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12 May 2015 MSgt Kevin Adkins USMC (Ret) President Crossview Concepts Corporation, Inc. 1986 James Gaynor Street Fallbrook, CA 92028 C: (760)645

- 5215 kadkins@crossview

- concepts.com
U. S. Department of Transportation Docket Operations 1200 New Jersey Ave., SE Washington, DC 20590
Subj: **AMENDMENT FOR APPLICANT PETITION DOCKET COMMENT TRACK NO .**  **1jz -** **8ien -** **tpi1** FOR CROSSVIEW CONCEPTS CORPORATION, INC. SECTION 333 SUBMISSION TO FAA FOR A PPLICATIONS/PETITIONS/EXEMPTIONS AND ANY OTHER ITEMS FOR WHICH A DOCKET DOES NOT EXIST.
Ref : Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21;14 CFR 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) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).
Sir or Madam, The initial Section 333 petition by the applicant (here after “Crossview Concepts Corporation”) was submitted on 19 Apr 2015 and this correspondence is an amendment of the original submission with identifier Comment Track No. 1jz

- 8ien

-tpi1

. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Crossview Concepts Corporation, Inc., an operator of Sma ll Unmanned Aircraft Systems (“sUAS”) equipped to offer on

- demand commercial s UAS operations for a host of industries and applications similar to the approved Section 3 3 3 Exemption No. 11251 AirRaids Aerials, LLC. These applications include:
• Aer ial search and rescue operational support • Infrastructure inspection • Agricultural monitoring and support • I ndustrial refinery and manufacturer plant inspection • Accident/Incident survey and investigative support • Flare stack inspection • Private security monitoring • Utility

- power generation system inspections and patrollingPage 2 of 11

• Pipeline inspection and patrolli ng • Filmmaking, cinematography, and videography • Wildlife and forestry monitoring • Aerial surveying and mapping • Construction site inspection and monitoring • Public Entity Support Operations
• Maritime aerial operations
• Reality and wedding videography and imagery
• sUAS consulting Crossview Concepts Corporation, Inc. hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to all ow commercial operation of its sUASs, so long as such operation s are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333 . To include, FAA Certificate of Waiver or Authorization (COA) that are issued to Crossview Concepts Corporation, Inc.
As described below, the requested exemption would permit the operation of green minded sUASs relatively inexpensive ly under controlled conditions in the N ational A irspace System (NAS) that is 1) limited , 2) predetermined, 3) controlled s UAS access a nd operati on, and 4) would provide safety enhancements to the already safe operations using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. The name and address of the applicant is: Crossview Concepts Corporation, Inc. Attn: Kevin Adkins 1986 James Gaynor Street Fallbrook, California 92028 Ph: (252) 626

- 6335 Email: kadkins@crossview

-concepts.com Regulations from which the exemption is requested:
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1)Page 3 of 11

14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pos e a threat to national security in light of the following: • The UAS’s size, weight, sp eed, and operational capability • Operation of the UAS in close proximity to airports and populated areas • Operation of the UAS within visua l line of sight of the operator Reform Act Section 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system .” Id. Section 333(c) (emphasis added) Applicant interprets this provision to place the duty on the Administrator to not only process app lications for exemptions under S ection 333, but for the Administrator to craft conditions for the safe operation of th e UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms incl udes exempting civil aircraft, as the term is defined under § 40101 of the Act that includes SUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) ( 1). Crossview Concepts Corporation, Inc. s UASs are vertical take

-off and landing (VTOL) rotary
-winged air vehicles (AV) and fixed

-wing AV, weighting 55 lbs or less including payload. They operate, under normal conditio ns at a speed of no more than 87 knot s ( 100 MPH), operation not to exceed manufacturer recommended airspeed, and have the capability to hover and move in the vertical and horiz ontal plane simultaneously. The sUAS assets will operate only in line of sight and will operate only within a sterile area. Such o perations will insure that the s UAS will “not create a hazard to users of the national airspace system or the public.” Reform Act Sectio n 333 (b). Given the small size of the s UASs involved and the restricted sterile environment within which they will operate, the appl icant falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also , due to the size of the UASs and the restricted areas in which the relevant s UASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs, the gran t of the requested exemptions is in the public interest.Page 4 of 11

