LJCAI Section 333 Exemption Page 1 9/23/2015

September 1 0, 2015
Lawrence Chestnut

- C E O LJ C Aerial Imagery LLC

. 107 Bennett’s Creek Landing Road Suffolk, VA 23435 +1 ( 868) 767

- 8227 ljcai@ljcaerialimagery .com www.ljcaerialimagery.com

Mr. James Williams Manager, Flight Standards Service Unmanned Aircraft Sy stems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 U.S. Department of Transportation, Docket Operation West Building Ground Floor, Room w12

- 140 1200 New Jersey

Avenue, SE Washington, DC 20590 Re: Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial s ys tems (sUAS) for aerial data collection for US

- based and i nternational clients Dear Mr. Williams: LJ C Aerial Imagery

LLC (LJCAI ) r espectfull y requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) for the commercial use of small UA S s under Section 333 for aerial data collection

. LJ CAI recognize the leadership role the FAA play s in aeronautic regulations around the world . It is the company ’s goal to share the processes and regulations that has placed the FAA in this leadership role with countries throughout the Caribbean, Africa, Central and South America. Initiall y, LJ CAI will be conducting business in the United States , Trinidad & Tobago , and other Caribbean countries

. The aircrafts LJCAI will employ initially include: 1. DJIPhantom 3 (company own) 2. DJIInspire 1 (company own) 3. DJI Matrice 100 ( company in process of buying ) 4. SenseFl y eXom (new and future purchase ) 5. SenseFl y eBee RTK (new and future purchase)LJCAI Section 333 Exemption Page 2 9/23/2015

All data collection sUAVs that may be used in the future are listed in Appendix B

. **BACKGROUND ON LJC AERIAL IMAGERY LLC (LJCAI)** LJ CAI strives to be a leader in the use of drones as a service tool. Our Drone Smart Service® processes and methodology strive to introduce the use of drones within a my riad of areas. These areas include, but are not limited to: 1. **Telecom and Utility Infrastructure Inspections**  2. **Damage Assessment** 3. **Disaster Relief** 4. **Emergency Response Search and Rescue** 5. **Surveying and Mapping** 6. **Residential and Commercial Real Estate**  **S ervices**  7. **Entertainment and International Flight Training and Drone Registration** ( 8. **UAV Training and Drone Registration** *
 Like man y countries with a high count of drones and few regulations on the books to help manage the safety of the inhabitants, Trinidad & Tobago is looking to have all s UA S ’s in the country

registered. LJCAI looks help the government not only register all drones in the country

but also provide a training initiative as well. LJ CAI with provides turnkey solutions utilizing UAS to deliver specific, low risk, and cost effective collection of aerial data. Though we will work wi th local and international companies who are developing their own UAS departments, LJCAIwill work to help clients avoid the capital expense and operating risks of establishing their own drone programs. Working within the national (or in the case of The Republic of Trinidad & Tobago demands an anal yt ical approach to providing drone smart services®. LJ CAI believes in providing a fully integrated solution, rather than one based on individual components. Whether working with clients in the United States or the Caribbean, our business process requires the following:

 Clearly

identifying requirements
 Developing business case (s)
 D emonstrating the Return on Investment (ROI) to our clients from the utilization of s UASLJCAI Section 333 Exemption Page 3 9/23/2015

**Regulatory Provisions from which LJCAI seeks an Exemption**  LJ CAI believes it may

need an exemption from the following provisions to conduct the contemplated operations. In some instances, relief is needed because relief from another provision renders compliance with the regulation at hand infeasible. **333 Aircraft Exemption Status** 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b) **AUTHORITY FOR EXEMPTIONS** The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, 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 s ections §44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the national airspace sy stem without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:

 The UAS’ size, weight, speed and operational capability ;  Whether the UAS operates within the visual line of sight of the operator;
 Whether the UAS operates outside of highly populated areas and away from close proximity to airports. Reform Act 333(a). If the Secretary determines that a UAS “may operate safel y i n the national airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace sy stem.” Id. 333(c).LJCAI Section 333 Exemption Page 4 9/23/2015

**UAS AND OPERATIONAL DESCRIPTION** With the United States FAA (and international aeronautic co ntrolling entities) LJCAIwill seeks to operate commerciall y a variety of UAS weighing less than 55 pounds including payload in the United States for the purpose of acquiring aerial data collection . The Appendix attached to this exemption petition lists the aircraft that LJ CAI may use in the execution of its business

. LJ CAI requests that it be granted permission to operate those aircraft already approved in previous Section 333 exemption petitions. As the operator of these aircraft, LJ CAI is committed to the following conditions and limitations on its operations. LJ CAI understands that failure to comply will be grounds for the immediate suspension or rescission any exemption granted. 1. Operations are limited to the s UAS listed in the Appendix and those s UAS previously

approved by

the Secretary when weighing less than 55 pounds including payload. 2. Operations for the purpose of closed

- set motion picture and television filming are not contemplated. 3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed recommended b y the aircraft manufac turer. 4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in Command (PI C) at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C’s U.S. driver’s license. 6. All operations will utilize a visual observer (VO). The aircraft will be operated within the visual line of sight (VLOS) of the PI C and VO at all times. 7. All operating documents needed to operate the UAS and will be accessible during UAS operations and made available to the Administrator upon request. The operator will also present updated and revised documents if it petitions for extension or amendment. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations. 9. LJCAI is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.LJCAI Section 333 Exemption Page 5 9/23/2015

10. Prior to each flight, the PI C will conduct a pre - flight inspection and determine the UAS is in a condition for safe flight.
11. LJ CAI will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under thi s ex emption will comply with all manufacturer safety bulletins. 13. The PI C will hold a UAS flight training certificate, in some cases training directly from the aircraft manufacturer, and 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. 14. LJ CAI will not permit any PI C to operate unless the PI C demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated to acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). LJ CAI will operate flights for the purposes of training LJ CAI PI Cs and VOs (training, proficiency , and experience

- building) and determining the PI C’s ability to safel y operate the UAS. 15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).
16. The aircraft will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility D irectory

(AFD) or for airports not denoted with an ARP, the center of the airport sy mbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA. 17. The aircraft will 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 PI C. 18. If the UAS loses communications or loses its GPS signal, the aircraft will return to a pre - determined location. 19. The PI C will abort the flight in the event of unpredicted obstacles or emergencies. 20. The PI C will be prohibited from beginning a flight unless (considering wind and forecast w eather c onditions) there i s e nough availa ble p ower o r f

uel f or the aircraft to conduct the intended operation and to operate after that for at least five minutes or with the reserve power or fuel recommended b y the manufacturer if greater. 21. All operations shall be conducted in accordance with an ATO

- issued COA if the blanket COA does not cover the intended operation.LJCAI Section 333 Exemption Page 6 9/23/2015

22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification ! (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 23. Documents used by LJ CAI to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PI C at the Ground Control Station of the UAS any time the aircraft is operating. 24. The aircraft will remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may be operated by the PI C from a moving device or vehicle; however, specific requests will be made via subsequent COA. 26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the aircraft or debris in the event of an accident; or b. The owner/controller/operator of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made an assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 27. The PI C, VO, operator trainees or essential persons will not be considered nonparticipating persons under this exemption. 28. All operations conducted over private or controlled

- access property will be conducted with the permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UA S 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.LJCAI Section 333 Exemption Page 7 9/23/2015

**DESCRIPTION OF SPECIFIC REGULATIONS**  14 CFR Part 21, Subpart H: Airworthiness certificates Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required b y FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by LJ CAI, 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. The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the Refor m 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 UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS 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 operating with an airwo rthiness certificate without the restrictions and conditions proposed. 14 CFR 45.23(b): Marking of the aircraft This regulation requires that certain experimental, provisionally certified aircraft, or light

- sport category aircraft to be marked with lett ers between 2 inches and 6 inches high “limited”, “restricted,” “light

- sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness certificate, an exemption may

be needed as the UAS 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, 2 inch lettering may be impossible. LJCAIwill mark the UAS as practicable. 14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the UAS will not carry

a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a UAS flight

- training course. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved b y 14 CFR 61.113(a) and (b).LJCAI Section 333 Exemption Page 8 9/23/2015

