August 12th, 2015 William Hill Hill Land Surveying 133 Featherstone Lane Hampton Cove, AL 35763 U.S

. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJersey Avenue, SE. Washington, DC 20590-0001 RE: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 

### 11, Hill Land Surveying requests exemption from the Federal Aviation Regulationsto allow for commercial UAS operation ofa 3D Robotics X8+for the purpose ofaerial photography, surveying, agricultural mapping and other flight operations that could be performed safely and more cost effectivelythan withoutthe use of an unmanned aircraft. The name and address ofthe applicant is: HILL LAND SURVEYING William Hill (President) 133 Featherstone Lane Hampton Cove, AL 35763 Phone: 256-337-6102 Email: hilllandsurvey@aol.com Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 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 (c) 

### 14 CFR 91.121 14 CFR 91.151 (a} 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a}14 CFR 91.407 

### (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Given the size and limited operating area associated with the aircraftto be utilized by Hill Land Surveying, an exemption from Part 21 Subpart Hshould be granted. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft 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 ofthe UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided by having the UAS marked on itsfuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14C.F.R § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Since the UAS will notcarry a pilot or passengers Hill Land Surveying requests a relieffrom these regulations. Any pilot in command or (PIC) operatingthe UAS will hold a Sport Pilot (or greater) certificate. All UAS operations will take place in a controlled area. The risks associated with the use ofa UAS are far less than similar commercial aircraft operations. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness Since there will be no airworthiness certificate issued for the aircraft, as the UAS will notcarry a pilot or passengers, should the exemption should be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafetywill be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft Given the size ofthe UAS, it has no abilityto place orcarry a flight manual on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control point where the pilotflying the UAS will have immediate access to it. 14 C.F.R. § 91.103: Preflight Action As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight battery requirements, checking takeoffand landing distances will be used to provide an equivalent or higher level ofsafety. 14 C.F.R. §91.109: Flight Instruction. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft. 14C.F.R. §91.119: Minimum Safe Altitudes The UAS will never be operated at an altitude higher than 200 feet AGL. The operation ofthe UAS will occur in safe areas away from public areas and traffic and only in private areas with permission oftheproperty owner. The UAS will be restricted by the flight controller to a maximum vertical height of 197 feet AGL and 

### 1500feet horizontal. Given the size, weight, maneuverability, and speed ofthe UAS, an equivalent or higher level of safety will be achieved. 14C.F.R. §91.121 Altimeter Settings As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight 14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions The UAS has a limited range and will be limited to operations in a controlled environment. The battery power ofthe UAS is approximately 

### 15 minutes offlight time, meaning it will be unable to meetthe 

### 30 minute requirement and requires an exemption to be granted

. An equivalent level ofsafety can be achieved by limitingflights to 

### 12 minutes or 

### 20% of battery power remaining, whichever occurs first. All flights will also occur in a controlled area where only authorized personnel and property owners will be allowed. This ensures thatthe UAS will be able to return to its planned landing zone anywhere in its limited operating area safely. 14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration Given the size ofthe UAS and that it is operated without an onboard pilot, there is no ability or place to carry certification and registration documents orto display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilotf lying the UAS will have immediate access tothem. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### & (b): Maintenance Inspections Since the above sections only apply to aircraft with an airworthiness certificate, these sectionswill not apply to the applicant and should be exempted. As a safety precaution, t he operatorwill perform preflight inspections and ensure thatthe UAS is in working condition before each flight. Equivalent Level ofSafety In addition to the safety standards mentioned above, the UAS will adhere to the following additional guidelines

. • The UAS will weigh less than 

### 55 lbs. • Flights will not exceed an airspeed of 

### 25 mph. • Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). • Minimum crew for each operation will consist ofthe UAS Pilot and the Visual Observer (VO) • The UAS pilotwill be a designated Pilot in Command (PIC) and hold at least a Sports Pilot License • All flights will occur undervisual meteorological conditions • The UAS will not be operated within 5 miles of an airport unless prior contactto Air Traffic Control has been established

. • The PIC and VO will communicate verbally at all times. • Loss ofcommunications w ith the remote controlleror loss ofGPS signal for the UAS will require it to return to a pre-determined location within a designated location and land autonomously. • The UAS will have automatically abort its flight in the event of emergencies or unforeseen obstacles.

### Public Interest The use of a UAS, as opposed to employees of Hill Land Surveying manually surveying the land, substantially reduces the risk of injury ofthe employees as well as reducing the overall time required for the work to be completed. The inspection ofthe land by use of UAS will eliminate any risks associated with physically climbing all areas ofthe land, especially considering that some ofthe locations being surveyed are quarries where there is substantial risk of injury climbing upthe piles in orderto take measurements. The use ofa UAS will greatly reduce the time it would take to complete the surveying project and eliminates the risk of injurytothe surveyors, allowing for better use of resources for both the surveyor and client as less time and effortwill be required for each project.