This exemption would be in concert with the current FAA Rule making Committee’s Small UAS Rules Proposal and the Modernization Act. The FAA decision to grant this exemption would eliminate the exemption request of 14 C.F.R. § 1.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. **AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The applicant intends to operate the following aircraft with this submitted exemption : 1. DJI Inspire 1 2. DJI Spre ading Wings S1000 and S900 3. DJI Phantom 2 4. DJI Phantom 3 5 . Aeryon Sky Ranger 6. 3DR X8

- M and Solo 7. Prioia Hex and Maveric 8. Hoverfly LiveSky, BigSky 60, and H

- Frame 9. Physical Sciences Instant Eye 10. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter, and x12 Copter 11. InovaDrone: Inova One 12. R/C Rotors and Aerial Media: Matrix Prof. Mutli Rotor Frame & Octo Heavy Lift Prof. Multi Rotor Frame Ronin Edition 13. Microdrones: MD4

- 1000 The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conducted with conventio nal aircraft. These limi tations and conditions to which Crossview Concepts Corporation, Inc. agrees to be bound when conducting commercial operations under an FAA issued exemption include:
1. The s UAS will weigh less than 55 lbs. 2. Flights will be ope rated within visual line of sight (VLOS) of a vehicle operator (VO) and/or observer. 3. Maximum total flight time for each operational flight will not exceed the capabilities and limitations of the s UAS type operated per manufacture specifications and rec ommendations . Flights will be terminated at no less than 1 5% battery power reserve during any flight to ensure Safety of Flight (SOF)

. 4. Day flights will be operated at an altitude of no more than 4 00 feet AGL

. 5. Range of operation and altitude shall be decreased when operating in close vicinity of airfields that are not controlled by air traffic control (ATC) in Class G airspace . Where airfields are controlled by ATC or other forms, coordination and permissive operations shall be coordinated with th e appropriate airspace control authority (ACA), i.e. Class B, Class C, Class, D, and Class E airspace. Clas s A airspace shall be avoided unless specified in an authorized COA

. Operation under Class E airspace and imposing a self

imposed safety buffer bel ow the Class E airspace shall only be conducted after proper coordination with the Class E airspace ACA. Safety buffers shall be reasonable and flights shall be c ancelled if Safety of Flight (SO F) is ever a concern by the ACA or of the s UAS VO. The UA sh all not operate within 5 nauticalPage 5 of 11

miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management shall be made available to the Administrator or any law enforcement official upon request. 6

. Minimum crew for each operation will consist of the s UAS vehicle operator (VO) . If visual line

-of

sight ( V LO S) is an issue during s UAS flight operations, an observer shall be utilized. When operating specific s UAS air vehicles during specific missions, a Payload Operator (PO) shall be a part of the aircrew. Specific sUAS operations may require a minimum of two aircrew personnel in order to s epa rate duties as a VO/PIC and a censor (payload) operator. 7. s UAS VO shall be trained and certified in the s UAS type operating and have visual acuity, correctable by glasses or contacts, of 20/20 and not be color blind

. 8. s UAS VO shall perform as the Pilot in Command (PIC) duties an d be responsible for the s UAS SO F

. C onsideration to obstacle s, safe launch/recovery area, LO S, s UAS capabilities and limitations, s UAS Operational Brief, pre/post flight operations, and Crossview Concepts Corporation, Inc. imposed airspace control measures and procedures shall be adhered to when directed by the company Director of Safety on a case

- by

- case basis when the mission is analyzed , i.e. mandatory ascending/descen ding Elevator P oints, Emergency Holding Points, etc. 9. A s UAS flight path shall never be programmed or manually operated to fly over another s UAS launch/recovery site and/or Ground Control Station (GCS) without prior communication with the other aircrew and not below sUAS manual identified separation altitudes compliance

