1

July 1 7 , 2015

Dear Sir or Madam,

Brasfield & Gorrie, L.L.C., hereby submits to the Federal Aviation Administration, pursuant to the FAA Modernization and Reform Act of 2012, an exemption petition, in accorda nce with section 333 of the
Act.

Brasfield & Gorrie, L.L.C. Background

Recently celebrating our 50 th anniversary, Brasfield & Gorrie has marked 2015 as the year we achieved our goal of obtaining the ranking of Best General Contractor as announced by the Associated Builders
and Contractors

. Brasfield & Gorrie is one of the largest privately held construction firms in the nation. Our mission is strengthening relationships by honoring commitments, exceeding expectations, and living our values every day. Brasfield & Gorrie owes its success to its people . The company founders established a reputation for unwavering quality and integrity, and those values remain the bedrock of our business philosophy today. Because safety is our top priority, it is also our top corporate value. We
strive to be the safest general contractor in every market we serve, and we are committed to ensuring the safety of our employees, clients, and associates. Our “THINK Zero!” safety initiative reflects our goal of zero incidents on all our projects. Our company website, Brasfiel dGorrie.com, houses a wealth of information pertaining to the scope of work we conduct.

Purpose for the Exemption

Brasfield & Gorrie is interested in utilizing an unmanned aircraft system (UAS) to conduct surveys, inspections, and photography of our jobsit es and client facilities.

Point of Contact Information

Timothy Eichelberger

Chief Pilot Brasfield & Gorrie 3021 7 th Ave South Birmingham, AL 35233 Mobile (205) 249

- 9706 Office (2050 714

- 1842 Email: TEichelberger@brasfieldgorrie.com2

TERMS OF REFERENCE:

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United States Code (49 USC) § 40102)

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities

, equipment and services, airports or landing areas; aeronautical charts, information and services; rules, regulations and procedures, technical information, and manpower and material

3. Operational Control: with respect to a flight, means the exercise of authority over initiating, conducting or terminating a flight (14 CFR § 1.1)

4. Pilot in Command (PIC): the person who has final authority and responsibility for the operation and safety of the flight; has been designated as PIC before or during the flight; and holds the appropriate category class and type

- rating, if appropriate, for the conduct of the flight (14 CFR § 1.1)

5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct human
intervention from within or on the aircraft (P.L. 112

- 95, Section 331)

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, including communication links and the components that control the unmanned aircraft, that are required for the pilot in command to ope rate safely and efficiently in the national airspace system (P.L. 112

- 95, Section 331)

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic Organization to an operator for a specific unmanned aircraft activity

8 . Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual contact between a pilot in command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground3

List of Specific Sections of 14 CFR for which exemption is sought:

Petitioner : Brasfield & Gorrie L.L.C.

- 61.23(a) and (c)

- 61.113(a)

- 91.7(a )

- 91.103(b)(2)

- 91.105

- 91.109

- 91.119(c)

- 91.121

- 91.151(a)(1)

- 91.405(a)

- 91.407(a)(1)

- 91.409(a)(1) and (2)

- 91.417(a) and (b)4

Expanded 14 CFR sections exemption is requested and why:

§61.23(a) and (c) Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person

— (1) Must hold a first

- class medical certificate: (i) When exercising the pilot

- in

- command privileges of an airline transport pilot certificate; (ii) When exercising the second

- in

- command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or (iii) When serving a s a required pilot flightcrew member in an operation conducted under part 121 of this chapter if the pilot has reached his or her 60th birthday. (2) Must hold at least a second class medical certificate when exercising: (i) Second

- in

- command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or (ii) Privileges of a commercial pilot certificate; or (3) Must hold at least a third

- class medical certificate

— (i) When exercising the privileges of a private pilot certificate; (ii) When exercising the privileges of a recreational pilot certificate; (iii) When exercising the privileges of a student pilot certificate; (iv) When exercising the privileges of a fl ight instructor certificate and acting as the pilot in command; (v) When exercising the privileges of a flight instructor certificate and serving as a required pilot flight crewmember; (vi) When taking a practical test in an aircraft for a recreational pil ot, private pilot, commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or (vii) When performing the duties as an Examiner in an aircraft when administering a practical test or proficiency check for a n airman ce rtificate, rating, or authorization. (c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person must hold and possess either a medical certificate issued under part 67 of this chapter or a U.S. driver's license when

— (i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in a light

- sport aircraft other than a glider or balloon; (ii) Exercising the privileges of a sport pilot certificate in a light

- sport aircraft other than a glide r or balloon; (iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while acting as pilot in command or serving as a required flight crewmember of a light

