October 27, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Petition ofDSI Drone Solutions and Imaging for an Exemption Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 Director: Flight Standards Service: Pursuant to Section 333 oftheFAAModernization and ReformAct of2012 ("ReformAct") and 14 C.F.R. Part 11, DSI Drone Solutions and Imaging ("Drone Solutions") hereby applies for an exemption from the FederalAviation Regulations ("FARs") identified below to allow commercial operation ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose ofconducting aerial photography, videography, property mapping, inspection ofresidential and commercial real estate for related real estate and construction industries. This petition for exemption is made based on information outlined inthis Petition for Exemption, as well as the accompanying Drone Solutions documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. Flight Manual' (Collectively 3 and 4 are referred to as "Manufacturer's Manuals"). Drone Solutions submits these supporting materials as confidential documents pursuantto 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary informationthat Drone Solutions has not and will not share with otherrequesting parties. Additionally, these documents contain operating conditions andprocedures that are not generally available to the public and are protected from release under the Freedom ofInformationAct, 5 U.S.C. § 552 et. seq. For your convenience, this Petition is organized as follows:

1

. The term "Manufacturer's Manual" also includes all relevant manufacturerpublications, including, butnot limited to: operations and flight manuals, user guides, component maintenance manuals, pilottraining manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation October 27, 2015 Page2 

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Photography, Videography, Property Mapping and Inspection 

### III. Relevant StatutoryAuthority IV. Drone Solutions'Proposed UAS Operations Meet the Requirements of Section 333 ofthe ReformAct A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions Set Forth inthe Operations Manuals 

### V. Regulations FromWhich Exemption is Requested A. 14 C.F.R. Part 21, Subpart H -Airworthiness Certificates and 14 C.F.R. § 91.203(a)(l) B. 14 C.F.R. Part 27Airworthiness 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)(l), 91.409(a)(l) 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): CivilAircraftAirworthiness G. 14 C.F.R. § 91.9(b)(2): CivilAircraft FlightManual intheAircraft and 14 C.P.R.§ 91.203(a) and (b): Carrying CivilAircraft Certification and Registration H. 14 C.F.R. § 91.103: PreflightAction I. 14 C.F.R. § 91.109(a): Flight Instruction J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes K. 14 C.F.R. § 91.121 :Altimeter Settings L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. ConclusionU.S Department ofTransportation October 27, 2015 Page3 

### I. DESCRIPTION OF PETITIONER Drone Solutions, is based inAurora, CO, working in photography and videography services for the real estate and construction industries. The Company specializes in, and will continue to focus on, the videography and photography ofproperty and real estate for inspection and sales purposes as well as property mapping and inspections for construction related projects. The Company's Principal, Andrew R. Martin, has been flying UAV Quadcopters as a hobby for more than one year without incident, spending hundreds ofhours flying. Uponthe grant ofthe 333 Exemptionthe Company's business will specialize inreal estate photography and videography ofresidential, commercial and industrial for the promotion of properties for sale and land development and additionally will offer services for property mapping and inspection. Drone Solutions' staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in additionto any other needed on site assistance. All ofthe equipment ownedby Drone Solutions is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Drone Solutions' goal is to advise the perspective clientthat Drone Solutions is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Drone Solutions seeks an exemptionto allow for photography, videography and otherrelated mediaproducts. The contact information for Petitioner is as follows: AndrewR. Martin DSI Drone Solutions and Imaging 19093 E. Bates Ave. Aurora, CO 80013 Phone: 720.675.0574 Email: danda34@comcast.net 

### II. DESCRIPTION OF PROPOSED OPERATION Drone Solutions seeks an exemption pursuant to Section 333 ofthe ReformAct to operate the DJI Phantom 2. (refened to as DSI-UAS) (under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions onprivate property or approved location where Drone Solutions has received verifiable permission to operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption and Drone Solutions' Operations Manuals. As detailed in Drone Solutions' Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") ofthe operator, inuncontrolled airspace, and will occur at least 5 mm away from an airport reference point. Moreover, Drone Solutions' Operations ManualsU.S Department ofTransportation October 27, 2015 Page4 incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. A. Aerial Photography, Videography, Property Mapping and Inspection Drone Solutions seeks to use small DSI-UAS for the purpose ofconducting photography, videography, mapping and inspection services for the real estate and construction industry. Drone Solutions has purposefully tailored its operations to meetthe requirements established by the FAAinprior grants ofexemption authorizing commercial use ofUAS inthe real estate industry, including:

