May 27,2015 U.S. Department ofTransportation Docket Management System : i \

1200 NewJersey Ave., SE Washington, DC 20590 Page 1 of 12

Re: ExemptionRequestPursuantto Section 333 ofthe FAA Modernization and Reform Act of2012, 49 U.S.C. § 44701(f), and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam Attached please find Michael J. Cavalere (MJC) a FloridaProfessional Surveyor and Mapper, License #3701, request for an exemption from the listed Federal Aviation Regulations to allow commercial operation ofa 

### small UnmannedAircraftSystems ("sUASs") for aerial imaging and for safe and efficient surveying and mapping ofsecured and controlled sites. The exemption request is exclusively for the use ofthe sUASs and technology manufactured by 

### DJI, an international manufacturer ofsUASs headquartered in Shenzhen, China. Also attached to this letter is the

### DJIPhantom 3 Flight Manual ("Manual"), which outlines the operating requirements, limitations, and technical specifications for the DJI system including its accessories. MJC has reviewed the DJ/Manual and its online resources and has found it to be acceptable for sUAS operations on secure project sites. Applicant submits this Manual as proprietary informationpursuantto 14 CFR 11.35(b). Attached is the full Exception Request. Thank you for your time and consideration, and please let me know ifyou have any questions. Sincerely,

# Ow~ Michael J. Cavalere, P.S.M. Florida Licensed Professional Surveyor and Mapper#3701 2722 Sweet MagnoliaPlace Oviedo, Florida 32765 mcavalere@cfl.rr.com Telephone 407-467-9374

C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docExemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations; Seeking Exemption from 14 C.F.R. Part 21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. §§ 91.7(a); 14 C.F.R. §§ 91.9(b)(2); 14 C.F.R. §§ 91.103; 14 C.F.R. §§ 91.109; 14 C.F.R.§ 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a)(b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b). Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Michael J. Cavalere (MJC), a Professional Surveyor and Mapper licensed inthe State ofFlorida, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation for a Small Unmanned Aircraft Systems ("sUASs") for safe, efficient andup-to-date aerial imaging ofsecured and controlled vacant and under- development sites, so long as such operations are conducted within and under the conditions outlined herein or as maybe established bythe FAA as required by Section 333. As detailed inthis document and the attached DJI Phantom 3 FlightManual, the requested exemption would permitthe operation ofsUAS under acceptable conditions in airspace that is: limited, predetermined, controlled as to access, and would provide an increased level ofsafety for use inLand Surveying and Aerial Photography. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to
.... "establishrequirements for the safe operation ofsuch aircraft systems in the national airspace system." The Name and Address ofthe applicant is: Michael J. Cavalere 2722 Sweet Magnolia Place Oviedo, Florida 32765 mcavalere@cfl.rr.com Telephone number 407-467-9374

C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docRegulations from which the exemption is requested:

• 14 CFRPart 21 • 14 C.P.R. 45.23(b) • 14 CFR 61.113 (a) & (b) • 14 C.P.R. 91.7 (a) • 14 CFR 91.9 (b)(2) • 14 C.P.R. 91.103 • 14 C.P.R. 91.109 • 14 C.P.R. 91.119 • 14 C.P.R. 91.121 • 14 CFR 91.151 (a) • 14 CFR91.203 (a) & (b) • 14 CFR91.405 (a) • 14 CFR407 (a)(1) • 14 CFR409 (a) (2) • 14 CFR417 (a) & (b)

1. Statutory Authority for Exemptions The Federal Aviation Act expressively grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under section §40101 ofthe Act that includes sUASs, from the requirement that civil aircraft musthave a current airworthiness certificate. This exemption application is expressly submitted to fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certain unmanned aircraft systems mayoperate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. Inmakingthis determination, the Secretary is required to determine whichtypes ofsUASs do not create a hazard to users ofthe NAS orthe public or pose a threat to national securityin light ofthe following:

• The sUAS's size, weight, speed, and operational capability • Operation ofthe sUAS in close proximityto airports and populated areas; and • Operation ofthe sUAS within visual line ofsight ofthe operator. Reform Act Section 333 (a). Lastly, ifthe Secretary determines that such operations "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." 

