3D Aerial Solutions LLC 4725 Constitutional Court Dayton, OH 45440 Phone: (937) 510-6836

October 8th, 2015 

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U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Ave, SE Washington, DC 20590 Re: ExemptionRequest Pursuantto Section 333 ofthe FAAReform Act of2012 and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 14 CFR61.113 (a); 14 CFR 61.315 (a); 14 CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR91.151 (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 Sir orMadam:

Pursuantto·Section 333 ofthe FAA Modernization andReform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, 3D Aerial Solutions LLC (3DA) herein after also known as the operator, is an operator ofsmall UnmannedAircraft Systems (UAS). 3D A is an Ohio-based companythat provides specialized expertise in creating and tailoring Unmanned Air Systemtechnology solutions for industrial andpublic applications. 3D A requests this exemptions in orderto pursue UAS applications inthe following areas:

• Aerial surveying, mapping and datacollection • Remote sensing • Educational and research operations • 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 civil engineering: waterways and shipping, forestry, fishery protection, pollution control and air sampling and crop performance • Railroad and motorvehicle road inspection • Telecommunications infrastructure inspection • Utility, Energy systems and electrical engineering inspections and asset management • Agricultural surveying and produce field management • Livestockmanagement and accountability • .· Construction site inspections and monitoring

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• Oil and gas pipeline inspection/patrolling and oil-field inspection • Real estate andmarketing • Aerial event security, surveillance and crowdmanagement • Aerial imagery evidence for property insurance claims • Structure Inspection 3DAhereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation oftheir UA, with full understanding that operations are conducted within andunder the conditions outlined herein or as may be establishedbythe FAA as required by Section 333. As described more fully below, the requested exemptionwould permitthe operation ofsmall, unmanned and relatively inexpensive UAS under controlled conditions inthe National Airspace System (NAS) regulated bythe Federal Aviation Administration (FAA). Approval ofthis exemptionwould thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

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### establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: 3D Aerial Solutions LLC Attn: Bret R. Givens 4725 Constitutional Court Dayton, OH 45440 Phone: (937) 510-6836 Email: bgivens@3daerial.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) & (6)

- Recreational pilot privileges and limitations • 14 CFR 61.113 (a)

- Private pilotprivileges and limitations: Pilot in command • 14 CFR 61.315 (c) (2), (3), (5) & (7)

- What are the privileges and limits ofmy 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) (2)- Fuel requirements for flights inVisual Flight Rules (VFR) conditions • 14 CFR 91.405 (a)- Maintenance 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 Request

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This exemption application is expressly submitted to fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certainunmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine whichtypes ofUAS do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity to airports andpopulated areas • Operation ofthe UAS within visual line ofsight ofthe operator. The aircraft intended for use for the operator includes the DJI Phantom 2, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Matrice 100, Sensefly Exom, 3DRobotics X8, 3DRobotics Y6, & 3DRobotics Solo. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely inthe national airspace system, the Secretary shall establishrequirements for the safe operation ofsuch aircraft inthe national airspace system." Id. §333(c) (emphasis added). The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is definedunder §40101 ofthe Act, which includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe 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). 3D Aerial Solutions LLC'sUAS are rotorcraft, weighting 55 or fewer pounds including payload. The UAS operate under normal conditions at a speed ofno more than 50 knots and have the capability to hover and move inthe vertical and horizontal plane simultaneously. The UAS will be operated only in line ofsiggtand will**b~** operated**~mly** 'Yithin a predetermined and protected flight areaunder the permission ofthe property representative. The UAS 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 as any other limitations the FAA may place on future operations. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public as perthe Reform Act Section 333 (b). Giventhe clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; The strong equivalent level ofsafety surrounding the proposed operations, and the significantpublic benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAS for aerial