• Trudeau, Realtor® (ExemptionNo. 11138) • Alon Sicherman (ExemptionNo. 11728) • Sokoler Medly (ExemptionNo. 11341) All UAS real estate photography and videography operations will occur onprivate property or approved location in a controlled area away from spectators and persons not involved inthe recording process. In addition, the filming will be conducted between dawn and duskto ensure maximum safety for the public and those involved in the manipulation and operation ofthe UAS; VFRconditions, at altitudes below 400' above ground level ("AGL"). As set forth below, Drone Solutions' operations provide an equivalent level ofsafety which is superiorto performing the same work using conventional fixed-wing aircraft or helicopters. Small UAS real estate video production is also safer thantraditional manned aircraft performing the same function. Videographer-inspectors also frequently need to climb roof tops, trees, or otherwise perform elevated work, which exposes them to the risk ofdangerous falls, electrocution orother work related injuries. In addition, depending on the nature ofthe video needed and inspection, proximityto equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofDSI-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most other types ofinspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel which inherentlypresents significant fire hazards as well as exposure to other chemical contaminates. Itis importantto note the use of small UAS inthis area will not onlybe safer and more cost effective to the perspective user or purchaser ofthe service, butthe quality and expanse ofacquired information will be far more robust giventhe low cost associated with its acquisition and otherpotential consumers an inexpensive product. UAS real estate video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. Small UASs will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible or highly dangerous using conventional aircraft or other inspection methods.U.S Department ofTransportation October 27, 2015 Page 5 

### III. RELEVANT STATUTORYAUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe FAAModernization and ReformAct of2012 ("ReformAct"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 ofthe ReformAct, the FAAAdministrator is to permit unmanned aircraft systems to operate inthe NationalAirspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAAAdministrator has general authority to grant exemptions from the agency's safety regulations and minimum standards whentheAdministrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(±) (definingthe authority ofthe Administrator); 49 U.S.C. § 44701(±) (permitting exemptions from§§ 44701(a), (b) and §§ 44702- 44716, et seq.). A party requesting an exemption must explainthe reasons why the exemption: (1) would benefitthe public as a whole, and (2) wouldnot adversely affect safety (or howit wouldprovide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. DRONE SOLUTIONS' PROPOSED DSI-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The small DSI-UAS operations proposed byDrone Solutions as noted above inthis Petition for Exemption qualifY for expedited approval pursuantto Section 333 ofthe ReformAct 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 ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The DSI-UAS utilized by Drone Solutions has been approved for use inprior Section 333 Grants ofExemption from the FAA. 2

• The DSI-UAS weighs less than 55 pounds, including payload

• The DSI-UAS will not be flown at a ground speed in excess of50 knots. The exemptionholdermay use either groundspeed or calibrated airspeed to determine compliance withthe 50 knot speed restriction.

2See e.g., Grant ofExemption to Trudeau, Realtor® (ExemptionNo. 11138); Grant ofExemptiontoA!on Sicherman (Exemption No. 11728); Grant ofExemptionto Sokoler Medly (ExemptionNo. 11341).U.S Department ofTransportation October 27, 2015 Page6

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot viatelemetric data feed.

• The DSI-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnection to the remote control or ground control station is lost, failsafe systems will permitthe UAS to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control ofthe DSI-UAS comply withthe Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the DSIUAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference in weight betweenthe DSIUAS and a helicopter significantly reduces the potential harmto the participating and nonparticipating individuals and/or surrounding property in the event ofan unintended accident or incident. 

