December

2, 20 15 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition of San Tan Traffic Consultants
for an Exemption Pursuant

to Section 333 of the FAA Modernization
and Reform Act of 2012 Director

: Flight Standards Service: Pursuant
to Section 333 of the FAA Modernization
and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part II, San Tan Traffic Consultants (San Tan) hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft"
or "VAS") for the purpose of conducting aerial photography, videography, inspection, mapping and data collection for accident reconstruction
for local municipalities. This petition for exemption

is made based on information outlined
in this Petition for Exemption, as well as the accompanying San Tan documents; I. PIC Flight Operations Manual and; 2 .Operations Manuals (Collectively

2 and 3 are referred
to as Documents

& Manuals") 3. User Guide and; 4. Flight ManuaJI (Collectively

3 and 4 are referred
to as "Manufacturer's Manuals") San Tan submits these supporting materials

as confidential documents pursuant
to 14 C

.F.R.
§ 11.35(b),
as the materials contain confidential commercial and/or proprietary information that San Tan has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available
to the public and are protected from release under the Freedom of Information Act, 5 U.S.C.

§ 552 et. seq. NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIAL AND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER. For your convenience, this Petition is organized
as follows: 1 •The tenn "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and, safety

/ service bulletins.U.S Department
of Transportation December

2, 2015 Page2
I. Description
of Petitioner II. Description

of Proposed Operations A. Aerial Videography, Photography, Inspection, Mapping and Data Collection III. Relevant Statutory Authority IV. San Tan's Proposed UAS Operations Meet the Requirements

of Section 333 of the Reform Act A .Approval

is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval

is Warranted Based onthe Operational Restrictions Set Forth in the Operations Manuals V. Regulations From Which Exemption

is Requested A
.14 C.F.R. Part 21, Subpart
H-Airworthiness Certificates and 14 C.F.R.

§ 91.203(a)(1) B.14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D .14 C.F.R.

§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections E.14 C.F.R. Part 61,14 C.F.R.

§ 61.3, 14 C.F.R.

§ 61.113

:Private Pilot Privileges and Limitations F.14 C.F.R.

§ 91.7(a): Civil Aircraft Airworthiness G. 14 C.F.R.

§ 91.9(b )(2): Civil Aircraft Flight Manual
in the Aircraft and 14 C.F.R.

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration H.14 C.F.R.

§ 91.1 03: Preflight Action I. 14 C.F.R.

§ 91.109(a): Flight Instruction J.14 C.F.R.

§ 91.119(c): Minimum Safe Altitudes K. 14 C.F.R.

§ 91.121: Altimeter Settings L. 14 C.F.R

.§ 91.151(a): Fuel Requirements
for Flight in VFR Conditions VI. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX. Federal Register Summary X. Conclusion I. DESCRIPTION
OF PETITIONER San Tan is based in Chandler, AZ and provides aerial videography, photography, inspection, mapping and data collection

totheir client base. The Company's Principal and Chief Pilot Joseph
V
.Catone has been flying UAV Quadcopters

asa hobby for morethan three yearsU.S Department ofTransportation December

2, 2015 Page3 without incident, logging thousands of hours flying. Upon the grant of the 333 Exemption the Company's business will continue
to specialize
in photography, videography, inspection, mapping and data collection for accident reconstruction

to be used by local municipalities and other interested parties. San Tan's staff are well trained and experienced

in providing support
as visual observers ("VO") for the pilot in command ("PIC")
in addition to any other needed on site assistance. All of the equipment owned by San Tan is of the highest quality gear and has been able to provide these services safely and without any claims or incident. San Tan's goal is to advise the perspective client that San Tan is following
all the applicable state and federal rules to ensure the safety of the public while providing the client with
a competitive and cost effective product. San Tan seeks an exemption

to allow for photography, videography, mapping, inspection and data collection and other related media products

. The contact information
for Petitioner

is as follows: Joseph V. Catone San Tan Traffic Consultants 975 E. Riggs Rd., Ste. 12-460 Chandler, AZ 85249 Phone

: 602.999.2125 Email

: jcatone@santanrecon.com II. DESCRIPTION
OF PROPOSED OPERATION San Tan seeks an exemption pursuant
to Section 333 of the Reform Act to operate the Blade 350 QX2 AP; Blade Chroma; and DJI Inspire; (referred
to DB-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions on private property or approved location where San Tan has received verifiable permission

to operate from the landowner, controller
or authorized representative. The proposed UAS operations will be conducted

in accordance with the conditions and limitations
of this Petition for Exemption and San Tan's Operations Manuals. As detailed
in San Tan's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-ofsight ("VLOS") of the operator,

in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, San Tan's Operations Manuals incorporate redundant safeguards
to assure the aircraft does not travel outside the controlled area of UAS operations, including GPS "geo-fencing" technologies. A. Aerial Videography, Photography, Inspection, Mapping and Data Collection San Tan seeks to use small STT -UAS for the purpose of conducting aerial photography, videography, cinematography, inspection and mapping for the film, television, real estate, and web industries. San Tan has purposefully tailored its operations

to meet the requirements established
by the FAA in prior grants of exemption authorizing commercial use ofUAS
in the relevant industries, including:U

.S Department
of Transportation December

2, 2015 Page4

•Astraeus Aerial (Exemption No.11 062) •Aerial MOB, LLC (Exemption No.11 066) •Pictorvision, Inc. (Exemption No

.11 067) •HeliVideo Productions, LLC (Exemption No.11 065) • Snaproll Media, LLC (Exemption No.11 063) •RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064) • Flying-Cam, LLC (Exemption No.11 080) •Aerocine, LLC (Exemption No. 11150) •Team 5, LLC (Exemption No. 11158) •Alan D
.Purwin (Exemption No. 11161) •HelinetAviation Services, LLC (Exemption No. 11160) •Picture Factory, Inc. (Exemption No