### !d. §333( c).

C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docMJC's sUASs are electricitypowered, multi-rotor vehicles, weighing fewer than lOlbs. including payload. They operate under normal conditions at speeds ofno more than 25 knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. The sUAS will operate only inthe line ofsight at all times and will operate only within the sterile area described and pre-established before all flights as outlined in the attached DJI Manual. Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system or the public." Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted environment within which theywill operate, the applicant falls squarely withinthat zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofsUAS to commence immediately. Also due to the size ofthe sUAS and the restricted areas inwhich the relevant sUAS will operate, approval ofthe application presents no national securityissue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significantpublic benefit, including reliable and up-to-date aerial imagery, enhanced safety for surveyors and associated contractors, and reduction in environmental impacts, including reduced emissions. Exemptions associated with allowing the commercial use ofsUAS in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. 

### 2. Public Interest This exemption application is expressly submitted to fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion oftherulemaking required under Section 332 ofthe Reform Act. By granting an exemptionthe FAAwill fulfill Congress' intent ofallowing sUAS to operate with significant safetyprecautions in lowrisk environments. The use ofsUASs in surveying, mapping and aerial imaging can significantly increase the quality and accuracy ofsite evaluation and surveys and would reduce the cost compared to conventional methods ofaerial imaging and photogrammetry. Larger more conventional aircraft are potentially hazardous due to their size, combustible fuel, and emission ofhazardous pollutants. Switchingto the use ofsUASs would increase the safety ofworkers and the general public. Additionallyuse ofsUASs would also allow greater access to densely vegetated or impassable areas. Conventional imaging is limited due to the size ofthe vehicles used andthe height ofsurrounding vegetation. sUASs would allow for greater precision in imagerythat would require an AGL too low for conventional aircrafts.

C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docLastly, use ofsUASs at vacant sites and under-development sites canreduce the risk of injury byeliminating the need for a large number ofworkers in a potentially hazardous environment. There are innumerable risks in almost every work place, and especially in the surveying and construction fields. The implementation ofsUASs can reduce the number of injuries and fatalities onthese hazardous sites. 3. Equivalent Level ofSafety MJC proposes thatthe exemptionrequested herein apply to civil aircraftthat have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations under the currentregulatory structure because the proposed operations represent a safety enhancementto the already safe protocols followed onconstruction sites for imaging and surveying operations conducted with helicopters and other conventional aircraft. MJC will be bound bythe following limitations when conducting sUAS operations under an FAA issued exemption: 1. The sUAS will weigh less than 10 lbs. 2. Flights will be operated within line ofsight ofthe Pilot. 3. Maximumtotal flight time for each operational flight will be 20 minutes or less for multirotor. Flights will be terminated at 25% batterypowerreserve should that occurprior to the 20 minute limit. 4. Flights will be operated at an altitude of200ft and no more than400 feet Above Ground Level (AGL). 5. Minimum crew for each operation will consist ofthe sUAS Operator who will maintain VLOS withthe sUAS at all times. 6. sUAS operators will be trained in flight, operations, and safetyprocedures as detailed in the Flight Manual 7. The sUAS will only operate within limits as defined inthe FlightManual. Itrequires the establishment ofa "SecurityPerimeter" for the flight operations area. 8. A briefing will be conducted inregard to the planned sUAS operations priorto each day's production activities. 

### It will be mandatory that all personnel that will be performing duties within boundaries ofthe safetyperimeter be present for this briefing. 9. All onsite personnel will consent to the sUAS flyover on site by waiver, and the operator will obtain additional verbal or written consent ofall persons who will be allowed within 1OOft ofthe flight operation. C:\Users\mcavalere\Documents\{STORAGE)\UAS\Michael J. Cavalere Application.doc10. The operator will prepare a written Plan ofActivities for each site. 11. The operator will have beentrained inthe safe operation ofsUAS generally and received up-to-date information onthe particular UAS to be operated. 12. Written and/or oral permission from the relevant propertyholders will be obtained. 13. All required permissions and permits will be obtained from territorial, state, county, or cityjurisdictions, including local law enforcement, fire, or other appropriate government agencies. 14. Ifthe sUAS loses communications or it loses its GPS signal, the sUAS will have capabilityto return automatically to a pre-determined location withinthe Security Perimeter and land. 15. The sUAS will have capabilityto abort flight in case ofunpredictable obstacles or emergencies. 4. Description ofSpecific Regulations 14 C.F.R. Part 21, Subpart H: Airworthiness certificates 14 C.F.R. Section 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR Section 91.203 (a) (1). Given the size and limited operating area associated with aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe Reform Act, both which authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, proximityto airports and to populated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates thatthe sUAS operated without an airworthiness certificate, in a restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe retractions and conditions proposed. The sUAS to be operated bythe applicant is less than 10 lbs. fully loaded; carries neither a pilot norpassenger; carries no explosive materials or flammable materials liquid fuels and operates exclusively within a secured area as set outin Manual. Like other civil aircraft, operations under this exemptionwill be controlled and monitored bythe operator, pursuantto the FlightManual's requirements, andunder the requirements and in compliance with local public safetyrequirements, to provide security for the area ofoperation. These safety enhancements, which already apply to civil aircraft operated in connection to motionpicture and television production, provide a greater degree ofsafetyto public and property owners than conventional operations conducted with airworthiness certificates issued