### In addition, the riskto the onboard pilot and cameraoperator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in Drone Solutions' Operations Manuals Drone Solutions' Operations Manuals and the Manufacturer's Manual for the selected DSI-UAS will contain all the procedures and limitations necessary to safely and successfully performthe operations specified inthis Petition for Exemption. To assist the FAA in making a safety assessment ofDrone Solutions'proposed operations, belowis a summary ofoperational limitations and conditions that Drone Solutions will adhere to, and which will ensure an equivalent or higher level ofsafetyto operations conducted under current regulatory guidelines: 1. The DSI-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UAS operated underthe Grant ofExemptionwill be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe DSI-UAS, and one ormore Visual Observers ("Observer") as necessary to safely conductthe mission.U.S Department ofTransportation October 27, 2015 Page 7 5. PICs shall possess either a private, recreational, or sportpilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, 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 an aircraft in whichthe PIC is rated on his orherpilot certificate. 6. The DSI-UAS shall be operated withinVLOS ofthe PIC and Observer at all times. The PIC must use human visionunaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption shall be added to the Drone Solutions' Operations Manuals. The Operations Manuals will be maintained and made available to theAdministrator upon request. Ifa discrepancy exists between the conditions and limitations inthe Grant ofExemption and Drone Solutions' Operations Manuals, the conditions and limitations inthe Grant of Exemption shall take precedence and must be followed. Otherwise, Drone Solutions shall follow the procedures outlined intheir Operations Manuals. 10. Drone Solutions may update orrevise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be provided to the Administratorupon request. Drone Solutions will also present anupdated and revised Operations Manuals ifit petitions for extension or amendmentto its Grant ofExemption. Ifan update orrevision would affect the basis upon whichthe FAA grants the exemption, Drone Solutions will seek an amendmentto its Grant ofExemption. Drone Solutions will contact the FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Drone Solutions Operations Manuals and its Grant ofExemptionwill be available to the PIC at the ground control station anytime the DSI-UAS is operating. 12. The PIC is prohibited from beginning a DSI-UAS flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly to the first intendedpoint of landing, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximumtotal flight time for each operational flight using the DSI-UAS will be limitedto 40 minutes orthe amount oftime the UAS can be flown and still maintain a reserve batterypower ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. Inthe eventthe structure being inspected exceeds 400 feetU.S Department ofTransportation October 27, 2015 Page 8 AGL, the UAS will not be operated more than 100 feet above the highest point onthe 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 otherthanthe PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the UAand/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures wherethe owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present anundue hazard, and;

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present anundue hazard to those persons per § 91.119(a). 16. The DSI-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 17. The DSI-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chartunless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required bythe Drone Solutions COA. The letter ofagreement withthe airport management will be made available to the Administrator uponrequest. 18. Priorto each flight the PIC shall inspect the DSI-UAS to confirmthat 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 inthe relevant sections ofthe operating documents as well as equipmentupdates. The PIC shall not operate any DSI-UAS ifthe inspection reveals a conditionthat affects the safe operation ofthe DSI-UAS until the necessary maintenance has beenperformed and the DSI-UAS is found to be in a condition for safe flight. The ground control station shall be included inthe preflight inspection. All maintenance and alternations must be properly documented in the UAS's records as required by Drone Solutions' Operations Manuals. 19. Drone Solutions will timely carry out its maintenance, inspections, and record keeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe DSI-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorizedpersonreturning the DSI-UAS to service.U.S Department ofTransportation October 27, 2015 Page9 20. Any DSI-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Drone Solutions' Operations Manuals. The PIC who conducts the functional test flight must make an entry inthe UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and DSI-UAS record entry shall be included in the Drone Solutions' Operations Manuals. 21. The DSI-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22. Priorto the operation, a Mission Packet will be created in accordance with the requirements on Drone Solutions' Operations Manuals. 23. Drone Solutions will obtain anAir Traffic Organization ("ATO") issued Certificate of Waiver orAuthorization, otherwise known as a COA, priorto conducting any operations underthis Grant ofExemption. ANOT AMwill be issued as required by the COA. All operations will be conducted in accordance with airspace requirements inthe ATO issued COAincluding class ofairspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe DSI-UAS loses communicationwiththe PIC, it will have the capabilityto safely return to a pre-determined location withinthe operational area and land safely. 26. Contingency plans will be inplace to safelyterminate flight ifthere is a loss of communicationbetweenthe PIC and the Observer. 27. The DSI-UAS will have the capabilityto 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 U.S. driver's license issued by a state. 29. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar DSI-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum ofhours pursuant to 14 CFR § 61.51(b) as UAS pilot operating the make and model ofDSI-UAS to be utilized for operations underthe exemption and three take-offs and three landing in the nreceolnP 90 Ol1VSU.S Department ofTransportation October 27, 2015 Page 10

