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MARK A. DOMBROFF 703.336.8700 EMAIL ADDRESS mdombroff@mckennalong.com

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 October 15, 2014

Re: DocketNo. FAA-2014-0610: Supplementto Petition ofTotal Safety U.S., Inc. for Exemption Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 Dear Gentlemen: On October 8, 2014, the Federal Aviation Administration informed Total Safety US, Inc. ("Total Safety") thatthe petition ofAstraeus Aerial had been granted, and invited Total Safety to submit any additional information in support ofthe petitionthat was appropriate in light ofthis new guidanec from the FAA. Accordingly, Total Safety submits the following supplement to its Petition for Exemption. I. 14 CFR § 61.113: Private Pilot Privileges And Limitations Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation orhire, and which would also have the effect ofrequiring a second class medical certificate. The purpose ofPart 61 is to ensure the skill and competency ofany PIC matches the airspace inwhichthe PIC will be operating and the types ofoperations being flown. Inthis case, while the UAS will be operated as part ofa commercial operation, it carries neither passengers nor cargo. Inthe Grant ofExemption inFAADocketNo. FAA-2014-0352, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the addition cost and restrictions attendant withrequiring a the PIC to have a commercial pilot certificate and class II medical certificate.U.S. Department ofTransportation October 15, 2014 Page 2

Total Safety will employ licensed private pilots as PIC for their operation. The restrictions Total Safety has placed on its UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial inFAA DocketNo. FAA-2014-0352. Flare stack inspections occur in refineries or other areas where access to the public is strictly limited and controlled. Under virtually all circumstances, all ofthe only property or structures near the flare stack are owned and operated by the same entity. As a result, the operation has no substantial impact on any third persons not involved in the inspection. In addition, unlike the film makers in FAA DocketNo. FAA-2014-0352, the UAS does not need to be operated in close proximityto persons and vehicles. Because Total Safety will operate in a sterile area, the UAS will be flown based on visual line-of-sight at altitudes below 400' AGL, and a NOT AM will be issued priorto any flight, the requested exemptionprovides an equivalent level ofsafety to any requirement for a commercial pilot's certificate. Accordingly, Total Safetyrequest that this exemption be granted. Ifyou have any questions orrequire any additional information, please do not hesitate to contact us.