. 10. Multiple s UAS launch/recovery sites shall ensure that s UAS VOs coordinate through positive communication during s UAS operations and shall stagger AV la unches and landings to ensure SO F. Positive communication means uninterrupted means of communication, i.e. Part 15 hand

- held radios, Motorola han d

- held radios, and other means of two

-way radios or voice systems and devices. Texting will never meet the positive communication requirement. 11

. The s UAS will only operate within a n identified confined “Sterile Area” of the flight operations area

. Area shall be surveyed by the aircrew prior to s UAS operational flight commencement. s UAS operations with in the aforementioned operations area shall not commence unless, if applicable, required ACA coordination has been completed, agreed upon, and authorized. 12

. A s UAS brief shall be cond ucted in regard to the day’s planned s UAS operatio ns . sUAS Brief shall be conducted before sUAS flight operations commence. The s UAS Brief is manda tory and all participating personnel who will be performing duties within the boundaries of the safety perimeter shall be present for this briefing. 13

. The operator shall obtain the consent of all persons involved and ensure that only consenting pe rsons will be allowed within 75 feet (25 meters) radius of the SUAS launch/recovery site (GCS); the radius may be reduced to 30 feet (10 meters) based upon an equivale nt level of safety and environment conditions and restrictions determination by the s UAS VO (PI C)

. 14. s UAS VO shall maintain current proficiency in all s UAS type that they are certified with. 15

. During all s UAS operations, where an observer is utilized, positive communication shall be maintained between the s UAS VO and the observer. 16

. Written and/or oral permission from th e relevant property holders shall be obtained. 17

. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate gove rnmental agencies when applicable

.Page 6 of 11

18. If the s UAS is the subject of a Loss o f Link (LOL) emergency or a GPS Loss emergency, the s UAS will have the capability to return to a pre

- determined location within the operating are a, i.e. manual control, and /or la nd safely, i.e. “land immediately” feature or similar. 19. The s UAS will have the capability to abort a flight in case of e mergencies and the VO shall conduct established Crossview Concepts Corporation, Inc. Emergency Procedures and manufacturer established emergency procedures. 20. All s UAS incidents that involve death, injury, damage to equipment (other than the company owned s UAS ), and damage to property (other than company owned) shall be reported appropriately. 21. “Right of way” shall alwa ys be given to all other manned and unmanned air vehicles in every scenario and event without exception. Special consideration shall always be granted in every event that requires actions that would prevent death of injury of any person. 22. Crossview Co ncepts corporation, Inc., on the behalf of the s UAS VO, shall submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction o ver the area of proposed sUAS operations

. It is understood that the 3

- day notificatio n may be waived with the concurrence of the FSDO. The plan of activities shall include at least the following: a. Dates and times for all flights. b. Name and phone number of the vehicle operator (VO) for the s UAS conduct ing the sUAS operation under this grant of exemption. c. Name and phone number of the person responsible for the on

- scene operation of the s UAS

. d. Make, model, and serial or N

- Number of s UAS to be used e. Name and certificate number of s UAS vehicle operator (VO)/pilot in command ( PIC ) involved in the sUAS operation

. f. A statement that the VO has obtained permission from property owners and/or, if applicable, local officials to conduct the filming production event; the list of those who gave permission shall be made availabl e to the i nspector upon request. g. Signature of exempti on holder or representative. h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as require d by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of t he Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capa bility, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the s UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed

-wing or rotary
-wing ) operating with an airworthiness certificate without the restrictions and conditions proposed. The s UAS to be operated hereunder is less than 55 lbs. full y loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and opera tes exclusively within a safe area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly co ntrolled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming d uring filming services

