ed a minimum of five hours of fli g ht time with the specific make and model of the UAS toAu g ust 27, 2015

Pa g e 20 be utilized for operations under the exemption and three take-offs and landin g s in the precedin g 90 da y s. • The UAS PIC will have successfull ycompleted the q ualification process as specified in the operations manuals, to include a knowled g e and skill test. 2

Re g ardin g Petitioner's re q uested relief from 14 C.F.R. § 91.7(a), it is Petitioner's understandin g that Petitioner's UAS will not re q uire an airworthiness ceilificate in accordance with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessar y . To the extent such an exemption is deemed necessar y , Petitioner asserts that it should be g ranted in li g ht of the safet yprocedures proposed herein. In accordance with the pertinent part of 14 C.F.R. § 913 ( b), the operator in command of Petitioner's UAS shall be responsible for 2 Prior to operatin g , the PIC will be re q uired to pass the knowled g e and airmanship test q ualifications developed b yPetitioner for the UAS ( which are included in Petitioner's operations manuals). There are no established practical test standards that support a jurisdictional FAA FSDO ("Fli g ht Standards District Office") evaluation and approval ofcompan y desi g nated examiners. Petitioner will conduct these tests in accordance with its operations manuals. Given the oonstraints ofthe proposed operations, this procedure for testin g will not adversel y affect the safet y ofthe NAS.Au g ust 27,2015

Pa g e 21 determinin g whether the aircraft is in a safe condition for fli g ht. Petitioner's manuals for maintenance and operations shall include safet y checklists to be used b ythe operator in command prior to each fli g ht. Re g ardin g Petitioner's re q uested relief from 14 C.F.R. § 91.9(b)(2) ( Civil aircraft fli g ht manual, markin g , and placard re q uirements) and § 91.203 ( a) and (b), (Civil aircraft: certifications re q uired), it is Petitioner's understandin g that relief from these for operations under the exeinption and three take-offs and landin g s in the re g ulations is no lon g er necessar y in li g ht of the FAA Memorandtan "Interpretation

re g ardin g whether certain re q uired documents ma ybe kept at an unmanned aircraft's control station," dated Au g ust 8, 2014. To the extent the FAA deems an exetnption from this section necessar yfor Petitioner's proposed operations, such exemption should be g ranted in li g ht of the miti g atin g fact that Petitioner will maintain the documents re q uired under 14 C.F.R. §§ 91.9 and 91.203 at the UAS g round control station durin gflights.August 27, 2015

Page 22 Additionally, 100% of Petitioner's operations will utilize a visual observer ("VO"). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and the PIC will be able to communicate verbally at all times during operational flights. Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b) (1), Petitioner will comply with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and takeoff distances beforeinitiation of a flight. The PIC will also account for all relevant sitespecific conditions in their preflight procedures. Risks presented by sun glare will be mitigated by the PIC's and VO's ability to see other air traffic and initiate a return-to-home sequence if needed. The PIC's UAS operation will be limited to a unique and restricted environment. Given the (1) separation of closed-set filming operations from other manned operations, (2) parallel nature of aeronauticalAu g ust 27, 2015

Pa g e 23 knowled g e re q uirements incumbent in obtainin ga private, recreational, or sport pilot certificate versus a commercial pilot's license, and (3) the proposed UAS airmanship skills of Petitioner's PICs, the additional manned airmanship experience of a commercial pilot would not coffelate to the airinanship skills necessar yfor Petitioner's proposed unmanned operations. Thus, Petitioner's re q uest for relief from 14 C.F.R. § 61.113(a) and (b) and § 61.133(a) should be g ranted.
C. Operatin gParameters of Petitioner's UAS Petitioner's UAS operations will be conducted within a sterile environinent of closed-set filmin g . In this controlled environment, Petitioner's operations will remain within VLOS of the PIC and VO, below 400 feet AOL, and at speeds below 87 knots. Onl y participatin g persons will be permitted within the operatin garea.3Au g ust 27, 2015