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The DSI-UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including, butnot limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. DSI-UAS Operations under Instrument Flight Rules, at night, orbeyond VLOS are prohibited. 34. TheUAS will not be operated from an elevated platform unless designed and engineered specifically for such purposes and be incompliance with the general restrictions imposed by the applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevatedplatform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe DSI-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The FederalAviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 oftheAct, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest.3 Drone Solutions seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code ofFederal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconducting the requested operations using DSI-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H -Airworthiness Certificates and 14 C.F.R. §91.203(a)(l)

349 U.S.C. §44701(f) (authorizingthe grant ofexemptions from requirements ofregulations prescribedpursuantto Sections 44701(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § 11.81(e), whichrequires a petition for exemption to include: The reasons why granting the exemption wouldnot adversely affect safety, or howthe exemption wouldprovide a level ofsafety at least equal to that provided bythe rule from which you seek exemption.U.S Department ofTransportation October 27, 2015 Page 11 The FAAhas stated that no exemption is needed from this section ifa finding is made underthe ReformActthatthe UAS selected provides an equivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and in point offact exceeded, and therefore no exemption is needed. 5 If, however, the FAAdetermines that there are some characteristics ofthe chosen UAS that fail to meetthe requirements ofthe ReformAct, an exemption is requested. EquivalentLevelof Safety Drone Solutions'use ofthe DSI-UAS is safe whentaking into account its size, weight, speed, and operational capability. As set forth inthe description ofproposed operations in Section IV (A), the DSI-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of50 knots. The DSI-UAS is also equipped with safety features which will allow Petitionerto operate the DSI-UAS safely after experiencing certain in-flight contingencies orfailures as noted below. 6 7 Additionally, the DSI-UAS carries neitherpilots nor passengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively withinthe parameters stated in Drone Solutions' Operations Manuals. Operations conducted underthis exemptionwill be closely controlled and monitored by the PIC operator and will be conducted incompliance with local public safety requirements, to provide security for the area ofoperation. Drone Solutions will also provide the FAAwith advance notice ofall operations viaNOTAMs as required by the applicable COA. In all cases, operation ofthe DSI-UAS under the proposed conditions will be at least as safe as, or saferthan, conventional

5See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6See e.g., Grant ofExemptionNo. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI SlOOO] has the capabilityto operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety comparedto a manned aircraft performing a similar operation."

7See e.g., Grant ofExemptionNo. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): The DSI-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to commandthe system where to go, and the system does all the flying for the operator. The DSI-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones ormaximum flight ranges and altitudes so the system cannot enter areas deemed unsafe orunnecessaryto fly over. The petitioner states further thatthe UAS has built-in intelligent fault handling which allows the DSI-UAS to detect a system fault while in the air and automatically fly backto its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, makingthe system easyto navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioningbut a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as windthresholds are not exceeded.Also a flight termination link

- to prevent a 'fly away' or otherpotentially dangerous situation

- is available to the operator."U.S Department ofTransportation October 27, 2015 Page 12 rotorcraft operating with an airworthiness certificate. Lastly, the DSI-UAS do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the DSI-UAS. 8 In addition, no sense-and-avoid technology is necessary for the DSI-UASs because they will be operated at all times inVFR conditions and withinVLOS ofthe PIC and Operator. 9 B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extentthat Drone Solutions' small DSI-UAS would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for 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 Drone Solutions 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), CivilAircraft Flight Manual, Marking and Placard requirements, provides that: No personmay operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. 

### § 45.23(b), Markings oftheAircraft, states: Whenmarks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.

• 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by 

### § 45.23.

8See Grant ofExemptionNo. 11062 toAstraeus Aerial (FAA-2014-0352 atpg. 13).U.S Department ofTransportation October 27, 2015 Page 13 In a previous Grant ofExemption, the FAAdetermined that exemption from these requirements was warranted provided thatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 EquivalentLevelof Safety All DSI-UAS flown by Drone Solutions will bearN-numbermarkings that are as 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 Drone Solutions 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 to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (statingthat each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption from these regulations is needed because Part43 andthese sections only apply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption 

