Petition for Exemption concerning operation of Colo rado Rocks, LLC Unmanned

Aircraft Systems in accordance with Section 333 of the FAA Modernization and Reform

Act of 2012 to allow commercial use of small unmann ed aircraft systems (“sUAS”) for the purposes of: aerial photography and videography , cinematography, videography, mapping, crop surveying, real estate, inspections, and other flight operations that could be performed safely with the use of a sUAS.

Name and Address of Applicant:

Colorado Rocks, LLC Attn: Nick Paslay

26451 Nanton Street Madison Heights, MI 48071

Exemptions requested per 14 C.F.R and how the opera tor will maintain an equivalent level of safety or no adverse impact to safety:

a. § 91.7(a) Civil Aircraft Airworthiness: No person s hall operate a civil aircraft unless it is in an airworthy condition. Applicant seeks an exemption from this rule by ensuring that the sUAS is in an airworthy condition based on compliance with the operating documents of the makes and models identif ied prior to every flight.

b. § 91.109 (a) Flight Instruction: No person may oper ate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The makes and models identified do not have dual controls. When flights are performed, no pilots wi ll be on the aircraft.

c. § 91.113 See and Avoid : Method for See-and-Avoid (§ 91.113). When weather conditions permit, regardless of whether an operati on is conducted under instrument flight rules or visual flight rules, vig ilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. The sUAS is strictly line of sight and will always be in consta nt contact with the operator and visual observer. See and Avoid will be conducted by the op erator and vigilance shall be maintained by each operator so as to “see and av oid” any other aircraft. There will be no adverse impact to the public because the visu al observer will have constant eye

contact with the sUAS at all times.

d. § 91.119 Minimum Safe Altitudes, no person may oper ate an aircraft below the following altitudes: Over other than congested area s. An altitude of 500 feet above the surface, except over open water or sparse ly populated areas. Operations will never be conducted higher than 400ft AGL and w ill avoid congested or populated areas and will pose no risk to the public. The PIC will always operate the UA an appropriate distance from nonparticipants as requir ed by § 91.119 and because of this will not adversely affect safety.

e. § 91.121 Altimeter settings: Each person operating an aircraft shall maintain thecruising altitude or fight level of that aircraft, as the case may be, by reference

to an altimeter that is set to the appropriate stat ion. The make and models identified use barometric altitude pressure but does not progr am in an altimeter setting. This exemption will benefit the public because the visua l observer and operator are visual line of sight at all times, and will not pose any risk t o the public and provide a level of safety required by this exemption.

f. § 91.151 (b) Fuel requirements for flight in VFR co nditions: No person may begin a flight in a rotorcraft under VFR conditions unless there is enough fuel to fly to the first point on intended landing and, ass uming normal cruising speed, to fly that for at least 20 minutes. The sUAS is battery operated with a maximum flying time of 18-23 minutes. However, this poses n o safety risk because the take-off point is near the landing point and will cause no s afety hazard to the public. The PIC will ensure that there is enough power to c onduct the operations.

g. § 91.207 Emergency Locator Transmitters: No person may operate a U.S.- registered civil airplane unless there is attached to the airplane an approved automatic type emergency locator transmitter. The sUAS does not use an ELT, all operations are VFR and in line of sight with a visu al observer. This exemption will benefit the public because the visual observer and operator are line of sight at all times

with the sUAS.

Inspection and Maintenance. (14 C.F.R § 91.405, 91. 407, 91.409). Applicant seeks an exemption from this rule by ensuring that the UAS i s in an airworthy condition based on compliance with the operating documents of the make s and models identified.

Pilot Qualifications (14 CFR 61.3, Requirement for certificates, ratings , and authorizations, and 14 CFR 61.5, Certificates and r atings issued under this part). a. Pilot Qualifications: All PIC will be current rated pilots with current m edical. They will hold either an airline, transport, commercial, private, recreation, or sport pilot certificate and the PIC will hold a current FAA air man medical certificate.

9. Flight areas a. Operations will be conducted under VFR of no mor e than 400 feet AGL. The sUAS will be operated within visual line of sight at all time s

Make and model of the aircraft for proposed operati ons:

DJI Phantom Series DJI Inspire Series

Granting the exemption would be in the public inter est and benefit the public as a

whole: Small unmanned aircraft systems (“sUAS”) can provid e similar services as full size manned aircraft at lower cost and with greater safe ty, providing exceptional value to Colorado Rock’s customers. In addition, there are several services that a sUAS canprovide that would be impossible or unsafe with ful l size manned aircraft, such as certain

angles/elevations for real estate photos and video. The small sUAS being utilized in this application will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft and wi ll promote economic growth.

Thank you for your time, and please direct all ques tions and concerns to Mr. Nick Paslay at Colorado Rocks, LLC: nick@gmail.com.