Pa g e 24

Consistent with the relief t y picall y provided to manned operations under FAA Order 8900. 1, Volume 3, Chapter 8, Section 1, Petitioner

re q uests relief from 14 C.F.R. § 91.119 ( c) with respect to those participatin g persons, vehicles, and structures directl yinvolved in the perforinance of the actual filmin g . Re g ardin g distance from participatin g persons, the operations manuals set forth safet yfactors for authorized and consentin g production personnel. Because those procedures are specific to participatin g persons, no fiirther FSDO or aviation safet y inspector approval is necessar yfor reductions to the distances specified in Petitioner's manuals.
Re g ardin g the distance from nonparticipatin gpersons, Petitioner will ensure that all operations are conducted at least 500 feet from all nonparticipatin gpersons, vessels, vehicles, and structures unless: (a) Barriers or struetttres are present that sufficientl yprotect nonparticipatin gpersons from the UAS and/or debris in the eventAu g ust 27, 2015

Pa g e 25 of an accident. Petitioner will ensure that nonparticipatin g persons remain under such protection. If a situation arises where nonparticipatin gpersons leave such protection and are within 500 feet of the UAS, fli g ht operations must cease immediatel y in a manncr ensurin g the safet y of nonparticipatin gpersons ; and

( b ) The owner/controller of an yvessels, vehicles, or structures has g ranted permission for operatin g closer to those objects and the PIC has made a safet yassessment of the risk of operatin gcloser to those objects and has detertnined that it does not present an undue hazard.
Unless a letter of a g reeinent with an aitport's mana g ement is obtained or the operations are otherwise permitted b y a Certificate of Waiver or Authorization ("COA"), Petitioner will not conduct UAS operations widiin 5 nautical miles of an airport reference point ("ARP") as denoted in the current FAA Airport/Facilit y Director y ('AFD"). For airports not denoted with an ARP, Petitioner will not conduct UAS operations withinAu g ust 27,2015

Pa g e 26 5 nautical miles of the center of the airport s y tnbol as denoted on the current FAA- published aeronautical chart, without the aforementioned letter of a g reement or COA in place. The letter of a g reement with airport

mana g ement will be made available to the FAA and an ylaw enforcement official upon re q uest. All operations will be conducted in accordance with a Notice to Airmen ("NOTAM'). Additionall y , Petitioner will not operate in Class B, C, or D airspace without written approval from the FAA. Nor will Petitioner operate the UAS less than 500 feet below or less than 2,000 feet horizontall yfrom a cloud or when visibilit yis less than 3 statute miles from the PIC.
Petitioner's UAS will remain clear and y ield the ri g ht of wa yto all manned operations and activities at all times (includin g , but not limited to, ultrali g ht vehicles, parachute activities, parasailin g activities, and han ggliders).Au g ust 27, 2015

Pa g e 27 Althou g h Petitioner seeks to compl y with the waiver process as described in FAA Order 8900. 1, Volume 3, Chapter 8, Section I (Issue a Certificate of Waiver for Motion Picture and Television Filmin g ), the cuffent section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from issuin g the re q uired Certificate of Waiver, because the section did not ori g inall yprovide for UAS operations. Thus, Petitioner seeks exemption from the applicable

re g ulations nortnall y waived durin g that process. Petitioner proposes that the FAA include the re q uired notifications and coordination with jurisdictional FSDOs throu g h the conditions and limitations accompan y in gthe re q uested exemption, and that the exemption sou g ht herein will take the place of the Certificate of Waiver nortnall yissued b y a jurisdictional FSDO under 8900.1. Under this rubric, Petitioner will notif y ever y FSDO with jurisdiction over the area that Petitioner plans to operate, just as with manned filmin g operations, and those FSDOs will liave the abilit yto coordinate further conditions and limitations with the [JAS Inte g ration Office to address an ylocal concems.Au g ust 27, 2015

Pa g e 28 Petitioner re q uests a "blanket" COA permittin gcommercial UAS operations at or below 200 feet AGL. For all other operations, Petitioner will obtain an Air Traffic Or g anization ("ATO") issued COA prior to conductin g an y operations under this g rant of exeinption. In fulfillin g its

re q uirements under the COA, Petitioner will be re q uired to re q uest a NOTAM not more than 72 hours in advance, but not less than 24 liours prior to the operation. When applicable, all UAS operations will be cotidtictcd in accordance with an ystate or local privac y laws. D. The Re q uested Exeinption Promotes the Public Interest

The enhanced safet y achieved b yreplacin g si g nificantl y lar g er manned aircraft cart y in g crew and flammable fuel with small UAS

carr y in gno passen g ers or crew and operated under the specific g uidelines and procedures proposed b yPetitioner g ives the FAA g ood cause to find that the UAS operations enabled b y the instant Petition areJ iv io q piv g u q pju El J ill `pau ! w q ns A li r

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