### willnothave. (Emphasis added) EquivalentLevelof Safety Anequivalent level ofsafety will be achieved or exceeded because maintenance and inspections will betimely performed in accordance withthe Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Drone Solutions' Operations Manuals, the PIC will conduct a pre-flight inspection ofthe DSI-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verifiedto address any conditions potentially affecting safe operation ofthe DSIUAS and no flights will occur unless, and until, all flight critical components ofthe DSI-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Drone Solutions' Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe DSI-UAS aircraft records ofthe flight. Drone Solutions' Operations Manual also includes requirements to follow 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, Drone Solutions' Operations Manuals also include procedures to document and maintain a record ofthe DSI-UAS's maintenance, preventative maintenance, alterations, status ofreplacement/overhaul component parts, and the total time in service ofthe DSI-UAS used under this Grant ofExemption. As a whole, the maintenance and

10. FAA DocketNo. FAA-2014-0352.U.S Department ofTransportation October 27, 2015 Page 14 inspectionprocedures required in Drone Solutions' Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved. PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations Drone Solutions seeks exemption from 14 CFR § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe private pilotis carrying passengers orcargo for hire. Inthis case, while the DSI-UASs will be operated as part ofa commercial operation, they carry neitherpassengers nor cargo. In the Grant ofExemptionto AstraeusAerial, the FAAdetermined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrantthe additional cost and restrictions attendant with requiringthe PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercialpilot would not lead to any additional safety benefits when UAS operations are involved. EquivalentLevelof Safety The restrictions Drone Solutions has placed on its DSI-UAS operations meet or exceed the restrictions similarly imposed onAstraeusAerial. Drone Solutions will operate onprivate property or approved location away from persons and property not involved inthe operation. Drone Solutions will also obtain anATO issued COApriorto conducting any operations under this Grant ofExemption. All operations will be conducted in accordance with airspace requirements inthe ATO issued COAincluding class ofairspace, altitude level and potential transponderrequirements. A NOTAM will also be issued as required bythe applicable COA. In additionto these flight restrictions, Drone Solutions will further ensure safe operationby requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also inthe unique aspects ofDSI-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only in DSI-UAS operations generally buthave logged flight time inthe specific make and model used for the operations before they are permitted to participate in commercial flights onbehalfofDrone Solutions. The pilot qualification, training, and currencyrequirements inthe Operations Manuals ensure that Drone Solutions pilots are competent and proficient in the DSI-UAS they are operating. Drone Solutions'training and qualification requirements are consistent withthose contained inprior FAA Section 33 3 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. OPERATINGPARAMETERS OFTHE UAS F. 14 C.F.R. § 91.7(a): CivilAircraftAirworthiness

12ExemptionNo. 11062 (FAA DocketNo. FAA-2014-0352).U.S Department ofTransportation October 27, 2015 Page 15 Inasmuch as there will be no airworthiness certificate issued for the UASs, Drone Solutions seeks an exemption from 14 C.F.R. § 91.7(a), whichrequires that a civil aircraft be in airworthy condition to be operated. The FAAhas stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent thatthe requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with SectionV (A), supra. G. 14 C.F.R. § 91.9(b)(2): CivilAircraft Flight Manual in theAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuantto 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) Forwhich anAirplane or Rotorcraft Flight Manual is required by§ 21.5 ofthis chapter, unless there is available inthe aircraft a current approvedAirplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuantto 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no personmay operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Giventhe small size and configuration ofthe DSI-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboard the DSI-UAS because there is simply no room and the DSI-UAS has no cabin or cockpit. As a way to comply withthe code Drone Solutions will maintain the documents withthe PIC and make them available for inspection. EquivalentLevelof Safety In an FAA Office ofChiefCounsel's Opinion datedAugust 8, 2014, and prepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledgedthatthe intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station

13See Id. at 13-14, 22.U.S Department ofTransportation October 27, 2015 Page 16 from which he or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety 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: PreflightAction Drone Solutions 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 inthe FAA-approved Flight Manual onboard 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 FAA-approved Flight Manual is required. EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the Drone Solutions' Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance with the Drone Solutions' 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 takeoffdistance, UA performance data, and contingency landing areas-before initiation offlight. Drone Solutions' 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 Drone Solutions seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinentpart that "[n]o personmay 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 throughthe use ofa device that communicates with the aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a). EquivalentLevelof Safety Giventhe size and speed ofthe UASs that Drone Solutions intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required by the Drone Solutions' Operations Manuals, all persons will be a safe distance away in the eventthat the UAS experiences any difficulties during flight instruction. Moreover, as required by the Drone Solutions' Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures

14 Memorandum from Mark Bury, FAAAssistant ChiefCounsel for International Law, Legislation andRegulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.U.S Department ofTransportation October 27, 2015 Page 17 provided for in Drone Solutions' Operations Manuals ensure that the proposed UAS operations provide an equivalent orhigher level ofsafety than that provided by the flight instruction regulations. J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes Drone Solutions requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from 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 operate at less than those minimum altitudes when it can be operated "without hazard to persons orproperty onthe surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed DSI-UAS operation will normally need to occur below 400 feet AGL. In circumstances where the DSI-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the DSI-UAS will not be operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may needto be less than 500 feet away from the DSI-UAS. EquivalentLevelof Safety Compared to flight operations withrotorcraft weighing far more thanthe maximum weights proposed herein, and giventhe lack offlammable fuel withthe above noted UASs, any risk associated with these operations is far less thanthose which presently exist with conventional aircraft. An equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe DSI-UASs, as well as the controlled location where the operations will occur. In orderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth inthe Operations Manuals, the DSI-UASs will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless thatperson is in a position where he or she is shielded from the DSI-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe DSI-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controllertimely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and, operations near the PIC or Observer will not present anundue hazardper§ 91.119(a). Adherence to these restrictions in

15Relieffrom § 91.119(a) will not be necessary because Petitionerwill be able to perform an emergency landing withoutundue hazard to persons orproperty on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15).U.S Department ofTranspmiation October 27, 2015 Page 18 Drone Solutions' Operations Manuals will ensure operations can be conducted without compromising public safety. 16 K. 14 C.F.R. § 91.121: Altimeter Settings Drone Solutions seeks an exemption from 14 C.F.R. § 91.121, whichrequires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is setto the elevation ofthe departure airport or barometric pressure. An exemption is required to the extentthat the UASs do not have a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAAhas statedthat an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 canbe achieved in circumstances where: (1) the UAS will be operated below 400 feet AGL or below17

, (2) withinVLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiationpoint is established for the PIC to confirm accuracy ofthe onboard GPS. 18 The DSI-UAS that Drone Solutions intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Drone Solutions' Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, the DSI-UAS Drone Solutions intends to use, and the safety mitigationprocedures contained in the Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemptionto the requirements of§ 191.121 is therefore appropriate. L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Drone Solutions requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight inVFR conditions. Section 91.151 states:

16See e.g., Grant ofExemptionNo. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbaniers or structures are presentthat can sufficientlyprotect nonparticipating persons from the UA or debris in the event ofan accident, then the UA may operate closerthan 500 feet to persons afforded suchprotection. The operatormust also ensure that nonparticipatingpersons remain under such protection. Ifa situation arises where nonparticipatingpersons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipatingpersons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures whenthe owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closerto those objects and determines that it does notpresent an undue hazard."

17Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operatedmore than 100 feet above the highestpoint onthe structure.

18See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation October 27, 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 to the first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations on UAS battery power means that no meaningful flight operations canbe conducted while still maintaining a 30-minute battery reserve. Anexemption from the fuel requirements of 14 C.F.R. 

### § 91.151(a) is therefore required. Moreover, it is not Drone Solutions' intention to fly the DSI-UASs at night. 

### EquivalentLevelof Safety Inthe Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafetyto the fuel requirements for flight inVFR conditions could be achieved byprohibiting the PIC from beginning a DSI-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intended point oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. Inreaching this conclusion, the FAAconsidered thatthe UAS batteries for the DSI-UAS provide approximately 50 minutes ofpowered flight (withpayload) and providedbattery level and battery time remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the DSI-UAS operating manual states: "startevery flight with a fully charged battery inthe aerial vehicle", and that in the eventthatthe DSI-UAS shouldrun low onpower, the PIC will be alerted and can safely land the- DSI-UAS as soon as possible. Like theVDOS Grant ofExemption, Drone Solutions' use ofthe DSI-UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and in fact exceeded. Similarly, inthe Grant ofExemptionto Alan Purwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved by prohibiting the PIC from beginning a flight withthe UAunless (considering wind and forecast weather conditions), there was enough powerto safely fly at normal cruising speedto the intended landing point and land the UAwith 25% battery power remaining. Drone Solutions will adhere to this limitation for its DSI-UAS flights. The DSI-UAS includes a lowbattery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the DSI-UAS to a ground-based-on-screen display. 20 As required by Drone Solutions' Operations Manuals, the PIC will promptly fly the DSI-UAS backto the home launch location or pre-determined abort location where it may safely land, while still maintaining a minimum of 25% reserve battery power. Drone Solutions submits that the procedures requiring flights to be

19. Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 20. The DSI-UAS ground control station displays the UAS's position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculatedtargetposition, date/time, and sensorheading and orientationrelative to the UAS.U.S Department ofTransportation October 27, 2015 Page 20 safely terminated once the batteries fall below 25% capacity, combined withthe requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and withinVLOS ofthe PIC and Observer(s), ensure that the proposed operation will provide an equivalent or higher level ofsafety to the public to that provided by the regulations from which exemption is sought. 

### VI. DRUGAND ALCOHOL PROGRAM Drone Solutions will have policies inplace to ensure that no person may participate in DSI-UAS flight operations ifthey are underthe influence ofalcohol or any drug. 

### VII. PUBLIC INTEREST The public interest will be served by granting Drone Solutions' Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS incontrolled, safe working environments such as those proposed inthis Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-theFAAAdministrator's assessment ofwhether certainUAS may operate safely inthe NAS before completion ofthe statutorily required rulemaking. The proposed DSI-UAS operations inthis Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermission was granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who maybe inthe local vicinity. Traditional methods ofinspecting and monitoring potential locations and relevant sites and facilities requires locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk ofserious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used inthe endproduct. The use ofsmall UAS can eliminate these hazards and ultimately create a much safer method of performing these types ofinspections creating a safer environment for the public as well as Drone Solutions employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in additionto flammable fuel, the UAS carry no passengers, crew orexplosive fuel. Furthermore, in the unlikely event of an accident, Drone Solutions' small battery powered DSI-UAS presents significantly less danger to persons onthe ground when compared to operations byconventional manned aircraft.21 As

21See Grant ofExemptionNo. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds ormore and are operated by an onboardpilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will weigh less than 55 pounds with no onboardpilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals orproperty in the event ofan incident or aceident. Riskto an onboard pilot and crew during an incidentor accident is eliminated with the use ofa UA for the aerial .C.:l--....:-..-

....._ ....._ .........: ........... "U.S Department ofTransportation October 27, 2015 Page 21 Petitioner's DSI-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing inthe same functions proposed herein. Air quality will naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAA in prior Section 333 Grants ofExemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft. 22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the currentUAS industry and provide additionaljobs 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 ofproduction; therefore, given the lower cost, owner/operators and others inthe relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All DSI-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate 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 inthe FEDERALREGISTER, should it be determined thatpublication is needed: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal 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) (1); 91.409(a) (1) & (2); 91.417 (a) & (b). The exemption will enhance safety byreducing 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 productionwith conventional fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Drone Solutions' Petition for Exemption satisfies the criteria articulated in Section 333 ofthe ReformAct of2012 which includes weight; speed; operating capabilities; proximity to airports and populated areas; operationwithinVLOS and national security. The proposed DSI-UAS

22See e.g., Grant ofExemptionNo. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation October 27,2015 Page 22 operations will benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendantrelated costs thereby increasing the demand for the finished product. In consideration ofthe foregoing, this Petition for Exemption provides the FAA with more than adequatejustification for granting the requested exemptions allowing Drone Solutions to use small DSI-UAS sinthe recorded production ofits product. We thank you for your prompt consideration ofourrequested exemptions. Respectfully Submitted,

# An~~6bz- DSI Drone Solutions and Imaging 19093 E. Bates Ave. Aurora, CO 80013 Phone: 720.675.0574 Email: danda34@comcast.net (The following attached items contain proprietary and commercial information exempt from disclosure under the Freedom ofInformationAct, 5 U.S.C. 

### § 522 et seq., and should be held in a separate file pursuant to 14 C.P.R. § 11.35(b)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals