World	Services,	LLC **333	Excemption** 1

World	Services,	LLC World Services, LLC 6561 McKinley St Hollywood , FL 33024 Shaun Sutton Managing Director Cell ( 954 ) 328 7535 Email: world1@comcast.net U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 September 15 , 2015 Dear Director: On behalf of World Services, LLC H ereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of Small Unmanned Aircraft Systems (sUASs) for the purposes of Arial Data collection, marine and industrial P hotographic , visual and thermal imaging inspections, mapping, surveying, aerial photography, videography and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft or in

person visual inspections. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11. World Services, LLC seeks Exemption Request per Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from : 14 C.F.R. Part 21; 14 C.F.R. 47 ; 14 C.F.R. 61.3(a); 61.23(a); 61.113(a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a) ; 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b);The requested exemption would permit World Services, LLC to

conduct commercial operation of small, unmanned sUAS by train ed , certified sUAS operators. Furthermore an exemption will allow World Services, LLC the opportunity to further develop NDT (non destructive testing) inspection programs that will be beneficial to the safety of inspectors our clients and the public in general and in turn raise awareness as to the beneficial uses of small

- unmanned air systems. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents

. Such operations will be conducted within and under the conditions outlined herein or as established by the FAA , as required by Section 333. World Services, LLC seeks exemption ; for operating the DJI Phantom 3 Pro, DJI Inspire 1 T600 and DJI Spreading Wings S1000+ The above referenced UAS’s manufactured by DJI are highly successful professional grade small rotorcraft drones each of which will be maintained and operated to manufactures specifications and at weights under 55lbs (including payload). Controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator ( PIC ) to monitor battery level, GPS s ignal strength, altitude (AGL) distan ce from PIC, camera imagery, and control camera angle. DJI utilizes internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. World Services, LLC UAS’s will be operated utilizing DJI’s failsafe modes of operation for either loss of RC or GPS signal. World Services, LLC operators (PIC’s) will utilize the on - board flight controller that limits altitude . M aximum altitude will be preprogrammed and maintained by the PIC to 40 0ft AG L thusWorld	Services,	LLC **333	Excemption** 3

World	Services,	LLC maintaining a safe buffer of 10 0ft AG L to aircraft m inimum permitted normal operational altitude of 5 00ft AG L

. Battery life limits flight times to approximately 20 minutes. The on

board flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. Visual line of sight will be maintained at all times by the “ PIC” A visual observer will be utilized. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. Risk mitigation The petitioner has reviewed FAA exemptions reference’s 13 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. 14 CFR §25.23(b) Marking of the Aircraft All aircraft operated will be identified by serial number, and registered in accordance with 14 CFR part 47, and have identificati on (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Given the obvious limitations World Services, LLC requests exemption from registration and markings size limitations. Should they be required m arkings will be made as large as possible

. Or as may be required by order of this exemption

. 14 CFR §61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. C urrent FAA ai rman medical certificate or a valid U.S. driver’s license

. 14 CFR §91.7(a): Civil Aircraft Airworthiness Airworthiness will be maintained by performance of routine inspections before each flight, conducting routine maintenance permanufactures recommendations post flight and utilize flight and

maintenance logs to record failure prone components. 14 CFR §91.103: Preflight Action To ensure that the UA airworthiness be verified before launch a pre-flight checklist as per DJI operating manuals will be employed

. 14 CFR §91.109: Flight Instruction World Services, LLC will not permit any PIC to operate unless the PIC has demonstrated the ability to safely operate the UAS, including evasive and em ergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants. T he PIC in training will operate the UA with appropriate distance from nonparticipants the instructor will be considered a participant with operati onal control

. 14 CFR §91.119: Minimum Safe Altitudes Altitude of no more than 400 feet above ground level (AGL) will be maintained. Furthermore World Services, LLC Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures. The “operator” (PIC) will ensure that nonparticipating persons remain under protection. If a situation arises where nonparticipating persons enter within 500 feet of the UA, flight operations will cease immediately. 14 CFR §91.121 Altimeter Settings DJI systems utilizes internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioningWorld	Services,	LLC **333	Excemption** 5

World	Services,	LLC system (GPS) to maintain its geospatial orientation and position

. As pa rt of each preflight position orientation is calibrated and set. 14 CFR §91.151(a) Fuel Requirements for Flight in VFR Conditions World Services, LLC seeks exemption from minimum fuel requirement as required by regulation as DJI UAS’s do not carry fuel. 14 CFR §91.203(a) and (b): Carrying Civil Aircraft Certificates and Registration Due to the UAS limits in size and construction it is impractical to carry any certificates and/or registration. Any documents required for the operation of the UAS will be held in the area of operation by the PIC. 14 CFR §91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections P rocedures will be adhered to for pre and post flight inspections so as to maintain continued airworthiness. Airworthiness will also be maintained by the perform ance of routine inspections, as outlined in the Manufactures maintenance manuals

. World Services, LLC will conduct routine maintenance per manufactures recommendations and use flight and maintenance log data to track and record fail ed components. Public interest Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying flammable fuel and a crew

. T his petition will enable World Services, LLC to offer a level of service to property and facility owners or their designees that cannot be conducted economically or safely through ground level or other means of areal videography and or photographic inspection

.Aerial marine and industrial inspections utilizing UAS’s can

increase work site efficiency improve safety eliminating the need for safety harness and scaffolding and thus reducing risks to inspection personnel

. Surveying applications for requested exemption will considerably enhances accessibility while cutting costs and greatly improving public safety

. Additionally, commercial use of the UAS could lead to stimulation of economic growth.

Conclusion The petitioner is requesting this exemption for the purposes of aerial photography, cinematography, videography, mapping, surveying, marine and industrial inspections a nd other flight operations. World Services, LLC requests a broad based exemption so as to capitalize on opportunities as they may arise without additional exemptions. Although videography and photography are included in the request, the primary objective will be aerial data collection in efforts to mitigate the need for “man

- lift” , rope access , ladders or scaffolding

. Respectfu lly submitted, Shaun Sutton World Services, LLC 6562 McKinley St Hollywood FL 33024 954 328 7535 World1@comcast.net Attachment links : DJI Inspire: www.dji.com/product/inspire

- 1/download DJI Phantom Pro : www.dji.com/product/phantom

-3/download DJI Spreading Wings S1000+ : www.dji.com/product/spreading

wings

-s1000

- plus/downloadWorld	Services,	LLC **333	Excemption** 7

World	Services,	LLC