.11178) •Trudeau, Realtor® (Exemption No. 11138) •Alon Sicherman (Exemption No. 11728) •Sokoler Medly (Exemption No. 11341) All UAS photography, videography, inspection mapping and data collection operations will occuron private propertyor approved location
in acontrolled area awayfrom spectatorsand personsnotinvolved
in the recording process.
In addition, the filming will be conducted between dawn and dusk toensuremaximum safety for the public and those involved
in the manipulation and operation of the UAS; VFR conditions,

ataltitudes below400' above ground level ("AGL"). As setforth below, San Tan's operations provide an equivalent level of safety which
is superior to performing the samework using conventional fixed-wing aircraft or helicopters. Small UAS recording operations

is also safer than traditional manned aircraft performing the samefunction

.Videographer-inspectors

also frequently need toclimb roof tops, ladders, trees, orotherwise perform elevated work, which exposesthem tothe risk of dangerous falls, electrocution

orother work related injuries.
In addition, depending
onthe natureof the video needed and inspection, proximity

to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves

arisk of exposure
tohazardous conditions. The useofSTT-UAS mitigates these hazards and is ultimately

amuch safer and costefficient method of performing these and mostother typesof recording operations. Moreover, conventional operations using rotorcraft and fixed-wing aircraft
in low level operations presentrisks associated with vehicles weighing tensof thousands of pounds (including payload) and carrying large amountsof fuel which inherently presents significant fire hazards aswell as exposure
toother chemical contaminates

.It is important
tonotethe useof small UAS in this areawill not only be safer and morecosteffective
tothe perspective useror purchaser of the service, but the quality and expanseof acquired information will be far more robust given the low costassociated with its acquisition and other potential consumers
an inexpensive product. UAS video production

is morereliable, and allows for the collection, dissemination, and storage of visual and other sensorydata with greater precision and duration
ata verylow cost.Small UAS will also be capable of accessing and inspecting areasthat would otherwise be inaccessible or highly dangerous using conventional aircraft orother inspection methods.U.S Department ofTransportation December

2, 2015 PageS III. RELEVANT STATUTORY AUTHORITY This Petition for Exemption

is submitted pursuant

to Section 333(a) through (c) of the FAA Modernization and Reform Act of 20 I 2 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration
of civil unmanned aircraft systems into the national airspace system." Pursuant
to Section 333 ofthe Reform Act, the FAA Administrator

is to permit unmanned aircraft systems to operate
in the National Airspace Systems ("NAS") where
it is safe to do so based on the following considerations: • The UAS's size, weight, speed and operational capability; • Operation of the UAS in close proximity

to airports and populated areas

; and • Operation of the UAS within the visual line of sight of the operator

. Additionally,
the FAA Administrator
has general authority
to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides

a requested exemption

is in the public interest. See 49 U

.S.C

.§ 106(f) (defining the authority of the Administrator);

49 U.S.C.

§ 4470l(f) (permitting exemptions from§§ 44701(a), (b) and §§ 44702

- 44716, et seq.). A party requesting
an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide

a level of safety at least equal to the existing rules). See 14 C.F.R.

§ 11

.8 I (petitions for exemption). IV. SAN TAN'S PROPOSED STT-UAS OPERATIONS MEETTHE REQUIREMENTS

OF SECTION 333 OF THE REFORM ACT The small SIT-U AS operations proposed by San Tan as noted above in this Petition for Exemption qualify for expedited approval pursuant
to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied

. A. Approval

is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability A Grant of Exemption

is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability. • The SIT-U AS utilized by San Tan has been approved for use in prior Section 333 Grants of Exemption from the FAA

. 2 • The SIT-U AS weighs less than 55 pounds, including payload • The SIT-U AS will not be flown at a ground speed in excess of 50 knots. The exemption holder may use either groundspeed

or calibrated airspeed
to determine compliance with the 50 knot speed restriction. 2 See e .g .,Gmnt of Exemption

to Shotover Camem Systems L.P

.(Exemption No. 11159)

; Gmnt of Exemption

to VDOS Global, LLC (Exemption No. 11112)

; Gmnt of Exemption

to LowCountryRC, Corp

.(Exemption No. 11184); Gmnt of Exemption

to Alan Purwin (Exemption No. 11161 ); Gmnt of Exemption

to Helinet Aviation Services (Exemption No

.11160); Gmnt of Exemption

to Total Safety U.S., Inc. (Exemption No. 11156)

..U.S Department
of Transportation December

2, 2015 Page6

•Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter,
or anycombination thereof. This information will be transmitted

tothe pilot via telemetric data feed

. •The STT-UAS will have systemredundancies and independent functionality

to ensurethe overall safety and predictability

of the system.If connection

tothe remote control or ground control station
is lost, failsafe systemswill permit the UAS to returntoa predetermined location and safely land without injury or damage

. •The radio frequencies used for operations and control of the STT-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the SITUAS is 2.4 GHz frequency bands. If the same operations wereconducted using

a helicopter, the aircraft's take-off weight would likely exceed 6,000 pounds depending on payload

.The difference

in weight between the SITUAS and
a helicopter significantly reduces the potential harm tothe participating and nonparticipating individuals and/or surrounding property
in the eventof anunintended accident or incident.
In addition, the risk tothe onboard pilot and camera operator

is eliminated. B. Approval

is Warranted Based onthe Operational Restrictions Set Forth in San Tan's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected SIT-U AS will contain all the procedures and limitations necessary
to safely and successfully perform the operations specified
in this Petition for Exemption.
To assist the FAA in making

a safety assessment
of San Tan's proposed operations, below
is a summaryof operational limitations and conditions that San Tan will adhere to,and which will ensurean equivalent
or higher level of safety to operations conducted under current regulatory guidelines

: 1. The STT-UAS weighs less than55 pounds, with payload. 2. All operations shall be conducted over private orcontrolled-access propertywith verifiable permission from the land owner/controller

orauthorized representative. Permission from land owner/controller

orauthorized representative will be obtained for each scheduled flight prior to operation. 3. All UAS operated under the Grant of Exemption will be identified by serial number, registered
in accordance with 14 CFR part4 7, and have identification (N-Number) markings