. I n regard to motion picture and television production, security of the filming location adds to and provide s a greater degree of safety to the publicPage 7 of 11

and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. This type of local operations area security is also found within the industrial and manufacturing areas, specific national, state, local, and privately controlled areas, and during local emergencies tha t are supported. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the s UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. The FAA has issued the following Exception No. 11251. **14 C.F.R. §45.23 (b). Marking of the Aircraft**
**.** The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally 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. Even though the SUAS will have no airworthiness certificate, an exemption may be needed as the s UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the s UAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §4 5.29 (f). The equivalent level of safety will be provided by having the S UAV marked on its fuselage as required by §45.29 (f) where the s UAS air vehicle (AV) vehicle operator (VO) , AV visual observer, and others working with the sUAS will see the identifi cation of the s UAS as marked appropriately with registered aircraft markings. Each Crossview Concepts Corporations, Inc. s UAS air vehicle shall be registered with the FAA and the FAA aircraft registration number shall be placed on the air vehicle in the l argest practicable manner

. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 , 11251, and 10167A. **14 C.F.R. §1 .113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in**  **Command.** Section 61.113 (a) & (b) limit private pilots to non

- commercial operations **.** Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’ s license to operate this s UAS

. Unlike a conventional aircraft that carries the pilot and passengers, the s UAS is remotely controlled with no living thing on board. The area of operation is control led and restricted, and all flights are planned and coordinated in advance. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associ ated with the operation of the s UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the s UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). The FAA has issued the following Exception No. 11251. **14 C.F.R. §91.7(a): Civil aircraft airwo rthiness.**  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 FAA regulatory standard will exi st for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections (j) , (l) and (q) , an equivalent level of safety will be provided. The FAA has issued the following Exception No. 11251. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.**  Section 91.9 (b) (2) provides:Page 8 of 11

“ No person may operate a U.S.

- registered civil aircraft...” (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless it is available in the aircraft, a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The s UAS, g iven 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 on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of sa fety will be maintained by keeping the flight manual at the GCS within the reach of the s UAS vehicle operator for immediate access. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 11251, and 10700. **14 C.F.R. § 91.103: Preflight action**  **.** This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The s UAS vehicle operator will take all actions including reviewing weather, flight battery requirements, launch paths and landing approaches, a nd aircraft pre -flight check parameters and data before committing to a AV Launch

. The FAA has issued the following Exception No. 11251. **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. s UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of the GCS Hand Controller Unit (HCU) th at communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. The FAA has issued the following Exception No. 11251. **14 C.F.R. §91.119: Minimum s afe altitudes**  **.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or al titudes prescribed for helicopters by the FAA. As this exemption is for a s UAS that is for not only s UAS fixed

-wing AVs, but also SUAS rotary
-winged ( helicopter ) and the exemption requests authority to operate at altitudes up to4 00 AGL, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the s UAS wil l never operate at higher than 400 AGL unless authorized by a COA or the published FAA rules for s UAS scheduled to be published in 2015. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required ACA coordination, permission of the property owner or local offi cials, and other unforeseen requirements that may arise. Due to the advance notice to the property owner and participants in the aerial activity, all affected individuals will be aware of the planned s UAS flight operations. Compared to flight operations with aircraft or rotorcraft, weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or belo w 40 0 AGL other industries. In addition, the low

- altitude operations of the SUAS will ensure separation between these s UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has issued the following Exception No. 11251. **14 C.F.R. §91.121 Altimeter Settings .**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departurePage 9 of 11

airport or an appropriate altimeter setting available before departure.” As the s UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the s UAS vehicle operator, purs uant to the Manual and Safety Check list, confirming the altitude of the launch /recovery site shown on the GPS altitude indicator before flight. The FAA has issued the following Exception No. 11251. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in V** **FR Conditions .**  Section 91.151 (a) prohibits an 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 of intended landing, and, assum ing 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 battery powering the s UAS provides set flight endurances for each s UAS type
. To meet the 30

- minute reserve requirement in 14 CFR §91.151, s UAS flights would be extremely limited or not be able to fly at all. Given the limitations on the s UAS’s proposed flight area and the location of its proposed operations within a predetermined are a, a longer time frame for flight in daylight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate withou t compliance with FAR 91.151 (a)). Operating the s UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engende r the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sma ll UAS. Additionally, limiting s UAS flights to extreme minimum flight time would greatly reduce the utility for which the exemption will be granted. Applica nt believes that an equivalent level of safety can be achieved by limiting flights to the manufacture’s flight endurance specifications and self