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 LJCAI contemplates operating, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the operational restrictions put on the aircraft, an equivalent level of safety will be provid ed. 14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 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 on board, but becaus e there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the Operating Manuals at the ground control point where the pilot flying the UAS will have immediate access to it. 14 CFR 91.103: Preflight action This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An ex emption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and landing distances, and all other actions in the Operating Manuak and safety checklists. These actions will provide an equivalent level of safety. 14 CFR 91.109: Flight instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y func tioning dual controls. By

design, UAS do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety is provided b y the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio signals from the controller and b y the size and speed of the aircraft. 14 CFR 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will never operate at altitude higher than 400 AGL and all operations will occur during daylight hours under Visual Meteorological Conditions (VMC) only

. The equivalent level of safety will be achie ved given the size, weight and speed of the UAS as well as the location where it is operated. No flight will be taken without theLJCAI Section 333 Exemption Page 9 9/23/2015

permission of the property owner. Because advance notice to the propert y owner and an y onsite personnel, as well as the precautions outlined below, all affected individuals will be aware of the planned flight operations. Flight operations will be conducted at least 500 feet from all non

- participating persons (persons other than the pilot in command (PI C) or vi sual observer (VO)), vessels, vehicles and structures, unless operations do not present an undue hazard. The UAS will remain within visual line of sight of the PI C or VO. Flight operations will be conducted at least 5 miles from an airport. The PIC or VO will provide notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an airport. The FAA will have advance notice of all operations through the filing of notices

- to

airmen. Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed herein, an y risk associated with our operations is far less than those presentl y presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 14 CFR 91.121: Altimeter Settings This regulation requires each per son operating the 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 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 PIC confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of UAS during daylight hours in visual f light rules (VFR) conditions to continue until 90 percent of remaining battery

power or fuel reserves remain. LJCAIseeks the requested relief because without an exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of any aerial acquisition of data that LJ CAI proposes to conduct pursuant to this Petition. The technical specifications of the proposed UAS, their Operations Manuals, and LJ CAI’s proposed operati ng limitations, ensure that LJCAIwill safel y operate the selected aircraft during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.LJCAI Section 333 Exemption Page 10 9/23/2015

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety wi ll be achieved b y keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 CFR 91.405(a); 407(a)(1); 409(a)(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 sections and Part 43 appl y only to aircraft with an airworthiness certificate, these sectio ns will not apply to LJCAI . Maintenance will be accomplished pursuant to the User Guide or Operating Manual. An equivalent level of safety will be achieved because these UASs are limited in size and will carry a small payload and operate onl y in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that the UAS is in working order prior to initiating flight, perform required maintenan ce and keep a log of an y maintenance performed. Moreover, the PI C is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition to provide the equivalent level of safety. **PUBLIC INTEREST** Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances safety while reducing risk. Manned aircraft in certain application such as pipeline monitoring create a greater risk because the aircraft are much larger and carry an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. In addition, additional streams of aerial data will allow large commercial entities to make decisions about how to best deploy ground resources and ensure the safety and cost

- effectiveness of their operations.LJCAI Section 333 Exemption Page 11 9/23/2015

**EQUIVALENT LEVEL OF SAFETY** LJ CAI proposes that the exemption requested herein apply to civil 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 and proposed regulatory

structure. **PRIVACY** A ll flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they

will be made anony

mous. **NATIONAL SECURITY** G iven the small size of the UAS involved and the restricted environment within which they will operate, our petition presents no national security issue. **FEDERAL REGISTER SUMMARY** Docket No.: No. FAA

- 2015

- Petitioner: LJC A erial Imagery LLC Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of T itle 14, Code of the Federal Regulations (14 CFR). Description of Relief Sought: LJ CAI is seeking an exemption to conduct commercial acquisition of aerial data using unmanned aircraft sy stems. Based upon the foregoing, LJCAIrequests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform Act as requested herein to allow for commercial operations of UAS within the United States.LJCAI Section 333 Exemption Page 12 9/23/2015

**Support for Petition for Exemption** In accordance with the procedural requirements of 14 C.F.R. §11.81, LJ CAI provides the following information: **Contact Information:** Lawrence Chestnut, CEO LJ C Aerial Imagery