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 4. Minimum crewfor each flight operation will consist of a pilot, who willbe Pilot

-in Command ("PIC") of the SIT-UAS, and oneormoreVisual Observers ("Observer") as necessary
to safely conduct the mission.U.S Department
of Transportation December

2, 2015 Page7
5. PICs shall possesseither

a private, recreational,

or sport pilot certificate. The PIC mustalso hold
acurrentFAA airman medical certificate
oravalid U.S. driver's license issued by astate,the District of Columbia, Puerto Rico

,a territory,

a possession,

orthe Federal government.The PIC will also meetthe flight review requirements specified
in 14 C.F.R 61.56 in anaircraft in which the PIC is rated on his orher pilot certificate. 6.The STT-UAS shall be operated within VLOS of the PIC and Observer

atall times. The PIC mustusehuman vision unaided by anydevice other than corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able tocommunicate verbally
atall times. 8. Electronic messaging
or texting will notbe pennitted during flight operations. 9 .The additional requirements identified

in the Grant of Exemption shall beadded to the San Tan's Operations Manuals. The Operations Manuals will bemaintained and made available

tothe Administrator upon request.
If a discrepancy exists between the conditions and limitations

in the Grant of Exemption and San Tan's Operations Manuals, the conditions and limitations

in the Grant of Exemption shall take precedence and mustbe followed. Otherwise, San Tan shall follow the procedures outlined
in their Operations Manuals

. 10. San Tan may update orrevise its Operations Manuals. Revisions will betracked and a revised copyof the Manual will be provided

tothe Administrator upon request.San Tan will also presentan updated and revised Operations Manuals
if it petitions for extension
oramendment

toits Grant of Exemption.

If an update orrevision would affect the basis uponwhich the FAA grantsthe exemption

,San Tan will seek an amendment

toits Grant of Exemption. San Tan will contactthe FAA's UAS Integration Office (AFS-80)
if questions arise regarding updates orrevisions
tothe operating documents. 11. San Tan Operations Manuals and its Grant of Exemption will be available
tothe PIC atthe ground control station anytime the STT-UAS

is operating. 12
.The PIC is prohibited from beginning

aSTT-UAS flight unless (considering wind and forecast weather conditions) there is enough powerto fly tothe first intended point of landing, and assuming normal cruising speed, to fly after that for atleast

1 0 minutes. 13. Maximum total flight time for each operational flight using the STT-UAS will be limited to40 minutes orthe amountof time the UAS canbe flown and still maintain

a reserve battery powerof noless than 25%

,whichever occursfirst. 14. Flights will be operated
atanaltitude of nomorethan 400 feet AGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA

.In the eventthe structure being inspected exceeds 400 feetU.S Department
of Transportation December
2, 2015 Page8 AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted

at least 500 feet from all nonparticipating persons. (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection.

If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft
is operated near vessels, vehicles or structures where the owner/controller

of such vessels, vehicles or structures has granted permission and the PIC has made

a safety assessment

of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119( a). 16. The STT-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from

a cloud or when visibility

is less than
3 statute miles from the PIC. 17
.The SIT-U AS may not operate within

5 nm of an airport reference point as denoted on a current FAA-published aeronautical chart unless

a letter of agreement with that airport's management

is obtained, and the operation

is conducted

in accordance with a NOT AM as required by the San Tan COA. The letter of agreement with the airport management will be made available
to the Administrator upon request. 18
.Prior to each flight the PIC shall inspect the STT-UAS

to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered
in the relevant sections of the operating documents

as well as equipment updates. The PIC shall not operate any STT-UAS

if the inspection reveals

a condition that affects the safe operation of the STT-UAS until the necessary maintenance has been performed and the STT-UAS

is found to be in a condition for safe flight. The ground control station shall be included
in the preflight inspection. All maintenance and alternations must be properly documented

in the VAS

' s records as required by San Tan's Operations Manuals. 19. San Tan will timely carry out its maintenance, inspections, and record keeping requirements

in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the STT-UAS records, including total time in service, description
of work accomplished, date completed and the signature of the authorized person returning the STT-UAS

to service.U.S Department
of Transportation December

2, 2015 Page9 20

.Any STT-UAS that has undergone maintenance

or alterations that affect the UAS operation
or flight characteristics (e.g., replacement
of a flight critical component) must timely undergo

a functional test flight in accordance with San Tan's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and STT-UAS record entry shall be included
in the San Tan's Operations Manuals. 21. The SIT-U AS will be operated and maintained according

to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22

.Prior to the operation,

a Mission Packet will be created
in accordance with the requirements
on San Tan's Operations Manuals. 23. San Tan will obtain an Air Traffic Organization

( " ATO") issued Certificate
of Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of Exemption

.A NOTAM will be issued as required by the COA. All operations will be conducted

in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25

.If the STT-UAS loses communication with the PIC, it will have the capability

to safely return to a pre-determined location within the operational area and land safely

. 26. Contingency plans will be in place to safely terminate flight ifthere
is a loss of communication between the PIC and the Observer

. 27

.The STT-UAS will have the capability

to safely abort flight in the case ofunpredicted obstacles
or emergencies. 28. PICs and Observers will have at least
a current Class III Medical Certificate
or a valid and current state driver's license issued within the United States. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR
§ 61.51 (b), a minimum of 200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least

I 0 hours logged as a UAS pilot with
a similar STT-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR
§ 61.51(b),

a minimum of hours pursuant
to 54 CFR
§ 61.5I(b) as UAS pilot operating the make and model ofSTT-UAS

to be utilized for operations under the exemption and three take-offs and three landing
inU.S Department
of Transportation December

2, 2015 Page 10 the preceding 90 days. 31. Operations shall occur during daytime VFR Meteorological Conditions; flights under special visual flight rules ("SVFR") shall notbe conducted. 32. The STT-UAS shall remain clear and yield the right of waytoall other manned operations and activities
atall times (including, but notlimited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.)

. 33

.STT-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited. 34. The UAS will notbe operated from anelevated platform unless designed and engineered specifically
for such purposesand be in compliance with the general restrictions imposed by the applicable regulations. Additionally

noPIC will provide any film-flight operations while in motion from atop anyelevated platform vehicle or device

. 35. Before conducting operations, the radio frequency spectrumused for operation and control of the STT-UAS will comply with the Federal Communications Commission (FCC) orother appropriate government oversight agency requirements. V. REGULATIONS FROM WHICH EXEMPTION

IS REQUESTED The Federal Aviation Act expressly grantsthe FAA the authority
toissue exemptions. This statutory authority,
by its terms,includes exempting civil aircraft, asthe termis defined under§ 40101 oftheAct, including UASs, from its safety regulations and minimum standards when the Administrator decides

a requested exemption

is in the public interest.

3 San Tan seeks an exemption from several interrelated provisions
of Title 14 of the Code of Federal Regulations ("14 C

.F.R") Parts 21, 45, 61 and 91 for purposesof conducting the requested operations using STT-UAS platforms noted above. Listed below are:(I) the specific sections of 14 C.F.R for which exemption

is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure

alevel of safety better than or equal tothe rules from which exemption

is sought.

4 UNMANNED AIRCRAFf SYSTEM A. 14 C.F.R. Part 21, Subpart
H-Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) 3 49 U

.S.C

.§ 4470

I (f) (authorizing the grantof exemptions from requirements
of regulations prescribed pursuant
to Sections 4470

I (a) and (b) and Sections 44702- 44716)

. 4 14 C

.F.R § 11.81(e}, which requires

a petition for exemption
toinclude: The reasons why granting the exemption would not adversely affect safety, orhow the exemption would provide

alevel of safety atleast equal tothat provided by the rule from which youseek exemption.U

.S Department
of Transportation December

2, 2015 Page11 The FAA has stated that no exemption

is needed from this section if a finding
is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared

to aircraft normally used for the same application. These criteria aremetand in point of fact exceeded, and therefore no exemption

is needed

. 5 If, however, the FAA determines that there aresomecharacteristics

of the chosen UAS that fail tomeetthe requirements
of the Reform Act, an exemption

is requested. Equiva/e11t Level of Safety San Tan

' suseof the STI-UAS

is safe when taking into accountits size, weight, speed, and operational capability. As setforth in the description
of proposed operations

in Section IV(A), the STI-UAS weighs less than 55 pounds, including payload and will notbe flown ata ground speed in excessof 50 knots. The SIT-U AS is also equipped with safety features which will allow Petitioner

to operatethe SIT-U AS safely after experiencing certain in-flight contingencies orfailures asnoted below.6 7 Additionally,
the SIT-U AS carries neither pilots nor passengers,carries no explosive materials orflammable liquid fuels, orother elements identified by Homeland Security
as being prohibitive and operate exclusively within the parametersstated in San Tan's Operations Manuals. Operations conducted under this exemption will be closely controlled and monitored
by the PIC operatorand will be conducted

in compliance with local public safety requirements,

to provide security for the areaof operation. San Tan will also provide the FAA with advance notice of all operations via NOTAMs

as required by the applicable COA. In all cases, operation of the SIT5 See Grant of Exemption No. 11062 toAstraeus Aerial (FAA-2014-0352

at pgs.13-14, 22)

. 6 See e .g.,Grant of Exemption No. 11184 toLow Country RC

,Corp

.(FAA-2014-0803

at pg

.3): "The [OJ! SIOOO] has the capability
to operate safely after experiencing certain in-flight contingencies

orfailures and usesanautopilot systemtomaintain UAS stability and control. The UAS is also able to respond
toaloss of global positioning system (GPS) oralost-link eventwith
a pre-coordinated, predictable, automated flight maneuver,and manual flight control functionality

asa backup. These safety features provide an equivalent level of safety compared
toamanned aircraft performing

asimilar operation." 7 See e.g

.,Grant of Exemption No

.11184 toVDOS Global, LLC. (FAA-2014-0382

at pgs.4-5): "The STT-UAS can be operated entirely by atouch-screen

,map-based interface. This meansthe operator only needs tocommand the systemwhere to go,and the systemdoes all the flying for the operator.The STT-UAS canbe operated
in both semi and fully autonomous flight modes, with the operator simply clicking ona maptocreate

a pre-planned flight path for a flight. In addition, the operatorcancreateno fly zonesormaximum flight rangesand altitudes sothe system cannotenterareasdeemed unsafe or unnecessary

to fly over.The petitioner statesfurther that the UAS has built-in intelligent fault handling which allows the STT-UAS

todetect

a systemfault while in the air and automatically

fly back toits takeoff location and land. Faults that canbe detected include: loss of communication; exceeding pre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, making the system easyto navigate

.At any point if the operator

is not explicitly commanding
the systemto move,the system automatically holds its GPS position. The flight control system employs not only G PS positioning but a variety of sensors including sonar, barometric pressure

,temperature,wind speed and others toensure stability so long aswind thresholds arenot exceeded. Also

a flight termination link

-to prevent

a 'fly away' orother potentially dangerous situation

-is available
tothe operator

."U.S Department
of Transportation December

2, 2015 Page12 UAS under the proposed conditions will be atleast assafe as,orsafer than, conventional rotorcraft operating with anairworthiness certificate. Lastly, the STT-UAS do notneed
ameans tocommunicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who arenotonboard the STT-UAS.

8 In addition

,nosense-and-avoid technology

is necessaryfor the STT-UAS because they willbe operated
atall times in VFR conditions and within VLOS of the PIC and Operator.