- sport aircraft other than a glider or balloon; or (iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot certificate in a light

- sport aircraft other than a glider or balloon. (2) A person using a U.S. driver's license to meet the requirements of this paragraph must

— (i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and any judicial or administrative order applying to the operation of a motor vehicle; (ii) Have been found eligible for the issuance of at least a third

- class airma n medical certificate at the time of his or her most recent application (if the person has applied for a medical certificate); (iii) Not have had his or her most recently issued medical certificate (if the person has held a medical certificate) suspend ed

o r revoked or most recent Authorization for a Special Issuance of a Medical Certificate withdrawn; and (iv) Not know or have reason to know of any medical condition that would make that person unable to operate a light

- sport aircraft in a safe manner.

Bra sfield & Gorrie requests exemption based on:

- Medical requirements do not, currently, provide guidance for the operator (PIC) of UAS. However, PIC
of Brasfield & Gorrie operated UAS will hav e at least current third class medical certification

.
Level of safety retained:

PIC will be required to have a current third class medical to operate the UAS which aligns with the private pilot requirement s.5

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensa tion or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

Brasfield & Gorrie requests exemption based on:

- The UAS Brasfield & Gorrie intends to operate is the DJI Inspire. It weighs less than 6.5 lbs. , cannot exceed 50 mph of forward flight, cannot carry cargo or passengers, and is limited to 13 min flight time. In addition to these parameters, the airspace in which the DJI Inspire will operate will be that which
does not interfere with other air traffic. How ever, t he PIC will have full authority and responsibility

tow ards the safe operation of the UAS missions. The PIC will have logged training flights that include emergency, evasive, and high wind procedures to ensure mission safety.

Level of safety retained:

A private pilot is trained extensively on visual flight rules which are the whole environment in which the
UAS will operate. Besides UAS operation , n o additional training would be required to achieve the safety and preflight planning that a higher certificate would enable, such as a commercial or airline transport
certificate.6

§91.7 Civ

il aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

Brasfield & Gorrie requests exemption based on:

- While no airworthiness certification exists for the DJI inspire, the UAS is flight tested prior to release to the public as well as all FCC considerations and regulations met. PIC preflight action prior to each flight will be mandatory to ensure safe operation is possible. Manufacturer guidelines as well as Day VFR flight rules and other atmospheric condition requirements will provide go/no

- go decision making
information

. By limiting our operation to this equipment, we feel retains the intent of the testing and validation that an airworthiness certificate provides.

Level of safety retaine d:

The DJI Inspire is a mass produced, heavily tested product that has position, control, and communication redundancy. The flight path will not be over persons on the ground. The UAS would be the same unit
that the PIC and VO train on in various scenarios so flight characteristics would be a known q uantity before actual missions take place.7

§91.103 Preflight action.

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Brasfield & Gorrie requests exemption based on:

- While Brasfield & Gorrie UAS operations will abs olutely include extensive preflights prior to flight, items listed in this regulation such as “runway slope”, “airport of intended use”, and “aircraft gross weight” do not have direct applicability.

Level of safety retained:

Preflight action to retain the level of safety intended by this regulation will include site analysis as it relates to the predetermined flight path. Jobsite leadership will be contacted to plan the UAS flight path as well as emergency and escape routes. The UAS will be inspected pri or to flight in accordance with the manufacturer’s recommended procedure. VFR weather minimums will be considered prior to flight and a no go decision will be made if assurance of cloud and visibility clearance restrictions are not possible.8

§91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while en route, each required flight crewmember shall

— (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of th e aircraft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her should er harness fastened while at his or her assigned duty station. This paragraph does not apply if

— (1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be unable to perform required duties with the sh oulder harness fastened.

Brasfield & Gorrie requests exemption based on:

- The DJI Inspire 1, which Brasfield & Gorrie intends to operate has a total weight of less than 6 lbs. and is incapable of carrying any crew members onboard. Flight Crew, as it rel ates to this regulation, will consist of a Pilot in Command (PIC) and a Visual Observer (VO).

Level of safety retained:

It is the intent of this regulation to ensure that flight crew members are in a position to immediately conduct emergency procedures and maintain constant positive control of the aircraft. With the flight crew of the UAS consisting of a PIC and VO, the PIC will be able to maintain constant positive control of the UAS with verbal cues from the VO as well as the VO being able to assure obst ruction and person clearance as well as constant escape route planning during each phase of flight.9

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless th at aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equippe d with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

— (1) The instructor has determined that the flight can be conducted safely; and (2) The person manipulating the controls h as at least a private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flig ht instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57 when

— (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b ), and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and (4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrume nt flight unless

— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, si mulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

— (i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class rating s. (d) No person may operate a civil aircraft that is being used for a flight test for an airline tr ansport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot be ing checked, is fully qualified to act as pilot in command of the aircraft.