LLC Someplace , Wyoming 90291 ( 868) 767.8227 ljcai@ljcaerialimagery .com Sky pe: ljchetsnut1 **Regulatory Provisions from which LJCAI**  **seeks an Exemption** LJ CAI believes it may

need an exemption from the following provisions to conduct the contemplated operations. In some instances, relief is needed because relief from another provision renders compliance with the regulation at hand infeasible. 333 Aircraft Exemp tion Status 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b) LJ CAI believes an exemption is only needed from the above

- listed regulatory provisions. To the extent that the FAA believes that additional relief is required for LJ CAI to conduct the operations described here, we request an exemption from any such regulatory provisions as well. **The Extent of Requested Relief and the Reasons Relief is Needed Section 333 Aircraft Exemption Status:**  Sec ti o n 33 3 o f th e M ode r n i zati o n A c t autho ri ze s th e F AA t o exe mp t a irc raf t f ro m th e requ ire m ent fo r an a ir

w o rth i nes s ce rti f

i cat e base d o n a cons i de rati o n o f th e s i ze , w e i gh t , speed , operati ona l capab ility o f th e parti cu l ar UA S , a s w e l l a s it s p rox im ity t o a ir po rt s an d popu l at e d areas . An ana l ys i s o f thes e cr it er i a de m ons trat e s that th e s UA S operat e d w ithout an a ir w o rth i nes s certifi cat e i n th e area s an d unde r th e cond iti on s cont e mp l at e d b y LJ CAI w il l b e at l eas t a s safe , o r safer , than a conventi ona l a irc raf t ( f i xe d w i n g o r ro t o rc raf

t )LJCAI Section 333 Exemption Page 13 9/23/2015

ope r a ti n g w ith an a irw o rth i nes s ce rti f i cat e w ithout th e cond iti on s p ropose d i n th i s r eques t

. T h e s UA S i s l es s than 5 5 lbs

. fu ll y l oaded , carr i e s ne ithe r a p il o t no r passenger , an d opera t e s exc lus i ve l y w ith i n a secur e d ar ea . Un li k e o the r c i v i l a ir c r af t , ope rati on s unde r th i s ex e m p ti o n w il l b e ti ghtl y contro ll e d an d m on it o r e d b y th e ope r at o r an d obse r ve r . O pe rati on s w il l b e conduc t e d i n co mp li anc e w ith th e FAA an d w ith l oca l pub li c sa f e ty r equ ire m ent s t o p r ov i d e secur ity fo r th e are a o f operati o n a s i s no w don e w ith conventi ona l equ ip m ent , i nfras truc ture , br i dg e an d out bu il d i n g eva luati on . T hes e safe ty enhance m ent s prov i d e an expande d degre e o f safe ty t o th e i nspec t or s ove r conventi ona l operati ons . L as tl y , app li cati o n o f thes e sa m e c rit e ri a de m ons trat e s that the r e i s n o c r ed ib l e thr eat t o nati ona l security pose d b y th e s UAS , du e t o it s s i ze , spee d o f operati on , l ocati o n o f operati on , l ac k o f exp l os i v e m at er i a l s and i nab ility t o carry a subs t anti a l ex t e r na l l oad. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation 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 sUAS. In all cases, an anal ys is of the se criteria demonstrates that the UAS 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. 14 C.F.R. §61.113(a) and (b) **§61.113 Private pilot privileges and limitations: Pilot in command.**  (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a sUAV pilot certification may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compe nsation or hire, act as pilot in command of an aircraft. (b) A private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only

incidental to that business or emplo ym ent; and (2) The aircraft does not carry passengers or property

for compensation or hire. ***** LJ CAI anticipates initially using a cadre of specially trained staff to conduct the sUAS op erations. T hese individuals will not hold commercial pilot licenses . The sUAS will not carry property for compensation or hire since they will be used solel y to assist in evaluation of the infrastructure, equipment, right

- of

- way , assets, bridges, tunnels and out

- buildings in furtherance of LJ CAI ’s client’s primary busines s, the successfu l operation of a infrastructure. The sUAVs will also be used for Damage Assessment, Infrastructure Maintenance, Disaster Relief, and Emergency