9 B.14 C.F.R. Part 27 Ainvorthiness Standards: Normal Category Rotorcraft Title 14 C

.F.R. Part 27 setsforth the procedural requirements
for airworthiness certification
of normal categoryrotorcraft. To the extentthat San Tan's small STT-UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the samereasonsidentified

in the requestfor exemption from 14 C.F.R. R. Part 21, Subpart H, supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements San Tan seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). •14 C.F.R.

§ 91. 9( c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate

aU.S

.-registered civil aircraft unless that aircraft is identified
in accordance with Part 45 of this chapter. •14 C.F.R.

§ 45.23(b), Markings of the Aircraft, states: When marks include only the Roman capital letter "N" and the registration number
is displayed onlimited, restricted or light-sport categoryaircraft or experimental

or provisionally certificated aircraft, the operatormust also display onthat aircraft neareach entrance
tothe cabin, cockpit, or pilot station,
in letters notless than 2 inches normorethan
6 inches high, the words "limited," "restricted," "light-sport, "experimental,"

or "provisional,"

as applicable. •14 C.F.R.

§ 45.27(a), Rotorcraft, states

: Each operatorof arotorcraft must display onthat rotorcraft horizontally onboth surfaces of the cabin, fuselage, boom

,ortail the marks required by § 45.23

. 8 See Grant of Exemption No. 11062 toAstraeusAerial (FAA-2014-0352

at pg.13)

.U.S Department
of Transportation December

2, 2015 Page 13 In a previous Grant of Exemption, the FAA determined that exemption from these requirements waswarranted provided that the aircraft "have identification (N-Number) markings

in accordance with 14 C.F.R Part 45, Subpart
C if the markings areas large as practicable

. "10 Equivale11t Level of Safety All STT-UAS flown by San Tan will bear N-number markings that areas large as practicable

in accordance with 14 C.F.R. Part 45, Subpart C.11 D.14 C.F.R.

§ 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections San Tan seeks an exemption from the maintenance inspection requirements contained
in 14 C.F.R.

§ 91.405(a), 91.407(a) (1), 91.409(a)(2}; 91.417(a} and (b). These regulations specify maintenance and inspection standards
in reference
to14 C.F.R. Part 43. See, e.g.,14 C.F.R.

§ 91.405(a} (stating that each owneror operatorof anaircraft "[s]hall have the aircraft inspected as prescribed

in subpart
E of this partand shall between required inspections

...have discrepancies repaired as prescribed
in part43 of this chapter"}. An exemption from these regulations

is needed because Part ./3 and these sections only apply Ia aircraft with anairworthiness certificate, which the UAS platforms

Iabe operated under this gran/ of exemption will nothave. (Emphasis added) Equivale11t Level of Safety An equivalent level of safety will be achieved orexceeded because maintenance and inspections will be timely performed

in accordance with the Manufacturer's Manual and any required manufacturer Safety orService Bulletins. Further, as required by San Tan's Operations Manuals, the PIC will conduct

a pre-flight inspection
of the STT-UAS and all associated equipment

to accountfor all discrepancies and/or inoperable components.Maintenance will be performed and verified
toaddress anyconditions potentially affecting safe operation of the SIT-UAS and no flights will occurunless, and until, all flight critical components
of the SIT-UAS have been found tobe airworthy and in acondition safe for operation

.A functional test flight will be conducted following the replacement
of any flight-critical components.
As required by San Tan's Operations Manuals, the PIC who conducts the functional test flight will make an entryin the SIT-UAS aircraft records of the flight. San Tan's Operations Manual also includes requirements

tofollow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection

,and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures

& airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, San Tan's Operations Manuals also include procedures

todocument and maintain arecord of the SIT-U AS's maintenance, preventative maintenance, alterations, statusof replacement /overhaul component parts,and the total time in service of the SIT-U AS used under 10
.FAA Docket No

.FAA-2014-0352. II.See

,e.g

.,FAA Docket No

.FAA-2014-0352,

at14.U.S Department
of Transportation December

2, 2015 Page 14 this Grant of Exemption. As awhole, the maintenance and inspection procedures required
in San Tan's Operations Manuals ensurethat an equivalent
or higher level of safety will be achieved. PILOT-IN-COMMAND

OF THE UAS E.14 C.F.R.

§ 61.113: Private Pilot Privileges and Limitations San Tan seeks exemption from 14 CFR
§ 61.113, which restricts private pilot certificate holders from flying aircraft for compensation

orhire

,and would also require

asecond class medical certificate

.The purposeof Part 61 is toensurethat the skill and competency
of anyPIC matches the airspace
in which the PIC will be operating,
aswell as requiring certifications

if the private pilot is carrying passengers
or cargofor hire. In this case,while the SIT

-U AS will be operated as partof acommercial operation, they carryneither passengersnor cargo.In the Grant of Exemption

toAstraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside of controlled airspace did notwarrantthe additional costand restrictions attendant with requiring the PIC tohave
aCommercial Pilot Certificate and Class III Medical Certificate

. 12 The fulfillment
of the additional requirements
for a private pilot tobecome qualified
asacommercial pilot would notlead to anyadditional safety benefits when UAS operations areinvolved. Equivale11t Level of Safety The restrictions San Tan has placed onits SIT-U AS operations meetorexceed the restrictions similarly imposed onAstraeus Aerial. San Tan will operateon private propertyor approved location awayfrom personsand propertynotinvolved
in the operation. San Tan will also obtain anATO issued COA prior to conducting any operations under this Grant of Exemption. All operations will be conducted

in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

A NOT AM will also be issued as required by the applicable COA

. In addition tothese flight restrictions, San Tan will further ensuresafe operation by requiring that anyPIC be thoroughly versed not only in airspace and communication issues pertaining
toall aircraft operatorsbut also in the unique aspectsof SIT-U AS flight. As setforth in the Operations Manuals, pilots will have experience not only in STT-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted
to participate
in commercial flights onbehalf of San Tan. The pilot qualification

, training

,and currency requirements

in the Operations Manuals ensurethat San Tan pilots are competentand proficient
in the STT-UAS they are operating. San Tan's training and qualification requirements
areconsistent with those contained
in prior FAA Section 333 Grants of Exemption, and will provide

a higher level of competencyand proficiency for its pilots and will ensureat least an equivalent level of safety tothe public. OPERATING PARAMETERS
OF THE UAS F.14 C.F.R.

