U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590

July 1, 2015 i._/;.

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RE: Exemption Request Pursuant to Section 333 ofthe FAAModernization and ReformAct of2012

Dear Sir or Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.P.R. Part 11, Drone's Eye View Consulting, LLC, operator ofSmall UnmannedAircraft Systems ("sUAS"), hereby applies for an exemption from Federal Aviation Regulations identified below, to allow commercial operations ofsUAS. Theproposed operations include the following:

• Aerial Surveying • Agriculture • Aerial Photography and Videography • Wildlife, Forestry andAgriculture monitoring • Construction site inspection andmonitoring • Public Entity Support Operations • Education and Research As described more fully below, the requested exemption would permit the operation ofsUAS under controlled conditions in airspace thatis limited, predetermined, and controlled as to access. Approval ofthis exemption will create newbenefits to the industries listed above as technical and inherently dangerous operations can be performed in a safer and more controlled mannerby sUAS and their operators. Additionally, sUAS will provide economicbenefit to these industries byimproving efficiency and quality, and virtually eliminating human risk. The name and address ofthe petitioneris: Drone's Eye View Consulting, LLC Attn: Lott S Gilbert Bolden II 209 E Monroe Ave Alexandria, VA 22301 c 

### I 703.431.9534 e 

### I gil@droneseyeviewconsulting.comRegulations from which the exemption is requested: 14 CFR Part 21 14 CFR Part 27 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 CFR407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) The following sUAS's are submitted for exemption from the regulations above for use in safe operations listed above for the reasons expressed more fully below: DJI Phantom 2 DJI Phantom 3 DJI Inspire 1 DJI S900 DJI SIOOO 3DRRobotic Solo 3DRX8+
This exemption application is expressly submitted to fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUASs do not create a hazard to users ofthe NAS orthe public orpose a threatto national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS withinvisual line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that suchvehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." Id. §333(c). Applicant interprets this provision to place the duty on the Administrator to not onlyprocess applications for exemptions under section 333, but for the Administratorto craft conditions for the safe operation ofthe UAS, ifit shouldbe determinedthatthe conditions set forth herein do not fulfill the statutoryrequirements for approval.
The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft as the term is defined under §40101 ofthe Act, thatincludes sUAS's, from the requirement that all civil aircraft must have a current airworthiness certificate.The Administrator maygrant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702/\44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Drone's Eye View Consulting sUASs are rotorcraft andfixed wing aircraft, weighting 55 lbs. or less including payload. They operate, under normal conditions at a speed ofno more than 100 MPH. They will operate only in line ofsight andwill operate only within a sterile area. Such operations will insure thatthe sUAS will "not create a hazardto users ofthe national airspace system or the public." Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted sterile environmentwithin which they will operate, the applicant falls squarely within that zone ofsafety (an equivalentlevel ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surroundingtheproposed operations, and the significantpublic benefit, including enhanced safety, reduction in environmental impacts, andreduced emissions, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grant the requested exemption without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for atleast an equivalent oreven higher level ofsafety to operations under the currentregulatory structure because the proposed operations represent a safety enhancementto the already safe operations conducted with conventional aircraft. These limitations andconditions to which Drone's Eye View Consulting agrees to be boundwhen conducting commercial operations under an FAA issued exemption include: 1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Flights will be terminated at 25% batterypower to ensure the safe return ofthe aircraft to the launch point. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned, with exception oftelecommunication towers or high powerlines, when altitude shall be limited to 100 feet above said tower or line. 5. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and/or the Camera Operator. 6. The sUAS pilot will be a designated Pilot in Command (PIC) andhold a valid state driver's license. If the PIC feels another operatorto be qualified withthe necessary skills to be PIC & possess a valid state driver's license or higher flight certificate, thatperson maybe designated PICprovidedthey have a minimum of20 hours offlight time with the sUAS. 7. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeterbe present for this briefing. 8. The operator will obtain the consent ofall persons involved and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, andthis radius maybe reduced to 20 feet based upon an equivalent level ofsafety determination. 9. Pilot and observer will have been trained in operation ofUAS generally andreceived up to date information on the particularUAS to be operated. 10. Observer andpilot will at all times be able to communicateby voice. 11. Written and/or oral permission from the relevantproperty holders will be obtained. 12. All requiredpermissions andpermits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 13. 15. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a predeterminedlocation within the Security Perimeter andland.14. 16. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies.