Brasfield & Gorrie requests exemption based on:

- Brasfield & Gorrie intends to conduct in

- house UAS operations training with the aid of qualified and experienced single and multirotor UAS operators. These instructors will be at least of private pilot

ce rtification and have experience either in a commercial or hobby use setting. Brasfield & Gorrie will develop a training curriculum which includes normal operations as well as emergency and evasive operations. While Brasfield & Gorrie will refer to these individuals as “instructors”, they will be unable to meet the criteria listed in this regulation due to certification not existing as well as aircraft requirements not being able to be met.

Level of safety retained:

When possible, an FAA certified flight instructor will be used to instruct new UAS operators to maintain
FAA in i tiatives in flight training, such as scenario based training. With each student operator being at least a private pilot, foundational preflight actions, weather knowledge, and good a eronautical decision making will be built upon in training the individual for UAS operation.10

§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(b) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Brasfield & Gor rie requests exemption based on:

- The mission of the UAS as it applies to Brasfield & Gorrie operations will require lower altitude. Currently, UAS operations allowed and regulated by the federal allow for a 400’ AGL ceiling which will
better insulate the UAS from any unforeseen air traffic.

Level of safety retained:

A 400’ ceiling will help to insulate the different types of aircraft. Also, having a VO will enable the PIC of the UAS to see and avoid any aircraft that penetrate that boundary unkowningly11

§91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter s etting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.

Brasfield & Gorrie requests exemption based on:

- The DJI Inspire is able to calculate, sense, and derive altitude information via onboard GPS, Barometer and Vision Positioning System. The Barometer can be set at zero prior to flight to ensure a max ceiling of 400’ AGL is able to be complied with. Also the GPS can give accurate indications of altitude. This information is displayed on the Ground Control Station.

- Max operations altitude (400’) is often under Minimum safe altitude as described in regulation. However, the UAS will not be operated as to provide a danger to persons or property. Operations will be limited to current Brasfield & Gorrie jobsites and/or owned property and structures. Flight will never be routed over employees or the g eneral public as we are able to control. Mission planning will be coordinated with jobsite leadership to ensure flight path while maintaining safety.

Level of safety retained:

Since the UAS operations will be limited to line of sight, the ability to conti nuously adjust for changing barometric pressure is not required. However, being able to derive UAS absolute altitude via three possible sources will assure an altitude below 400’ AGL. Also a safeguard 400’ AGL limit may be programmed prior to flight to e nsure the UAS flight does not take place above the altitude limit.12

§91.151 Fuel requirements for flight in VFR conditions. (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 f

ly after that for at least 30 minutes

Brasfield & Gorrie requests exemption based on:

- Batteries will be maintained and operated per manufacturer recommendations. Most flight stage length will take place under the minimum requirement for VFR fuel reserv es. Battery capacity and charge level will be monitored during the flights and flight will be safely discontinued at any point that a battery comes within the maximum depletion level.

Level of safety retained: The DJI Inspire 1 has safeguards in place to both warn the PIC and auto land in the event of battery starvation. These safeguards and that fact that neither cargo nor passengers will be carried assure the level of safety that 14 CFR 91.151 desires.13

§91.405 Maintenance required. Each owner or operator of an aircraft

— (a) 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;

Brasfield & Gorrie requests exemption based on:

- UAS will be maintained per manufacturer recommended procedures and repair stations as needed

.
Level of safety retained:

Preflight action will serve as a continuous maintenance program in addition to manufacturers recommended procedures. If at any point a component is found to be worn or broken beyond repair, that part will be replaced with the manufacturers recommended replacement part and the work shall be done either by the m anufacturer when able or a knowledgeable repair facility.14

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and

Brasfield & Gorrie requests exemption based on:

- Return to service test flights will be conducted by a fully trained operator as recommended by the
manufacturer.

Level of safety retained:

Return to service flights will be conducted in a controlled area, away from obstacles, persons, or property. An extensive preflight will be conducted; focusing on the repaired component and subsequent flight testing of all phases of flight will be conducted and logged prior to returning the UAS
to service.15

§91.409 Inspections. (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

Brasfield & Gorrie requests exemption based on:

- Preflight and system monitoring will be in accordance with manufacturer’ s recommendations which do not comply with standard aircraft inspection requirements. However, if at any point a system is found
to be defective or no l onger operational, it will be removed and/or replaced with an operational replacement part. All maintenance records will be logged and available to the PIC prior to each flight.

