1

March 6, 2016

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: 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

61.1 13(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).

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernizati on and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Tri

- State Aerial Solutions

, (“ Tri

- State Aerial Solutions ”) Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to offer on

- demand commercial UAS operations for a host of indust ries and applications and to perform the purposes listed below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures, and working adjacent to treacherous infrastructure. 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 i n the national airspace system.” Section 333(c) of the Reform Act.2



### N ame and address of applicant :

Tri

- State Aerial Solutions Attn: Jason T. Snyder (Private Pilot)

Email: jtsnyder85@gmail.com

Address: 1236 12th Street, Nitro, WV 25143



### Background

Tri

- State Aerial Solutions is under Jason T. Snyder ’s direction. Jason T. Snyder is a private pilot (Private Pilot Certificate #2742561 issued 27DEC2002) and a h ighly accomplished, capable, experienced and trusted professional.

Tri

- State Aerial Solutions is an aerial photography firm specializing in safe and
efficient industrial inspection applications

.

Tri

- State Aerial Solutions employs professionals in the fields of photography

, inspection and safety management. They have a combined 29 years of flight and safety management experie nce and are experienced with the systems, characteristics and safety features of the sUAV equipment they operate. Aerial photography has become an important element in their inspection process and safety management . Tri

- State Aerial Solutions aims to provide the highest quality visuals while practicing safety measures such

as pre

- flight safety check lists, pre

- flight site walkthroughs and tours, pre

- flight photography shot list and planning, and a dherence to the regulations and parameters set forth by the FAA.



### 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)

 14 CFR 409 (a) (2)

 14 CFR 417 (a) & (b)3



### Introduction :

Tri

- State Aerial Solutions requests the agency issue a summary grant process for this application. Tri

- State Aerial Solutions has i dentified recently approved exemption numbers whereby the FAA has already granted a p revious exemption similar to these
request s for the following :

 Commercial purposes  Type of sUAVs (UAS)

 Title 14 Exemptions



### Description of Type, Make and Models of sUAV/UAS Requested:

Tri

- State Aerial Solutions is seeking an exemption to commercially operate sUAV ’s

makes and models as follows:

Blade Chroma ; DJI Inspire 1 ; DJI Phantom 3

Each sUAV weigh s 55 lbs. or less, with payload.



### Purposed Commercial Operation :

This exemption request, once granted would allow Tri

- State Aerial Solutions to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to

conduct structural i nspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of resid ent ial

and commercial real estate , aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, and videography, precision a griculture with on board sensors, wildlife and forestry monitoring, aerial surveying, construction site inspection and monitoring, pub lic entity support operations, a erial imaging for safety, monitoring and comparing work efforts and completion percentages , and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and phot ography for public and private use , p ublic events , training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS

, risk management and assessment, mining , disaster and catastr ophe events.4



### Public Benefit as a Whole :

Tri

- State Aerial Solutions proposes the use of its sUAV provided equivalent or augmented levels of safety for eac h of the uses proposed herein: The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, are now conducted by either a person climbing on the roofs and structures that are steep, tall, slippery, weakened or otherwise hazardous or by the use of conventional aircraft.

The current procedures can result in significant injuries to the people who must climb on the roofs or require the use of aircraft that are orders of magnitude greater in size
than the sUAV. Either method, manual inspection or large conventional aircraft, results in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or i ncreased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those undertake n with a sUAV.

The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site because the aircraft mu st be flown to and from

the site. By contrast, the sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the sUAVs and emit pollutants associated with internal combustion engines. The sUAVs proposed herein are battery powered and have no emissions.



### Aircraft and Equivalent Level of Safety to the Existing Rule :

Tri

- State Aerial Solutions 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 operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Exemptions 11136, 1113 8, 11172, 11174 and 11177, 11062, 11109, 11112, and 11213 and

as recent as 11857.

These limitations and conditions to which Tri

- State Aerial Solutions (referred to as
“o perator”) agrees to be bound when conducting commercial operations under an FAA

issued exemption include:5 1) Operations authorized by this grant of exemption are limited to the aircraft described in the Operator’s manual, which is a multi

- rotor weighing up to 55 pounds. Proposed operations of any other aircraft will require a new petition o r a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30 mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 2 00 feet above ground level (AGL), as indicated by the procedures spec ified in the Operator’s manual. All altitudes reported to ATC must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the Aircraft Operator at all times. This requires the Aircraft Operator to be
able to use human vision unaide d by any device other than corrective
lenses.

5) The Exemption Holder’s Manuals must be amended to include all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon request. If a discrep ancy exists between the conditions and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Opera tor must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and
revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents if it petitions for an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA g ranted this exemption, then the Exemption Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a
condition that affe cts the safe operation of the UAS, 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. The Ground Control Station must be included in the preflight inspec tion. All maintenance and alterations must be properly documented in the aircraft records.

7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight6 critical component, mus t undergo a functional test flight in accordance with the Exemption Holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a
functi onal test flight and aircraft record entry must be added to the Exemption Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, w ith particular attention to flight critical components that may not be addressed in the manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s
Manuals. Mai ntenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized technician returning
the UAS to service.

10) The authorized technicians must receiv e and document training referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS log book or equivalent document of the corrective action taken against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have logged at least 25 hours of total time as a UA rotorcraft pilot and at least

t en hours logged as a UA pilot with a similar UA type and 5 hours in the
make and model.

14) 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 and land or be recovered in accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption Holder’ s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes.7 17) All aircraft operated in accordance with the 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. Ma rkings must be as large as practicable.

18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requir ements.

19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement o fficial upon request.