Services Search and Rescue. T he employees’ operation of the sUAS will not be incidental to thei r employment with LJ CAI , and they will be compensated for such work. Without an exemption, the pilot would be required to hold a commercial pilot certificate underLJCAI Section 333 Exemption Page 14 9/23/2015

§61.133. However, the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole control of LJ CAI clients. Accordingl y, th e risk would be limited to LJ CAI personnel, who will be appropriatel y outfitted in safety gear, and LJ CAI client’s property

on the ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose addi tional cost on LJ CAI . Because the contemplated operations would not comply with §61.113(b)(1) and none of the other exceptions to paragraph (a) appl y, relief is needed from both paragraphs (a) and (b).LJCAI Section 333 Exemption Page 15 9/23/2015

14 C.F.R. 91.119(c) **§91.119 Minimum safe altitudes: General.**  Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: *** (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. ***** LJ CAI submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief i s required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficientl y distinct to be meaningful. Since operations at this altitude also pose a heightened risk of collision with another aircraft, safety can only be assured through the grant of an exemption. The anticipated rotorcraft operations should be adequatel y addressed by paragraph (d) (1). Additionally , relief should not be needed from paragraph (a) because an emergency landing of the aircra ft due to a power failure will not create an undue hazard to persons or property on the surface. As noted in the explanation of why an exemption will not adversely affect safety , LJ CAI clients has exclusive use of the land over which the sUAS will be operated, and public access is restricted. It also has exclusive use of significant portions of land adjacent to the infrastructure and structures that will be the objects of evaluation and anal ys is. LJ CAI ’s Clients tightl y control access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk of injury

is minimal. LJ CAI does not contemplate conducting op erations over congested areas, so relief is not requested from paragraph (b). 14 C.F.R. 91.121 **14 C.F.R. §91.121 Altimeter 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 departure.” ***** As the sUAS 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 Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. A ltitud e i nfo r m ati o n w il l b e p rov i de d t o th e s UA S p il o t v i a a d i g it a ll y encode d t e l e m e tri c dat a feed , wh i c h do wn li nk s fro m th e a i rcraf t t o a ground

- base d on - scree n d i sp l ay . T h i s a ltitud e i n f o r m ati o n w il l b e generat e d b y equ ip m ent i ns t a ll e d o n boar d th e a i rcraf t , us i ng G P S tri angu l ati on , o r d i g it a ll y encode d baro m e tri c a lti m e t e r , o r rad i o a lti m e t e r , o r an y co mb i nati o n the reo f

. P ri o r t o eac h fli ght , a zer o a ltitud e i n iti ati o n po i nt w il l b e es t ab li shed an d conf i rm e d fo r accurac y b y th e p il o t

.LJCAI Section 333 Exemption Page 16 9/23/2015

14 C.F.R. 91.151 **§91.151 Fuel requirements for flight in VFR conditions.**  (a) No person may

begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day , to fly after that for at least 30 minutes. (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended land ing and, assuming normal cruising speed, to fl y after that for at least 20 minutes. ***** Operating the sUAS in a pre

- defined area with less than 30 minutes of reserve fuel does not raise the ty pe of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it has to be flown to an alternate airport or circle the planned airport in the event of unanticipated conditions. LJ CAI does not intend to use the sUAS for point

- to

- point flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order to land. Rather, LJ CAI will operate the sUAS using pre

- planned flight paths (taking into account weather conditions) designed to allow the sUAS to fly to the point of intended landing. As such, there is no need for a time

- based excess fuel requirement. Rather it should be sufficient to require onl y as much additional excess flight capacity as necessary to safel y land the sUAS. We believe that a 25% battery

reserve is more than sufficient to meet this objective. 1 4 C

. F

. R

. 91

. 405 ( a ) , 91

. 407 ( a ) ( 1) , 1 4 C

. F

. R

. 91

. 409 ( a ) ( 1 ) & ( 2 ) an d 1 4 C

. F

. R

. 91

. 417 ( a ) & ( b ) **§91.405 Maintenance required.** Each owner or operator of an aircraft

– (a) 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; ***** **§91.407 Operation after maintenance, preventive maintenance, rebuilding, or**  **alteration.** (a) No person may

operate any

aircraft that has undergone maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service b y a person authorized under §43.7 of this chapter; ***** **§91.409 Inspections.** (a) Except a s provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ***** **§91.417 (a) & (b)** *****LJCAI Section 333 Exemption Page 17 9/23/2015

LJ CAI believes that an exemption from these three maintenance requirements is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to service inspections required b y §91.409(a). LJ CAI will maintain the aircraft as instructed in the owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft until it has reasonably determined that an y needed repairs have been made. However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate. Please do not hesitate to contact me at the phone number or via the e

- mail address provided above should you have an y questions or concerns. Respectfully

submitted,

Lawrence Chestnut CEO, ljc Aerial Imagery

llcLJCAI Section 333 Exemption Page 18 9/23/2015

**Appendix A** Summary for Federal Register Publication Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determine that publication is needed. Pe titioner: LJ C Aerial Imagery LLC . ( LJ CAI ) Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b) Description of Relief Sought: Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations over LJCAI Client’s owned or controlled land, solely during daylight hours, to assist in the safe evaluation and anal ys is of infrastructure and operations. In gen eral, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature of operations anticipated by LJ CAI requires that the sUAS be flown at relatively low altitudes. LJ CAI expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingl y, the risk of interference with other aircraft is minimal.LJCAI Section 333 Exemption Page 19 9/23/2015

**Appendix B**

1 3D Robotics Aero

- M 2 3D Robotics Iris 3 3D Robotics Iris+ 4 3D Robotics X8 5 3DRobotics Fixed Wing 6 3DRobotics Multirotor 7 3DRobotics Quadrotor 8 3DR Solo 9 3DR Spektre 10 3DRobotics Spektre Industrial Multi

- Rotor Aerial Vehicle 11 3D Robotics Solo 12 3DRobotics X8+ 13 3D Robotics X8

- M 14 3D Robotics Y6 15 DJIFlame Wheel F450 16 DJIFlame Wheel F550 17 DAx8 18 DJI Inspire 19 DJI Inspire 1 20 DJI Inspire 2 21 DJI M P330z 22 DJI Phantom 23 DJI Phantom 2+ 24 DJI Phantom 2 Vision 25 DJI Phantom 2 Vision+ 26 DJI Phantom Vision + 27 DJI Phantom 3 28 DJI Phantom FC40 29 DJI Spreading Wings S900 30 DJI Spreading Wings S1000 31 DJI Spreading Wings S1000+ 32 DJI S800 33 DJI S800 EVO 34 DJI T600 35 Draganflyer Guardian 36 Draganflyer X4ES 37 Draganflyer X4P 38 Draganflyer X6 39 Parrot Bebop droneLJCAI Section 333 Exemption Page 20 9/23/2015

40 Parrot PF 725100 Bebop Drone 14MP 41 Parrot Skycontroller 42 Patriot X4 43 Patriot X8 44 Precision Drone Pacesetter 45 PrecisionHawk 46 PrecisionHawk Hawkeye Mk

- III 47 PrecisionHawk Lancaster 48 Precision Lancaster MK3 49 SenseFly eBee 50 SenseFly eBee RTK 51 SenseFly eXom 52 Tarot FY690S Hexacopter 53 Tarot quadcopter 54 Tarot 680pro 55 Tarot 690 56 Tarot 900 57 Tarot 960 58 Tarot T

- 15 59 Tarot T15 C/F Folding Octocopter 60 Tarot T18 UAV 61 Tarot T690 62 Tarot T810 63 Tarot T960 64 VA03

- v1 65 VA04

- v1 66 VA07

- v1 67 Viking UAS Multicopter (VTOL) 68 Viking UAS FF

- X4/X8 69 VK

- Patriot X4/X8 70 Viking UAS Patriot X4/X8 Multirotor 71 Viking UAS X6 Model 800 72 Viking UAS Viking ONE 73 VK

- 450 74 Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 75 Viking VK

- FF

- X4 76 VK

- Ranger EX

- SAR Fixed Wing UAS 77 Vulcan frame controlled by a DJI A2 flight controller 78 Vulcan Mantis 79 Vulcan Octocopter 80 Vulcan RavenLJCAI Section 333 Exemption Page 21 9/23/2015

81 Vulcan UAVLJCAI Section 333 Exemption Page 22 9/23/2015