Level of safety retained: Repairs and inspections will be conducted by the ma nufacturer or a knowledgeable repair facility in order to ensure proper repairs in accordance to manufacturer recommendations.16

§91.417 Maintenance records. (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, an d alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to se rvice. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the ins

pection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time a nd date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service.

Brasfield & Gorrie requests exemption based on:

- All Maintenance records will be logged and be in accordance with manufacturer’s recommendations. These records will be available to the PIC pr ior to each flight.

Level of safety retained:

Each UAS that Brasfield & Gorrie operate will have an accompanying maintenance log sheet that shows date, place, and nature of repair. Each UAS will also have a flight log reflecting flight notes, return to service flights, and any abnormalities noted by the PIC.17

Unmanned Aircraft Description

- The UAS used will be the DJI Inspire. The Inspire is a Quadcopter design, capable of capturing 4k Video and transmitting to multiple devices. While the Inspire i s controlled by a remote control, positioning is assured and stored by the use of GPS. In addition to GPS position confirmation, Vision Positioning technology provides hovering precision when no GPS signal exists

. The Inspire is preprogrammed with
fail s afe features that add to the safety of operation. A Return To Home system is activated with a manual button, and automatically with a low battery indication or loss of communication with the transmitter. Vertical and Lateral boundaries may be established prior to each flight to ensure reception, and operations area containment and safety.

Following the petition summary are documents provided by the manufacturer:

A.

- Inspire 1 User Manual

B.

- Inspire 1 Safety Guidelines

C.

- Inspire 1 Maintenance Manua l

Radio Frequency Information

- Both controllers that come with the Inspire are listed by the manufacturer to be CE and FCC compliant. Controller and video link transmission operate at 2.4GHz and have a maximum range of 2 kilometers.

PIC Qualifications

- Each pilot of the UAS will be an Airline Transport, Commercial, or Private certified pilot and will hold at
least a valid third class medical.

- Each pilot of the UAS will have logged training for multirotor UAS flight consisting of takeoff and landing, emergency and evasive actions, and scenario based mission training.

- Each PIC will maintain currency required as applicable.18

Description of intended UAS Operations

Brasfield and Gorrie L.L.C. intend to use the Inspire within the applicable Federal Aviation Regulations while accomplishing our desired mission goal of jobsite survey, photography, and inspections. Operations will be conducted in uncontrolled airspace 500 feet AGL and below and outside a 5 nautical mile radius of any airport re ference point. If any mission requires operation within that 5nm radius, a letter of agreement will be obtained from the airport’s management, and the operation will be
conducted in accordance with a Notice to A irman as required by the Certificate Of Auth orization. All flights will be conducted under specific operating limitations:

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other air craft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour) . The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires
the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified
on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated wi thin the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messag ing or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outli ned in the operating documents,
the conditions and limitatio ns herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise19

its operating documents. It is the operator’s responsibility to track such revision s and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operat or determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection a nd determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UA S, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety
bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercia l, private, recreational, or sport pilot 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 of Columbia, Puerto Rico, a territory, a possession, or the Federal gover nment. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot
certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability t o safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the20

UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experien ce

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operat e within 5 nautical 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 char t, 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 must be made available to the Administrator or any law enforcemen t official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considerin g wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations
shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted un der the terms of the
attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45 , Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground
Control Stat ion of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.21

24. The UA must remain clear and give way to all manned aviation operations and activities at all
times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons lea ve such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for opera ting closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparti cipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorize d representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.22

Benefits of the utilization of UAS

Brasfield & Gorrie stands to enhance the safety of our employees by reduci ng the exposure to risk.
Exte rnal building inspection above 6 ’ would no longer require a person to assume some risk by putting themselves in a position relative to the structure that is not inherently safe. Aerial inspection and photography done by full sized rotorcraft can be minimized, thus lowering any additional strain on the Air Traffic Control system as well as lowering emissions produced by those vehicles. From an aviation community enhancement prospective, the process of training an employee on P rivate Pilot curriculum may spur on an interest in general aviation and add to the general public’s favorable vision of aviation.