20) The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultra

- light vehicles, parachute activities, parasailing activities, hang gliders, etc.).

21) T he UA may not be operated by the Aircraft Operator from any moving
device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14
CFR 1.1.

23) All operations must be conducted under visual meteorological conditions (VMC). 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 Operator.

24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airpor t as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required by the Operator’s COA. The letter of agreement wit h the airport management must be made available to the Administrator upon request.

25) The UA may not be operated over congested or densely populated areas
unless the conditions set for in #26 are satisfied. These populated areas
include but are not limited t o the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsib ility to maintain the minimum safe altitudes required by § 91.119 (d) (1).8 26) 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 sufficie ntly protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of th e risk of operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an undue hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlled

- access property with permission from the lan d owner/controller or authorized representative. Permission from land owner/controller or authorized 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 repo rted to the National Transportation Safety Board (NTSB) per instructions contained on the
NTSB Web site: www.ntsb.gov

. 

### Equivalent Level of Safety :

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command;

Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Tri

- State Aerial
Solution ’s sUAV is remotely controlled with no passengers or p roperty of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire.

Tri

- State Aerial Solution ’ s UAV respectfully proposes that o perator requirements should take into account the characteristics of the particular UAS. Tri

- State Aerial Solution’ s UAV has a high degree of pre

- programmed control and various built

- in technical capabilities that strictly limit the potential for operatio n outside of the operating conditions set forth in the exemption application. Tri

- State Aerial Solution’s UAV has navigation and9

control system comprised of a Ground Control Station (GCS) and auto

- pilot system that can be pre

- programmed to set operational boundaries. All flights are pre

- programmed with precision GPS guidance. In the case of unplanned events, the o perator may input pre

programmed evasive maneuvers from the control unit, and the onboard autopilot executes
those maneuvers. Pre

- programmed o perator interventions include initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (Flight Termination System).

Additional automated safety fu nctions and safety enhancing features of the Tri

- State Aerial
Solution ’s sUAVs may include the following:
1.1. Auto

- pilot detection of lost GPS or of insufficient satellites initiates an immediate landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low power below 10% triggers an immediate landing. 1.3. If the auto

- pilot detects a lost

- link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored

, execute a return to home and land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un

- commanded deviation from the flight path. 1.5. The aircraft, weighs less than 55 lbs., fully loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 2 00 feet above AGL

.

In addition to these safety features, o per ators of the Tri

- State Aerial Solution ’s sUAV are required to hold a private pilot certification.

The risks associated with the operation of the Tri

- State Aerial Solution ’s sUAV (given its size, speed, operational capabilities, and lack of combustible fu el) are so diminished from
the level of risk associated with conventional aircraft ope rations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present level of safety provided un der 14 C.F.R. § 61.113(a) & (b).



### 14 C.F.R. § 91.7(a): Civil aircr aft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the
UA. Given the size of the aircraft and the requirements that the o perator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with th e manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067,
11080 and 11110.10



### 14 C.F.R. §91.119: Minimum safe 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 altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS t hat is a helicopter and the exemption requests authority to operate at altitudes up to 2 00 AGL, an exemption may be needed to allow such operations.

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 permission of the property owner, facility owner, and/or local officials. Becau se of the advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operat ions

. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the
low

- altitude operations of the sUAS will ensur e separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section
91. 119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.



### 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 departure airport or an appropriate altimeter setting available before d eparture.” As the Tri

- State Aerial
Solution ’s sUAV, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The o perator will achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.



### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibi ts 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, 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.”11

Tri

- State Aerial Solutions believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (a llowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with le ss than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

Tri

- State Aerial Solutions believes that an equivalent level of safety can be a chieved by limiting flights to 15 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.



### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections

These regulations require tha t 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 these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Tri

- State Aerial Solutions

. Maintenan ce will be accomplished by the o perator or manufacturer pursuant to the flight manual and operating
handbook as referenced in the Manuals att ached as an equivalent level of safety will be achieved because these small UASs are very limited in siz e and will carry a small payload and operate only in defined areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 2 00 feet AGL. As provided in the Aircraf

t Flight Operations Manual the o perator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any mainte nance performed. Additionally, the o perator and manufacturer are most
familiar with the aircraft and bes t suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 11110.12



## Federal Register Publication :

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:

Tri

- State Aerial Solutions seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91. 7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, fil mmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed a nd live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, p rofessional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and catastrophe events.



## Summary :

Approval of exemptions allowing commercial operations of sU AVs for Tri

- State Aerial Solutions to operate an unmanned aircraft system (UAS) to conduct struct ural inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of residen tial and commercial real estate, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, and videography, precision agr iculture with on board sensors, wildlife and forestry monitoring, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use, pub lic events, training to persons individually or belonging to both private and public organizations to increase awareness and improve13

safety for current and future UAS operations within the NAS, risk management and assessment, mining, disaster and catastrop he events.

Conventional operations, using jet or piston powered aircraft, ladd ers or placing people on roofs or tall, hazardous or weakened structures, exposes them to higher risks than those created by use of a sUAVs. Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and
la ck of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small U ASs, weighing less than 55 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the grou nd, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional op erations conducted with helicopters operating in close proximity to the ground and people or the use of individuals to climb the structures to conduct the 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 an d national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of
Tri

- State Aerial Solution ’ s UAS for the p urposes outlined herein and are consistent with exemptions already granted, i ncluding Exemptions number 11171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 15151

.

Sincerely, Jason T. Snyder (Private Pilot Certificate #2742561 issued 27DEC2002)
Tri

- State Aerial Solutions
1236 12 th Street Nitro, WV 25143