§ 91.7(a): CivilAircraftAinvorthiness 12 Ex e mption No. 11062 (FAA Docket No

.FAA

-2014

-0352).U.S Department
of Transportation December

2, 2015 Page 15 Inasmuch
asthere will be noairworthiness certificate issued for the UAS, San Tan seeks an exemption from 14 C.F.R.

§ 91.7(a), which requires that
acivil aircraft be in airworthy condition tobe operated. The FAA has stated that no exemption

is required for 14 C

.F
.R. § 91.7(a) tothe extentthat the requirements
of Part21 arewaived orfound inapplicable.

13 Accordingly, Petitioner requeststhat the requirements for§ 91.7(a) be treated in accordance with Section V(A), supra. G. 14 C.F.R.

§ 91.9(b)(2): Civil Aircraft Flight Manual
in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration Title 14 C.F.R.

§ 91.9(b) (2) and§ 91.203(a) and (b) require the operator
to carryairworthiness documents and other aircraft manuals onboard the aircraft. Pursuant
to14 C.F.R.

§ 91.9(b) (2): (b) No person may operate

a U.S.-registered civil aircraft

- (2) For which an Airplane orRotorcraft Flight Manual
is required by § 21.5 of this chapter, unless there is available
in the aircraft

acurrent approved Airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or anycombination thereof. Pursuant
to14 C.F.R.

§ 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate

acivil aircraft unless
it has within
it the following: ( 1) An appropriate and currentairworthiness certificate
... (b) No person may operate

acivil aircraft unless the airworthiness certificate required by paragraph (a) of this section ora special flight authorization issued under
§ 91.715
is displayed

atthe cabin or cockpit entrancesothat it is legible to passengers
orcrew. Given the small size and configuration

of the SIT-UAS,

it would be impossible

to keep airworthiness documents and other aircraft manuals onboard the STT-UAS because there is simply noroomand the SIT-U AS has nocabin or cockpit. As a wayto comply with the code San Tan will maintain the documents with the PIC and make them available for inspection. Eq11ivalellt Level of Safety In anFAA Office of Chief Counsel's Opinion dated August
8, 20 14, and prepared by Dean E. Griffith, Attorney, AGC-220,

it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is metif the pilot of the unmanned aircraft has accesstothe UAS flight manual, registration certificate, and other required documents from the ground control station 1 3See
Id. atI 3- I 4, 22.U.S Department
of Transportation December

2, 2015 Page 16 from which he or she is operating the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore,
an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents

at the ground control station from which he or she is piloting the UAS. H. 14 C.F.R.

§ 91.103: Preflight Action San Tan seeks an exemption from 14 C.F.R

.§ 91

.103, which requires

a PIC to become familiar with specific information before each flight, including information contained

in the FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary
to safely conduct the flight, an exemption

is requested
to the extent that an FAAapproved Flight Manual
is required. Eq11ivale11t Level of Safety An equivalent level of safety will be provided by following the San Tan's Operations Manuals and the Manufacturer's Manual. The PIC will perform

a series of checklists designed
to identify any defects or inoperable components

in accordance with the San Tan's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures

.The PIC will also be required
to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency landing areas-before initiation of flight. San Tan's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible
to the PIC at all times while operating the UAS. I. 14 C.F.R.

§ 91.109(a): Flight Instruction San Tan seeks an exemption from 14 C.F.R

.§ 91.1 09(a), which provides
in pertinent part that "[n]o person may operate

a civil aircraft (except

a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control
is accomplished through the use of a device that communicates with the aircraft via radio communications. Accordingly,

an exemption will be required for the flight instruction requirements

of 14 C.F.R.

§ 91.109(a). Eq11ivale11t Level of Safety Given the size and speed of the UASs that San Tan intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required by the San Tan's Operations Manuals, all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight instruction. Moreover,
as required by the San Tan's Operations Manuals, all flight training will be conducted in controlled and sterile environment.
As a whole, the safety procedures provided for in San 14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No

.FAA-20 14-0352
at 16-18.U.S Department
of Transportation December

2, 2015 Page 17 Tan's Operations Manuals ensurethat the proposed UAS operations provide an equivalent
or higher level of safety than that provided by the flight instruction regulations. J. 14 C.F.R.

§ 91.119(c): Minimum Safe Altitudes San Tan requestsan exemption from the minimum safe altitude requirements
of 14 C.F.R.

§ 91.119(

c)Y Section 91.119 prescribes the minimum safe altitudes under which aircraft maynot operate, including 500 feet above the surface and awayfrom any person,vessel, vehicle, or structure
in non-congested areas.See 14 C.F.R.

§ 91

.119( c). Section 91.119( d) allows for a helicopter

to operateatless than those minimum altitudes when it canbe operated "without hazard to personsor propertyonthe surface," provided that "each person operating the helicopter complies with anyroutesoraltitudes specifically prescribed for helicopters
by the FAA." An exemption

is required because the proposed STT-UAS operation will normally need tooccur below 400 feet AGL. In circumstances where the STT-UAS

is used to inspect

astructurewhose height exceeds 400 feet AGL, the STT-UAS will notbe operated morethan 100 feet above the highest point onthe structure,and within 50 feet horizontally
of the structure. Additionally, due the natureof the proposed operations, the Pilot and/or Observers(s) mayneed tobe less than 500 feet awayfrom the STT-UAS. Equivale11t Level of Safety Compared
to flight operations with rotorcraft weighing far morethan the maximum weights proposed herein, and given the lack of flammable fuel with the above noted UASs, anyrisk associated with these operations