DJI Inspire 1 specifications

Aircraft Model

- T600

Weight (Battery Included)

- 2935 g

Hovering Accuracy (GPS mode)

- Vertical: 0.5 m, Horizontal: 2.5 m

Max Angular Velocity

- Pitch: 300°/s, Yaw: 150°/s

Max Tilt Angle

- 35°

Max Ascent Speed

- 5 m/s

Max Descent Speed

- 4 m/s

Max Speed

- 22 m/s (ATTI mode, no wind)

Max Flight Altitude

- 4500 m

Max Wind Speed Resistance

- 10 m/s

Max Flight Time

- Approximately 18 minutes

Motor Model

- DJI 3510

Propeller Model

- DJI 1345

Indoor Hovering

- Enabled by default

Operating Temperature Range

- - 10° to 40° C

Diagonal Distance

- 559 to 581 mm

Dimensions

- 438x451x301 mm

Gimbal Model

- ZENMUSE X3

Output Power (with camera)

- Static: 9 W, In Motion: 11 W

Operating Current

- Station: 750 mA, Motion: 900 mA23 Angular Vibration Range

- ±0.03°

Mounting

- Detachable

Controllable Range

- Pitch:

- 90° to +30°, Pan: ±320°

Mechanical Range

- Pitch:

- 125° to +45°, Pan: ±330°

Max Controllable Speed

- Pitch: 120°/s, Pan: 180°/s

Camera Name

- X3

Model

- FC350

Total Pixels

- 12.76M

Effective Pixels

- 12.4M

Image Max Size

- 4000x3000

ISO Range

- 100

- 3200 (video)

- 100

- 1600 (photo)

Electronic Shutte r Speed

- 8s

- 1/8000s

FOV (Field of View)

- 94°

CMOS

- Sony EXMOR 1/2.3”

Lens

- 20mm (35mm format equivalent)f/2.8 focus at ∞, 9 Elements in 9 groups, Anti

distortion

Still Photography Modes

- Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias
Time

- lapse

Video Recording Modes

- UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60

Max Bitrate of Video Storage

- 60 Mbps

Supported File Form ats

- FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264)

Supported SD Card Types

- Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required.

Operating Temperature Range

- 0° to 40° C

Remote Name

- C124

Controller Operating Frequency

- 922. 7~927.7 MHz (Japan Only)

5.725~5.825 GHz 2.400~2.483 GHz

Transmitting Distance (outdoor and unobstructed)

- 2 km

EIRP

- 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

- USB, mini

- HDMI

Power Supply

- Built

- in battery

Charging

- DJI charger

Dual User C apability

- Host

- and

- Slave connection

Mobile Device Holder

- Tablet or Phone

Max Mobile Device Width

- 170m

Output Power

- 9 W

Operating Temperature Range

- - 10° to 40° C

Storage Temperature Range

- Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C

Charging Temperature Range

- 0

- 40° C

Battery

- 6000 mAh LiPo 2S

Charger Model

- A14

- 100P1A

Voltage

- 26.3 V

Rated Power

- 100 W

Battery (Standard) Name

- Intelligent Flight Battery

Model

- TB47

Capacity

- 4500 mAh

Voltage

- 22.2 V

Battery Type

- LiPo 6S High voltage battery

Energy

- 99.9 Wh

Net Weight

- 570 g

Operating Temperature Range

- - 10° to 40° C25 Storage Temperature Range

- Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C

Charging Temperature Range

- 0° to 40° C

Max Charging Power

- 180 W

Battery (Optional) Name

- Intelligent Flight Battery

Model

- TB48

Capacity

- 5700 mAh

Voltage

- 22.8 V

Battery Type

- LiPo 6S

Energy

- 129.96 Wh

Net Weight

- 670 g

Operating Temperature Range

- - 10° to 40° C

Storage Temperature Range

- Less than 3 months:

- 20 to 45° C More than 3 months: 22° to 28° C

Charging Temperature Range

- 0° to 40° C

Max Charging Power

- 180 W

Vision Positioning Velocity Range

- Below 8 m/s (2 m above ground)

Altitude Range

- 5

- 500 cm

Operating Environment

- Brightly lit (lux > 15) patterned surfaces

Operating Range

- 0

- 250 cm26

Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register should the FAA det ermine that publication is needed.

Petitioner: Brasfield & Gorrie L.L.C.

Sections of 14 C.F.R. Affected:

14 C.F.R. §61.23(a) and (c)

14 C.F.R. §61.113(a)

14 C.F.R. §91.7(a)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)(1)

14 C.F.R. §91.409(a)(1) and (2)

14 C.F.R. §91.417(a) and (b)

Description of Relief Sought: Petitioner seeks relief from the requirements of the above parts to the CFRs to conduct UAS operations over private and publicly owned or co ntrolled land, solely during daylight hours and in visual meteorological conditions, to conduct surveys, inspections, and photography of Brasfield & Gorrie jobsites, Brasfield & Gorrie owned property, and controlled prospective jobsites. In general, the UA S mission will be limited to line of sight with a max altitude of 400’ AGL. The flight crew will consist of a pilot in command and a visual observer.