C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docunder 14 C.P.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national securityposed bythe sUAS due to its size, speed of operation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. 14 

### C.F .R. Section 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter ''N" andthe registration of the number is displayed on limited, restrictedor in a light-sport categoryaircraft or experimental or provisionally certifiedaircraft, the operator mustalso display on the aircraft near each entrance to the cabin, cockpit, orpilotstation, in letters notless than 2 inches nor more than 6 inches high, the words "limited, " "restricted," "light spot," "experimental," or ''provisional," as applicable. Eventhoughthe sUAS will have no airworthiness certificate, and exemptionmaybe needed as the sUAS, because ofits size, will have no entrance to the cabin, cockpit or pilot station onwhichthe word "experimental" can beplaced. Given the size ofthe sUAS, the two inch lettering will be impossible. However, the word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided byhaving the sUAS marked onit fuselage as required by §45.29 (f) where the operator, observer and others working withthe sUAS will be able to visually see the identification ofthe sUAS as "Experimental." The FAAhas issued the following exemptions to this regulation to exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167A. 14 C.F.R. § 61.113 (a) & (b): Private pilots Privileges and Limitations: "Pilot in Command". Sections 61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the sUAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafetyofcurrent operations byrequiring thatthe "Pilot inCommand" operatingthe aircraft to have logged 50 hours offlight experience along with 200 take-offs and 200 landings with a DJI's UAS before flying at a site, rather thanhave a commercial pilot's license to operate this small sUAS. Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled with no living thing onboard. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafetyprovidedby the requirements included inthe manual exceeds thatprovided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated withthe operation ofthe sUAS are so diminished from the level ofrisk associated withthe operation ofa commercial operations contemplated with Part 61 when drafted, that allowing operations ofthe sUAS as requested with a pilot who has metthe minimum requirements outlined in the Manual and has logged a sufficient number offlights exceeds the present level ofsafety achieved by 14 C.P.R. §61,113 (a) & (b).