is far less than those which presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the STT-UAS,
aswell asthe controlled location where the operations will occur.In order toavoid anyrisk tomanned aircraft, flight operations will be restricted

to400 feet AGL orbelow, or when inspecting

aU.S. structurewhose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structureand50 feet horizontally
of the structure. As setforth in the Operations Manuals, the STT-UAS will be operated
in arestricted area,and all flights will be operated
atalateral distance of atleast 500 feet from any nonparticipating persons,unless that person
is in a position where he orshe is shielded from the STT-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated

if a nonparticipating personwithin 500 feet of the STT-UAS leaves

ashielded position

.Further, its operations will occuratleast 500 feet awayfrom vehicles orstructures unless the propertyowner/controller timely has granted permission and the PIC has made

a safety assessment
of the risk of operating closer tothose objects and, operations nearthe PIC or Observer will not presentanundue hazard per§ 91.119( a). Adherence

tothese restrictions

in 15 Relief from
§ 91

.119(a) will notbe necessarybecause Petitioner will be able to perform an emergency landing without undue hazard to personsor propertyonthe ground
in the eventof afailure. Petitioner's proposed UAS operations will notoccurover congested areas,and therefore
an exemption from
§ 91.119(b) will notbe necessary

. See e.g.,Grant of Exemption No

.11157 to Slugwear, Inc., dba Like onatreeAerial (FAA-2014-0534

at 15).U.S Department
of Transportation December

2, 2015 Page 18 San Tan's Operations Manuals will ensure operations can be conducted without compromising public safety.
16 K. 14 C.F.R.

§ 91.121: Altimeter Settings San Tan seeks an exemption from 14 C.F.R.

§ 91.121, which requires

a person operating an aircraft to maintain cruising altitude or flight level by reference
to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption

is required
to the extent that the UASs do not have
a barometric altimeter, but rather

a GPS altitude read out. Equivale11t Level of Safety The FAA has stated that an equivalent level of safety to the requirements

of 14 C

.F
.R. §91.121 can be achieved
in circumstances where:

( 1) the UASs will be operated below 400 feet AGL or below

17 ,(2) within VLOS, (3) where GPS based altitude information

is relayed in real time to the operator
at a ground-based on-screen display and, (4) where prior to each flight,

a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS.I

8 The STT-UAS that San Tan intends to use for the proposed operations will meet all these operational characteristics. Moreover,
as required by San Tan's Operations Manuals, the PIC will be required
to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption, the STT-UAS San Tan intends
to use, and the safety mitigation procedures contained
in the Operations Manuals, both ensure that an equivalent level of safety or greater level will be achieved, and a Grant of Exemption

to the requirements of§ 191

.121 is therefore appropriate. L. 14 C.F.R.

§ 91.151(a): Fuel Requirements
for Flight in VFR Conditions San Tan requests an exemption from 14 C.F.R.

§ 91.151(a)'s fuel requirements
for flight in VFR conditions. Section 91.151 states: 16 See e
.g
.,Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481

at 19): "If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris
in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection.

If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA

,flight operations must cease immediately. When considering how to immediately cease operations, the primary concern

is the safety of those nonparticipating persons

.In addition

,the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner

/ controller of any such vessels, vehicles or structures grants pennission for the operation and the PIC makes

a safety assessment
of the risk of operating closer to those objects and determines that it does not present an undue hazard

." 17 1fthe height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. 18 See Grant of Exemption No. II 062 to Astraeus Aerial (F AA-20 14-0352
at 21 ).U.S Department
of Transportation December

2, 2015 Page 19 (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 tothe first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for atleast 30 minutes; or (2) At night, to fly after that for atleast 45 minutes. Here, the technological limitations
onUAS battery powermeansthat no meaningful flight operations canbe conducted while still maintaining

a30-minute battery reserve.An exemption from the fuel requirements
of 14 C

.F.R.
§ 91

.151 (a) is therefore required. Moreover,

it is notSan Tan's intention
to fly the SIT-U AS at night. Equivale11t Level of Safety In the Grant of Exemption

toVDOS (Exemption No

.11112), the FAA determined that an equivalent level of safety tothe fuel requirements
for flight in VFR conditions could be achieved by prohibiting the PIC from beginning

aSTT-UAS flight unless (considering wind and forecast weather conditions) there was enough powerto fly tothe first intended point of landing and, assuming normal cruising speed, to fly after that for atleast

I 0 minutes.
In reaching this conclusion, the FAA considered that the UAS batteries for the STT-UAS provide approximately 50 minutes of powered flight (with payload) and provided battery level and battery time remaining
in minutes and seconds tothe PIC.19 The FAA also considered the fact the STT-UAS operating manual states:"start every flight with
a fully charged battery in the aerial vehicle", and that in the eventthat the SIT-U AS should runlow on power,the PIC will be alerted and can safely land the- STT-UAS
assoonas possible. Like the VDOS Grant of Exemption, San Tan's useof the STT-UAS, combined with the requirements
of Petitioner's Operations Manuals, ensure that an equivalent level of safety canbe achieved and in fact exceeded. Similarly,

in the Grant of Exemption

toAlan Purwin (Exemption No. 11161), the FAA determined that an equivalent level of safety tothe fuel requirements
for flight in VFR conditions could be achieved by prohibiting the PIC from beginning

a flight with the UA unless (considering wind and forecast weather conditions), there was enough powerto safely fly at normal cruising speed tothe intended landing point and land the UA with 25% battery power remaining. San Tan will adhere tothis limitation for its STT-UAS flights. The STT-UAS includes

alow battery warning systemand the amountof battery reserve power remaining

is continuously transmitted

tothe PIC via telemetric data feed, which downlinks from the STT-UAS
toa ground-based-on-screen display.

20 As required by San Tan's Operations Manuals, the PIC will promptly fly the SIT-U AS back tothe home launch location or predetermined abort location where
it may safely land, while still maintaining

aminimum of25% reserve battery power.San Tan submits that the procedures requiring flights tobe safely 19. Grant of Exemption No

.11112 toVDOS Global, LLC (F AA-20 14-0382
atI 0). 20. The STT-UAS ground control station displays, the UASs position, navigation route,tail number, altitude, heading, north seeking arrow, rangeto targets

,calculated target position, date
/ time, and sensor heading and orientation relative
tothe UAS.U

.S Department
of Transportation December

2, 2015 Page 20 terminated oncethe batteries fall below 25% capacity, combined with the requirement that flights only be conducted within

asecure,isolated area, using

aUAS weighing less than55 pounds, and within VLOS of the PIC and Observer(s), ensurethat the proposed operation will provide an equivalent
or higher level of safety tothe public tothat provided by the regulations from which exemption

is sought. VI. DRUG AND ALCOHOL PROGRAM San Tan will have policies
in place toensurethat no person may participate

in STT-UAS flight operations

if they areunder the influence of alcohol or any drug. VII. PUBLIC INTEREST The public interest will be served by granting San Tan's Petition for Exemption. Congress has established

anational policy that favors early integration ofUAS into the NAS in controlled, safe working environments such asthose proposed

in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act

-the FAA Administrator's assessment
of whether certain UAS may operate safely in the NAS before completion
of the statutorily required rulemaking. The proposed STT-UAS operations

in this Petition for Exemption significantly improves the safety and reduces risk of harm, physical injury and property damage
tothe public at large, the propertyownersfrom whom permission was granted for use by Petitioner and abutting properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who maybe in the local vicinity. Traditional methods of providing surveillance and mapping services location personnel
toclimb towers, trees,ventureonto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped
to perform, which exposes them to unnecessaryrisk of serious physical injury from dangerous falls orother physical mishaps. Moreover, inspectors/surveyors areoften unnecessarily exposed
tohazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites tobe used in the end product. The useof small UAS caneliminate these hazards and ultimately create

amuch safer method of performing these typesof inspections creating

asafer environment
for the public aswell asSan Tan employees. The useof small UAS also enhances safety and reduces risk tothe surrounding public because, unlike manned aircraft weighing thousands of pounds, carrying crewin addition
toflammable fuel, the UAS carryno passengers,crewor explosive fuel. Furthermore,

in the unlikely eventof anaccident, San Tan's small battery powered STT-UAS presents significantly less danger
to personsonthe ground when compared

to operations
by conventional manned aircraft.

21 As 21 See Grant of Exemption No. 11158 toTeam 5, LLC (FAA-20 14-0783
at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds ormoreand are operated by anonboard pilot

,in addition toother onboard crewmembers,

as necessary.The petitioner's UAs will weigh less than55 pounds with noonboard pilot orcrew

. The pilot and crewwill be remotely located from the aircraft

.The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals
or property
in the eventof anincident oraccident. Risk toanonboard pilot and crew during anincident oraccident

is eliminated with the useof aUA for the aerial filming operation."U.S Department
of Transportation December

2, 20 15 Page 21 Petitioner's STI-UAS are battery powered, the public will also benefit from

a reduction
in harmful petroleum based emissions associated with conventional aircraft performing

in the same functions proposed herein. Air quality will naturally be improved with the reduction of fuel powered vehicles. Lastly, as recognized
by the FAA in prior Section 333 Grants of Exemption

to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding
the industry, adding

a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft.

22 The quality of the finished product
is enhanced and provides

a greater finished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product

is greatly reduced while reducing the difficulty with which the finished product

is created. The demand for the current industrial product
is increasing and will continue
to increase given the enhanced flexibility of production; therefore, given the lower cost, owner/operators
and others in the relevant industry will be more inclined
to utilize the services of commercial UAS along with an appropriate licensed PIC's. VIII. PRIVACY All STT-UAS operations will be conducted

in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller

or authorized representative

.Permission from land owner/controller

or authorized representative will be obtained for each flight to be conducted. IX. FEDERAL REGISTER SUMMARY Pursuant
to 14 C.F.R. Part 11, the following summary

is provided for publication

in the FEDERAL REGISTER, should
it be determined that publication

is needed: Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l)

& (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft,
or other methods. X. CONCLUSION San Tan's Petition for Exemption satisfies the criteria articulated

in Section 333 of the Reform Act of 2012 which includes weight; speed; operating capabilities; proximity
to airports and populated areas; operation within VLOS and national security. The proposed STT-UAS 22 See e
.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (F AA-20 14-0794
at 18).U.SDepartmentofTransportationDecember2,2015Page22operationswillbenefitthepublicasawholebyimprovingsafetyandreducingriskbyalleviatinghumanexposuretodangerwhileloweringtheattendantrelatedcoststherebyincreasingthedemandforthefinishedproduct.Inconsiderationoftheforegoing,thisPetitionforExemptionprovidestheFAAwithmorethanadequatejustificationforgrantingtherequestedexemptionsallowingSanTantousesmallSTT-UASintherecordedproductionofitsproduct.Wethankyouforyourpromptconsiderationofourrequestedexemptions.RespectfullySubmitted,JosephV.CatoneSanTanTrafficConsultants975E.RiggsRd.,Ste.12-460Chandler,AZ85249Phone:602.999.2125Email:jcatone@santanrecon.com(ThefollowingattacheditemscontainproprietaryandcommercialinformationexemptfromdisclosureundertheFreedomofInformationAct,5U.S.C.§522etseq.,andshouldbeheldinaseparatefilepursuantto14C.F.R.§11.35(b}).Attachments:I.GeneralOperationsManual2.PICOperatingManual3.CompanyProtocols4.LocationProtocols5.FlightCommunicationsProtocols6.DepartingLocationProtocols7.TransmitterProtocols8.PreflightChecklist9.PostFlightChecklist10.EquipmentChecklist11.VASManufacturer'sManualsa.UserManualsb.VASMaintenanceManuals