- imposing minimum reserve battery life to force a controlled landing safely without exceeding the manufacturer’s maximum flight endurance specifications. This restriction would be mo re than adequate to return the s UAS to its planned launch/recovery site from anywhere within its limited operating area. Similar exemptions have been granted to other operations, inclu ding Exemptions 2689F, 5745, 10673, 11251, and 10808. **14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration**
**.** The regulation provides in pertinent part: (a) Except as provided in Section 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 cabin or cockpit entrance so that it is legible to passengers or crew. The s UAS, fully loaded, weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the SUAS

. An equivalent level of safety will be achieved by keeping these documents at the GCS where the s UAS vehicle operator operating the AV will have immediate access to them, to the ext ent they are applicable to the s UAS . The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 11251, and 10700. **14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections** 
**.** These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that the se section s and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to thePage 10 of 11

applicant. The operator pursuant to the flight manual and operating handbook will accomplish maintenance. An equivalent level of safety will be achieved due to the nature of these s UASs based on their sized and will carry a small payloa d and operate only in observed controlled areas for limited periods of ti me. If mechanical issues arise , the SUAS can land immediately and will be operati ng from no higher than 400 feet AGL unless otherwise authorized through a FAA COA

. T he operator will ensure that the s UAS is in working o rder prior to initiating flight and perform required operator maintenance . Major maintenance events beyond basic operator maintenance shall be recorded in the s UAS equipment record jacket maintained by the applicant

. Moreover, the vehicle operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has issued the following Exception No. 11251. **Summary** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(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); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned aircraft vehicle ( SUAS ) (55 lbs

. or less). Approval of exemptions all owing commercial operations of s UASs, will enhance safety by reducing risk while operating within the NAS

. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subjects being filmed or equipment being inspected and in extreme proximity to people and stru ctures and present the risks associated with vehicles that weigh in the neighborhood of 4,000 lbs, carrying large amounts of J et A, JP

-8 or other fuel. Such aircraft must fly to and from the operational location. In contrast, a s UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The s UAS is carried to the operation site and not flown. The SUAS will carry no passengers or crew and, therefore, wi ll not expose them to the risks associated with manned aircraft flights. The operation of s UASs, weighting less than 55 lbs., conducted in the strict conditions aforementioned , will provide an equivalent level of safety supporting the grant of the exempti ons requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment ; resulting in a far safer air vehicle flight than conventional aircraft operations utilizing combustible fuels and rotating blades operating within close proximity to the g round, personnel, and equipment during filming and inspections. Crossview Concepts Corporation, Inc. has every i ntention to adhere to and comply with established policies, rules, guidelines, and established laws. **Privacy** Privacy of personnel and property shall be adhered to. No person shal l be surveilled unless proper authorization is provided by the appropriate authorizing agency or organization in accordance with established intelligence oversight practices and in compliance with all applicable regulations, orders, publications, and/or pol icies. All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge , unless the area is deemed a public area

. Navigational imagery may be used to support incident/mishap reporting as applicable. Only imagery supporting the purpose of the s UAS operational flight shall be utilized for the appropriate purpose. Commercial Film and TV filming events will be of people who have also consented to being filmed or otherwise have agreed to be in the area w here filming will take place. All s UAS operations shall be conducted inPage 11 of 11

consideration to the direction to government entities set forth in the Presidential Memorandum, Promoting Economic Competitiveness While Safeguarding Privacy, Civil Rights, and Civil Liberties in Domestic Use of Unmanned Aircraft Systems (February 15, 2015). The grant of this exemption request will provide improved safety in both day and low

- light operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing comme rcial operation of applicant’s commercial and private s UAS

.

Respectfully,

Kevin Adkins President Crossview Concepts Corporation, Inc. Small Unmanned Aircraft Systems ( SUAS ) Service Provider