C:\Users\mcavalere\Documents\{STORAGE)\UAS\MichaelJ. Cavalere Application.doc14 C.P.R. §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, should this exemption be granted, no FAAregulatory standard will exist for determining airworthiness. Given the small size ofthe aircraft and the requirements contained inthe manual for maintenance as well as the use ofsafety check lists priorto each flight and as set forth inthe manual, an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual, marking and placard in the Aircraft The sUAS, 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 onboard, but because there is no room or capacityto carry such an item onthe aircraft. The equivalent level ofsafetywill be maintained bykeeping the flight manual atthe ground control pointwhere the operator flying the sUAS will have access to it. The FAA has issued the following exemptions to this regulation: ExemptionNos. 8607, 8737, 8738, 9299,9299A,9565,9565B, 10167, 10602,32827,and 10700. 14 C.F.R. § 91.103: Preflight action This regulationrequires eachpilot in command to take certain actions before flight to insure the safety ofthe flight. An exemption is needed from this requirement as the pilot will take all actions including reviewing weather, flight batteryrequirements, landing and takeoffdistances and aircraft performance data and all other actions outlined in the Flight Manual, before initiation offlight. These actions will provide an equivalent level ofsafety. 14 C.F.R. §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 fully functioning dual controls. sUASs and remotely controlled aircraft, bytheir design, do nothave fully functioning dual controls. Flight control is accomplished through the use ofa remote control box that communicates with the aircraft viaradio communications. The FAAhas approved exemptions for flight training without fully functioning dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See exemptionNos.5778K & 9862A. The equivalent level ofsafety will be provided inthat neither a pilotnorpassengers will be carried inthe aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operations ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less thanthe minimums prescribed provided the person C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docoperating the helicopter complies with anyroute or altitudes prescribed for helicopters bythe FAA. This exemption is for the sUAS that flies similarly to a helicopter and the exemption requests authority to operate at altitudes ofup to 400 Above Ground Level (AGL), or notmore than 200 above an elevatedplatform from which filming is planned, an exemption is needed to allow such operations. As set forth by herein, except for the limited conditions stated in the Flight Manual, the sUAS will never operate higher than 400 AGL. It will, however, be operated in a restricted area with a securityperimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants inthe activity, all affected individuals will be aware ofthe planned flight operations as set forth in the FlightManual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximumweight proposed herein and the lack offlammable fuel, any risk ofassociated withthese operations is far less than those presentlypresented with conventional aircraft operating at orbelow400 AGL inthe surveying and mapping industry. In addition, the low-altitude operations ofthe sUAS will ensure separationbetween these small SUAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings This regulation requires eachperson operating an aircraft to maintain cruising altitude byreference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead, through the use ofGPS technology and a GPS altitude read out, an exemption maybe needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the Flight Manual and Safety Check list, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. 14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits and individual from beginning "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 ofintended landing, and assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The batterypoweringthe sUAS provides approximately 20-25 minutes ofpowered flight. To compensate the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limitedto approximately 15 minutes in length or 25% battery, whichever comes first, which would allow for a reserve ofa third ofits battery power for emergencyuse. Given the limitations onthe SUAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ornight VFR conditions is reasonable. MJC believes that an exemption from 14 CFR (a) falls within the scope ofprior C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docexemptions. See Exemption 11600 (Regulatory DocketNo. FAA-2015-0527) (allowing Bartram Trail Surveying, Inc. to operate without compliance with FAR 91.151(a)). Operating the small sUAS, in a tightly controlled area where onlypeople and property owners or official representatives who have given their approval, with less than 30 minutes ofreserve fuel, does not engender the type ofrisk that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small sUAS. Additionally, limiting the sUAS flight tirnr would greatly reduce the utility for which the exemption will be granted. MJC believes that an equivalent level ofsafety can be achieved bylimiting flights to 15 minutes or 25% ofbatterypower, whichever happens first. This restriction would be more than adequate to returnthe sUAS to its landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 and 10808. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides inpertinentpart: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than 10lbs and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents or display them onthe sUAS. An equivalent level ofsafety will be achieved bykeeping these documents at the ground control pointwhere the pilot flying the sUAS will have immediate access to them; to the extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exemptions includes ExemptionNos. 9565, 9665, 9789, 9789A, 9797, 9816A, 10700. 14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (b) These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter

... ," and others shall inspect ormaintain the aircraft in compliance with part43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to MJC. Maintenance will be accomplished bythe operator pursuant to the Flight Manual and operatinghandbook as referenced inthe Manual. An C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.docequivalent level ofsafety will be achieved because these small sUAS are verylimited in size and will carry a small payload and operate only inrestricted areas for limited periods oftime. If mechanical issues arise the sUAS canland immediately and will be operating from no higher than 400 feet AGL. As provided inthe Manual, the operator will ensure thatthe sUAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany maintenance preformed. Moreover, the operator is the personmost familiar withthe aircraft and best suited to maintainthe aircraft in an airworthy conditionto provide the equivalent level of safety.

Pursuantto 14 C.F.RPart 11, the following summaryis provided for publication inthe Federal Register, should itbe determined thatpublication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (10 lbs. or less) for Photographic, Surveying and 3d Mapping Service Operations Approval ofexemptions allowing commercial operations ofsUASs inthe surveying and 3d mapping/scanning industry will enhance safety by reducing risk. Conventional aerial mapping uses larger aircraft or helicopters carrying crew members, passengers and operate using fuel and are very large by design. The sUAS will carry no passengers or crew, are very small relative to conventional manned airplanes or helicopters and therefore, will not expose anyone to the types ofrisks associated with manned aircraft flights. The operations ofsmall sUASs, weighing less than 55 lbs., conducted inthe strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe Part 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, closer to the ground and in a restricted and controlled environment, as a result, are far safer than conventional operations conducted with a manned piston and orturbine aircraft operating close to the ground. Public Acknowledgement/Privacy All Flights will occur only once the property owner has authorized operations to be conducted. Images taken will be ofindividuals who have also consented to being filmed or otherwise has agreed to be inthe area where aerial photography will take place.

Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximityto populated areas and or close proximityto airports and operations within visual line ofsightprovides more than adequatejustificationfor the grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in Photography, Surveying and 3D mapping service operations. C:\Users\mcavalere\Documents\(STORAGE)\UAS\Michael J. Cavalere Application.doc

### Sincerely,

MichaelJ. Cavalere Professional Surveyor and M

## Tele~hone: (407) 467-9374 apper, LS 3701 (Florida). 

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