November 13, 2015

U. S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act. Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), Technical Applications 

### &Consulting ("TAC"), the operator, Tracy Blocker (the applicant), planned operator of Unmanned Aircraft Systems (UASs) equipped to conduct aerial photography and digital point cloud surveys forvarious industries hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation ofour UASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAAas required by Section 333. As described more fully in Appendix A, the requested exemption would permitthe operation of UASs by the operatorfor commercial use that would provide the following benefits: 1. Operations would be performed in an area ofoperation limited in size suitable to the specific use, in advance offlight. 2. Theflight would be planned in advance to minimize hazards to persons and property in the air and on the ground. 3. The operatorwould reasonably limit or control access to provide safetyto those not involved in the operation. 4. Operation ofa UAS would provide significant safety, environmental and other enhancements not possible by larger sized aircraft. 5. An FAA licensed airman with a Commercial Pilot Certificatewould operate the UAS or directly supervise the operation. 6. Provide a beneficial and currently unavailable service to government organizations and the general publicthat would serve the public interest.Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAAAdministrators) responsibilities to "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system. "Section 333(c) ofthe Reform Act. It is possible to operate an UAS so to not create a hazard to users ofthe National Airspace System (NAS), the public or pose a threat to national security ifdone so safely and responsibly. The applicant has demonstrated theirwillingness to act safely and responsibly by not engaging in commercial UAS operations. The applicant has worked within FAA guidelines to obtain a legal authorization to conduct commercial operations. Additionally, the factthat the applicant currently holds a FAA Commercial Pilot Certificate demonstrates thatthe applicant has a high regard to safe operations, as well as a necessary high-level understanding ofthe NAS and FARs. The experience ofa FAA certificate serves to add significantlyto the level ofsafety in any operation performed by the applicant orthe applicant's employees. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristics of UAS and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level ofsafetyto operations underthe current regulatory structure as the proposed operations represent a safety enhancementto the already safe aerial commercial photography and survey operations conducted with conventional aircraft. The UASs planned to be operated is the 30 Robotics IRIS Plus rotorcraft. Each unmanned aircraft (UA) is equipped with four rotors that are driven by electric motors, powered by batteries, and weigh less than 4 pounds, including payload. The UAwould have a maximum airspeed of30 knots. The principal construction material ofthese UA is plastic. Operations will be performed by a qualified UAS Pilot in Command (PIC), as outlined below, to insure thatthe UAS will"not create a hazard to users ofthe national airspace system orthe public." Given the small size ofthe UAS involved and the preplanned environmentwithin which theywill operate, the applicant believes thatthese operations fall squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also, operation in a researched (to include applicable NOTAMs), pre-defined area will preventthe possibility ofa national security issue. The operation of UASs by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the public benefit and reduce environmental impacts related to current methods ofaerial photography and survey. These limitations and conditions to which the operator, or its employees, acting as an UAS PIC, agrees to be bound when conducting commercial operations under an FAA issued exemption: 1. Safetywill be the first and foremost consideration in any UAS operation.2. The UAS pilotwill be an FAA licensed airman with at least a Commercial Pilot Certificate orthe UAS pilot will be directly supervised by an FAA licensed airman with at least a Commercial Pilot Certificate. 3. The UAS Pilot, and observerwill hold at least a Second Class Medical Certificate

. 4. The UAS FAA licensed airman will be considered PIC, whetherflying or supervising, and will be responsible for safe operation ofthe flight. 5
. Flights will be conducted within line ofsight ofthe PIC and an observer. 6. Flights will be conducted in Class G airspace whenever possible. Ifan operation in another airspace is required, the relevant controlling agencywill be notified at least 24 hours priorto the operation and, if required, any necessary permission obtained

. 7. Flights will be conducted undervisibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR)

. 8

.The UAS will at all times give wayto any aircraft, object, or persons. 9. Minimum crewfor each operation will consist ofthe UAS PIC and an observer

. The observer and PIC will at all times maintain visual line ofsite to the UA, and be able to communicate byvoice

. 10

. Priorto a UAS flight, an area ofoperation will be established. This area ofoperation will include a defined lateral and vertical area, where the UAS will operate. Safety procedures will be established for persons, property and applicable airspace within the area ofoperation. 11

. Flight planning will include flight completion with at least 20% battery power remaining as measured by the UAS or appropriate timing

. 12. The UAS will utilize GPS navigation, failsafe, return-to-home (RTH) and/orflight abort safetyfeatures. 13. A briefing will be conducted in regard to the planned UAS operations priorto operation at each new location. All personnel who will be performing dutieswithin the boundaries ofthe area ofoperation will be presentforthis briefing

. 14. All required permissions and permits will be obtained from appropriate state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. Written, to include electronic, and/or oral permission from the relevant property owners will be obtained priorto an operation.16. The UAS pilotwill be trained in advance for the safe operation ofthe UAS to be operated. This will include operation ofthe UAS both in normal and emergency modes ofoperation as applicable, and will includefamiliarization with the operation manual (or similar) if published by the UAS manufacturer. Training will also includetypes of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace. It is the applicant's beliefthatthe size, speed, operating environment, limitations, and level ofapplicant's experience in the NAS outlined provides an "equivalent level of safety" or betterwhen operating a UAS forthe public interest as outlined in Section 

### 333 in the FAA Modernization and Reform Act of2012. It is requested that the FAA issue an exemption to permit safe, legal, commercial UAS operation by the applicant as soon as possible. Sincerely, 

# ?-/YL Tracy Blocker, Owner Technical Applications 

### &Consulting 7426 SW 101hAve Topeka, KS 66615 785-806-9542

AppendixA Exemption Requests and Equivalent Level ofSafety Appendix 

### 8 30 Robotics IRIS Plus Operation Manual Appendix C 

### 30 Robotics IRIS Plus Flight Checklist Appendix 

### 0 30 Robotics Gimbal User Guide