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data collection, the grant ofthe requested exemptions is inthe public interest. Accordingly, the applicant respectfully requests thatthe FAA grant the requested exemption without delay. The FAAhas issued grants ofexemption in circumstances similar inmaterial respects to those presented inthis petition. InExemptions Nos. 12990, 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 11109 Aircraft and Equivalent Level ofSafety 14 C.F.R. Part21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required byFAR §91.203 (a) (1). The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteriademonstrates that the UAS operated without an airworthiness certificate, inthe 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 UAS to be operated hereunder are rotorcraft weighing less than 55 pounds including payload, carries neither a pilotnorpassenger. Carries no explosive materials or flammable liquid fuels, and operates exclusively within visual line ofsight ofthe pilot in command (PIC) and a visual observer (VO). They operate at a speed oflessthan 50 knots and have the capability to hover and move inthe 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 ofthe national airspace system. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitoredby boththe operator and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation. The FAAwill have advance notice ofall operations. These safety enhancements provide a greater degree ofsafety 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 ofthese same criteria demonstrates that there is no credible threatto national security posed by the UA, due to its size, speed ofoperation, location of operation, lack ofexplosive materialsor**flaml1!~21~** lig!!!dJuels, and inability to carry a substantial external load. The Secretary ofTransportationhas previously determined that these aircraft meets the conditions ofSection 3 33. Therefore, the FAA has found thatrequest ofrelieffrom 14 CFRpart 21, and any associated noise certification and testing requirements ofpart 36, is not necessary. This has been stated inexemptions to this regulation in Exemptions Nos. 12990, 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230 The applicant proposes that the exemptionrequested herein apply to aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at

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8. Any UAS thathas undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional testflight prior to conducting further operations under this exemption. Functional test flights may onlybe conductedby a PIC with aVO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to notpose 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. Priorto 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. lfthe inspectionreveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer;s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. EachUAS operated under the exemptionmust 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 issuedby a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC must also meetthe flight review requirements specified in 14 CPR § 61.56 in an aircraft inwhichthe PIC is rated onhis orher pilot certificate. 14. The operatormay not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent withhowthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with 14 CPR§ 61.51(b). Flights for the purposes oftraining the operator's PICs and VOs (training, proficiency, and experience building) and determining the PIC's ability to safely operate the UAS in a manner consistent withhowthe UAS will be operatedunder this exemption are permitted underthe terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CPR § 91.119. 15. "VASoperations may not be conductedduring night, as defined in 14 CFR § 1.1. All operations must be conductedunder visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are notauthorized. "

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### Relieffrom this restriction prohibitingnight flight. 3DAerialwould like the ability to perform roof inspections on large commercial buildings with flat roofs. Inwarmer seasons/climates, spots ofa roofthat are leaking have collected water thatretains the day's heatfor a few hours longer than the rest ofthe roofthathas not been compromised. The traditional method for locating leaks, orwet spots on large flat roofs is to use a handheld thermalimaging camera shortly after nightfall and have

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the technicianwalkthe roofto identify leaks. While many safety features are in place, every year, several people become distracted and accidentally walk offan edge in the darkresulting in serious injury or death. This is a very dangerousjob that commercial roofing companies would like to make much safer and even save lives by using UASs. Since the thermal imaging needs to be done shortly after sunset, and after several hours does not yield results, 3DAerial is requesting only partialrelieffrom this limitation and seeking permission to operate up to 4 hours after sunset. 3DAerial will still maintain visual flight rules and only fly underVFR conditions and altitude lower than 100 ft. to top ofinspection site. 16. The UAS may not operate within 5 nautical miles ofan airportreference point (ARP) as denoted inthe current FAAAirport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAApublished aeronautical chart, unless a letter ofagreement withthat airport's management is obtained or otherwise permitted by a COA issued to the exemptionholder. The letter of agreement withthe airport management must be made available to the Administrator or any law enforcement official uponrequest. 17. The UAS may notbe operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhenvisibility is less than 3 statute miles from the PIC. 18. Ifthe UAS loses communications or loses its GPS signal, the UAS mustreturnto a predetermined location withinthe private or controlled access property. 19. The PIC must abort the flight inthe event ofunpredicted 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 UAS to conductthe intended operation andto operate after that for at leastfive minutes orwiththe reserve power recommended bythe manufacturerifgreater. 21. Air Traffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COAifit intends to conduct operations that cannotbe conductedunderthe terms ofthe attached COA. 22. All aircraft operated in accordance withthe exemption mustbe identified by serial number, registered in accordance with 14 CFRpart47, and have identification (N- 6 Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings mustbe as large as practicable. 23. Documents used bythe operatorto ensure the safe operation and flight oftheUAS and any documents required under 14 CFR§§**~91.9** and91.203 mustbe available to the PIC at the Ground Control Stationofthe UAS any timethe aircraft is operating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest. 24. The UAS must remain clear and give way to all manned aviation operations and activities atall times. 25. The UAS may notbe operated by the PIC from any moving device orvehicle. 26. All Flight operations mustbe conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the UAS and/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises

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and in a protected flight area underthe permission ofthe property representative, and all flights are planned and coordinated in advance. Relieffrom restriction prohibiting night flight. 3DAerial would like the ability to performroof inspections onlarge commercial buildings with flat roofs. Inwarmer seasons/climates, spots ofa roofthat are leaking have collected water thatretains the day's heat for a few hours longer than the rest ofthe roofthat has notbeen compromised. The traditional method for locating leaks, or wet spots onlarge flat roofs is to use a handheld thermal imaging camera shortly after nightfall andhave the technician walkthe roofto identify leaks. While many safety features are inplace, every year, several people become distracted and accidentally walk offan edge inthe dark resulting in serious injury or death. This is a very dangerousjobthat commercial roofing companies would like to make much safer and even save lives by using UASs. Since the thermal imaging needs to be done shortly after sunset, and after several hours does notyield results, 3DAerial is requesting only partial relieffrom this limitation and seeking permissionto operate up to 4 hours after sunset. 3DAerial will still maintain visual flight rules and only fly under VFR conditions and altitude lower than 100 ft. to top ofinspection site. The FAA has issued the following exemptions ofthis regulation: ExemptionNos. 12990, 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 andthatthey may not act as pilot in command ofan aircraft that is carrying passengers or property for compensation orhire. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing onboard. The area ofoperation will bepredetermined and in a protected flight areaunder the permission ofthe property representative, and all flights are planned and coordinated in advance. The FAAhas issuedthe following exemptions to this regulation: ExemptionNos. 12990, 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 14 CFR § 61.315 (c) (2) (3) (5) (7): What are the privileges and limits ofmy sport pilot certificate? This section limits sportpilots to non-commercial operations and thatthey may not act as pilot in command ofan aircraft that is carrying passengers orproperty for compensation or hire, or in the furtherance ofa business. They also may not carry more than one passenger, fly at night, and under otherrestrictions that are outside ofthe scope ofintended flights ofthe UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the UAS is remotely controlled with no living thing onboard. The areaofoperation will be predetermined and in a protected flight areaunder the permission ofthe property representative, and all flights are planned and coordinated in advance. Relieffrom restriction prohibiting night flight. 3DAerial would like the ability to performroof inspections on large commercial buildings with flat roofs. Inwarmer seasons/climates, spots ofa

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will ensure separationbetweenthese small- UAS operations andthe operations ofconventional aircraft that must comply with Section 91.119. The FAAhas issued the following exemptions to this regulation: Exemptions Nos. 12990, 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 14 CFR 

### § 91.121: Altimeter Settings. This regulation requires eachperson operating an aircraftto maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemptionmay beneeded. An equivalent level ofsafety will be achieved bythe operator, pursuantto the manufacturer's publishedprocedures and live flight data monitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. Inthe eventthat the GPS altitude read out system becomes none functional during flight, the UAS will also have a pre-programmed maximum flight limit of400 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 § 91.151(a) (1) (2): Fuel Requirements for Flight in VFR Conditions. Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (consideringwind 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 thatfor at least 45 minutes." The LiPo battery powering the DJI Phantom 2 & DJI PhantomVision +,DJI Phantom III, SenseFly Exom, 3DRobotics X8,3DRobotics Y6 and 3DRobotics Solo UAS provides less then 25 minutes ofpowered flight. While the DJI Matrice 100 will support flights up to 40 minutes with a second LiPo battery. The PIC will not begin a flight unless there is enough available power for the UAS to conductthe intended operation and to operate after that leaving at least 20% battery or with the reserve power recommendedby the manufacturer ifgreater. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions, and that flight with less than 45 minutes ofreserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Similar exemptions have been grantedto other operations, including Exemptions Nos. 12990, 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 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 ofthis part and shall betweenrequired inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect ormaintain the aircraft incompliance withPart 43. Given



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that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only inrestricted areas for limitedperiods oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 200 feet AGL and within VLOS ofthe PIC and VO. Priorto 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. Ifthe inspectionreveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. The operatormust follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirements for the aircraft and aircraft components. The FAAhas issuedthe following exemptions to this regulation: Exemptions Nos. 12990, 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. Privacy All flights will occur over private or controlled access property with the property representative orowner's prior consent and knowledge. Filming will be ofpeople who have also consentedto being filmed orotherwise have agreed to be inthe areawhere filming will take place. All flights will occur in accordance with any state or local laws regarding privacy. Additional Views, Information & Summary 3D Aerial Solutions LLC has collective experience over 20 years inunmanned aircraft flight operations for military and civilian use. 3D Aerial Solutions currently holds a valid private pilot certificate as well as a 333 Exemption (#11193) for fixed wing operations ofthe Sensefly Ebee platform. We understand that safety is paramount, butwe also knowthat integrating and operating in congested airspace along withmanned aircraft is possible without incident. 3D Aerial Solutions LLC was established November 2013. 3D Aerial Solutions LLC support public outreach and educationthrough the sponsorship ofthe Dayton Drone Users Group. As a public benefit 3D Aerial Solutions LLC will advance:

• Research into future safety guidelines for the use ofUAS, • Reduction in dangers by limiting the use oflarger rotorcraft or fixed wing aircraft, • Reducing carbon emissions, & • Advancement ofscience through advanced data collection 

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Pursuantto 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 CFR91.407 (a) (1); 14 CFR91.409 (a) (1) & (2) and 14 CFR91.417 (a) & (b) to operate commercially a small unmanned vehicle (55pounds or less) for the purpose ofaerial surveying, mapping and data collection; Remote sensing; Educational and research operations; 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 civil engineering: waterways and shipping, forestry, fishery protection, pollutioncontrol and air sampling and crop performance; Railroad and motorvehicle 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; Structure Inspection; Construction site inspections and monitoring; oil and gas pipeline inspection/patrolling and oil-field inspection; Real estate and marketing; Aerial event security, surveillance and crowd management and aerial imagery evidence for property insurance claims. Approval ofexemptions allowing commercial operations ofUAS in the listed industries will enhance safety by reducing risk. Conventional flight operations usingjet, piston or multi-engine powered aircraft occasionally operate atextremely low altitudes to complete some ofthe requested uses and in extreme proximityto people and structures. This presents associated risks as these vehicles weigh in excess of3,000 pounds and carry large amounts of jetA or other fuel. Such aircraft must fly to and from the mission location. In contrast, a UAS weighing fewer than 55 pounds, powered bybatteries, virtually eliminates all ofthe above risks given the UAS's reduced mass and lack ofcombustible fuel carried onboard. The UAS is carriedto the mission site. The UAS will carry no passengers or crew, therefore, the UAS will notexpose themto the risks associated with manned aircraft flights. The operation ofsmall UASs, weighing less than 55 pounds, conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supportingthe grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground but under 400 feet AGL, and within visual line ofsight ofthe 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 ofthe criteriaprovided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximityto airports and populated areas, operation within visual**~ine** ofsight,**n~tional** security and the significant public benefit as well as the positive economic Impacts -provide more than adequatejustification for the grant ofthe requested exemptions

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# ------------------- 3)> AERIAL allowing commercial operation ofapplicant's UAS. Granting 3D Aerial Solutions LLC the above exemptions will allow for the expansion ofUAS systems into the future, in a professional, safety conscious culture steeped inthe tradition ofAviation. 3D Aerial Solutions LLC respectfully requests that the FAA grant its exception without delay, The FAA bas the authority to issue the exemption soughtby 3D Aerial Solutions LLC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

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----- Bret R. 

### Give 3D Aerial Solutions LLC, President

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