14 C.F.R. Part 

### 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, establishes the procedural requirements for the issuance ofairworthiness certificates as requiredbyFAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilizedby the Applicant, an exemption from Part 21 SubpartH meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 ofthe Reform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, andproximity to airports andpopulated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposedwill be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set outin the Manual. Unlike other civil aircraft, operations under this exemption willbe tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local andpublic regulation. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture andtelevision production, provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 21, SubpartH. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posedby the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (b).Marking of the Aircraft The regulation requires: When marks include only the Roman capital1etter "N" andthe registration numberis displayed on limited, restricted orlight-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Given the size ofthe sUAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will beprovidedby having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others workingwith the sUAS will see the identification ofthe UAS as "Experimental." The FAAhas issued the following exemptions to this regulation in Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Drone's Eye View Consulting, LLCrequests thatthe exemption allow operationwithout a private pilot certificate. Per 49 USC §44711, Drone's Eye View Consulting maynot serve in any capacity as an airman with respect to a civil aircraft in air commerce without an airman certificate authorizing the airman to serve in the capacity for which the certificate was issued. On February 15, 2015 the FAA announced newproposedrules for SUASI. In that document (http://www.gpo.gov/fdsys/pkg/FR-2015-02-23/pdf/2015-03544.pdf), the FAA stated the following:"in addition to obtaining an airworthiness certificate, any person serving as an airman in the operation ofa small UAS must obtain an airman certificate. 49 U.S.C.44711(a)(2)(A). The statute defines an "airman" to include an individual who is "in command, or as pilot, mechanic, or member ofthe crew, who navigates aircraft when under way." 49 U.S.C. 40102(a}(8)(A). Because the person operating the small UAS is in command and is a member ofthe crew who navigates the aircraft, that person is an airman and must obtain an airman certificate. Undercurrentpilot certification regulations, depending onthe type ofoperation, the operator ofthe small UAS currently must obtain either a private pilot certificate or a commercial pilot certificate. A private pilot certificate cannotbe used to operate a small UAS for compensation or hire unless the flight is only incidental to the operator's business or employment. Typically, to obtain a private pilot certificate, the small UAS operator currently has to: {1) Receive training in specific aeronautical knowledge areas; (2) receive training from an authorized instructor on specific areas ofaircraft operation; {3) obtain a minimum of40 hours offlight experience; and (4) obtain a third class airman medical certificate. Conversely holding atleast a commercial pilot certificate allows the small UAS to generally be used for compensation or hire, but is more difficult to obtain. In addition to the requirements necessary to obtain a privatepilotcertificate, applicants for a commercialpilot certificate currently need to also obtain 250 hours offlight time, satisfy extensive testingrequirements, and obtain a second-class airman medical certificate. While these airman certification requirements are necessary for manned aircraft operations, they impose an unnecessary burden for many small UAS operations. This is because a person typically obtains a private or commercial pilot certificate by learninghowto operate a manned aircraft. Much ofthatknowledge would notbe applicable to small UAS operations because a small UAS is operated differently than a manned aircraft. In addition, the knowledge currently necessary to obtain a private orcommercialpilot certificate would not equip the certificate holder with the tools necessaryto safely operate a small UAS. Specifically, applicants for a private or commercial pilot certificate currently are nottrained in how to deal with the "see-and-avoid" andloss-of-positive-control safety issues that are unique to small unmanned aircraft. Thus, requiring persons wishing to operate a small UAS to obtain a private or commercial pilot certificate imposes the cost ofcertification onthose persons, but does notresult in a significant safety benefitbecause the process ofobtaining the certificate does not equip those persons with the tools necessary to mitigate the public risk posed by small UAS operations" In addition to the FAA's recent findings, Drone's Eye View Consultingbelieves requiring a private pilot certificate is not in the public interest because (1) the expenses incurredby obtaining a privatepilotlicense and maintaining itwill have to bepassed on to Drone's Eye View Consultings' customers, (2) flying manned aircraft is harmful to the environment, (3) flying manned aircraft poses a higher risk to people, property, and other aircraft than flying UAS, and (4) since Drone's Eye View Consulting has no interest in flying manned aircraft, thebare minimum will be done in order to satisfy the requirement ofobtaining and maintaining a private pilot certificate. Pilots whom are not deeply invested in flying manned aircraft pose a much greater risk to people, property, and other aircraft. Since 49 USC§ 44711 requires an airman certificate authorizing the airman to serve inthe capacity for which it was issued, requiring a private pilot certificate does not satisfy this statutory requirement. This is evident since the FAA statedthat obtaining a private pilot certificate for the purpose ofoperating a UAS (1) does not result in a significant safety benefit, (2) does not equip those persons with the tools necessary to mitigate thepublic risk posedby small UAS operation, and (3) much ofthatknowledge would notbe applicable to small UAS operations because a small UAS is operated differently than a manned aircraft. Furthermore, Drone's Eye View Consultingbelieves requiring a privatepilot certificate will (1) create an unnecessary burden thatis detrimental to Drone's Eye View Consultings' operations, (2) will not increase thelevel ofsafety, (3) will introduce dangerous situations thatpose a much higher risk to people, property, and other aircraft, and (4) is notin the public interest. Furthermore, the FAA does notrequire a private pilot certificate for noncommercial operations thatperform the same flights, so removing this requirementwill still allow Drone's Eye View Consultingto operate within a level ofsafety that is equal to the level ofsafety providedby existing rules. For those reasons, Drone's Eye View Consultingwould like this requirement to be removed from the exemptionand for the FAA to require a certificate that allows the airman to serve in the capacityfor which it was issued so that Drone's Eye View Consulting is able to satisfy the statutoryrequirement in 49 USC§ 44711. 14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, shouldthis exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists prior to each flight, an equivalentlevel ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person mayoperate a U.S.-registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is notrequired by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not onlybecause there is no pilot on board, butbecause there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintainedby keeping the flight manual at the ground control pointwhere the pilotflying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.1 09: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs andremotely piloted aircraft, bytheir design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box thatcommunicates with the aircraft via radio communications. The FAA has approved exemptions for flight trainingwithout fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety will be providedby the fact that neither a pilot norpassengers will be carried in the aircraft andby the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated atless than the minimums prescribed, providedthe person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS and the exemption requests authority to operate at altitudes up to 400 AGL, ornot more than 200 above an elevated platform from which filming is planned, an exemption maybe neededto allow such operations. An additional exemption is also requested for permission to operate at 100 feet above a transmission tower, communication tower, orbridge for the purpose ofinspection. This will allow for safe inspection ofthe latter without potential conflict with other aircraft. As set forth herein, except for the limited conditions statedpreviously the UAS will never operate at higher than 400 AGL. Itwill, however, be operated in a restricted area with security perimeter, where buildings andpeople will notbe exposedto operations withouttheir pre-obtained consent. The equivalentlevel ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe required permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the aerial activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weightingfar more than the maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presentlypresented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separationbetween these small-UAS operations andthe operations ofconventional aircraft that must comply with Section 91.119. 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 thatis set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption maybe needed. An equivalent level ofsafety willbe achievedbythe operator, pursuantto the Manual and Safety Checklist, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements tor Flight in VFR Conditions Section 91.151 (a) prohibits 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 ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after thatfor atleast 30 minutes; or (2) At night, to fly after that for at least 45 minutes." Depending on the sUAS, the batteryprovides approximately 15-60 minutes ofpowered flight. To meet the 30- minute reserve requirement in 14 CFR §91.151, sUAS flights would be extremely limited. Given the limitations on the UAS's proposed flight area andthe location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.15l(a) falls withinthe scope ofprior exemptions. See Exemption 1067 3 (allowing LockheedMartin Corporation to operate without compliance with FAR 91.151 (a)). Operatingthe small UAS, in a tightly controlled area where only people andproperty owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91.15l(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to extremely short flights would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalentlevel ofsafety canbe achieved by limiting flights to 25% ofbattery power. This restriction wouldbe more than adequate to return the sUAS to its plannedlanding zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loadedweighs no more than 55 lbs and is operated without an onboardpilot. As such, there is no ability orplace to carrycertification and registration documents or to display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground controlpoint where the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofotherexceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have the aircraft inspected as prescribed in subpart E ofthis part and shallbetween required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43.Given that these section and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the applicant. The operatorpursuant to the flight manual and operatinghandbookwill accomplish maintenance. An equivalentlevel ofsafetywill be achieved because these small UASs are very limited in size andwill carry a small payload and operate onlyin restricted areas for limitedperiods oftime. Ifmechanical issues arise the UAS can landimmediately andwill be operatingfrom no higherthan400 feet AGL. As provided in the Manual, the operatorwill ensure thatthe UAS is in working orderpriorto initiating flight, perform required maintenance, andkeep a log ofany maintenanceperformed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy conditionto provide the equivalentlevel ofsafety. Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, shoulditbe determined thatpublication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpartH; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmannedvehicle (55lbs orless). Approval ofexemptions allowing commercial operations ofsUASs, will enhance safetybyreducing risk. Conventional aircraft operating atlow altitudes near subjects being filmed and in close proximity to structures present major risks associated with the size ofthe vehicle carryingjetA or otherfuels. Such aircraft must fly to and from the operational location. In contrast, a sUAS weighing fewer than 55 lbs. andpowered by batteries eliminates virtually all ofthatrisk given the reduced mass andlack ofcombustible fuel carried onboard. The sUAS is carried to the operation site and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofsmall UASs, weightingless than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalentlevel ofsafety supportingthe grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conductedwith turbine helicopters or fixed wing aircraft.Conclusion Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security

- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofDrone's Eye View Consulting's UAS. Drone's Eye View Consultingrequests thatthe exemption allow Drone's Eye View Consulting to operate without a COAin Class G airspace, at400 feet AGL orbelow, and at least five nautical miles from the geographic center ofan airport unless a letter ofagreement with the airport's management is obtained. The FAA does not require a COAfor non-commercial operations in Class G airspace thatperform the same flights, so removing this requirementwill still allow Drone's Eye View Consulting to operate within a level of safety that is equal to the level ofsafety providedby existing rules. Furthermore, this requirement creates an unnecessaryburden that is detrimental to Drone's Eye View Consulting's' operations since most operations will take place in Class G airspace, at 400 feet AGL orbelow, and at least five nautical miles from the geographic center ofan airport. Forthose reason, Drone's Eye View Consulting would like the exemption to onlyrequire a COA when notoperatingin Class G airspace Drone's Eye View Consulting, LLC is committed to safe operation and due to the foregoing reasons shouldbe permitted to conduct small UAS operations in accordance with its manuals and all other operatingparameters deemed necessary and appropriate bythe FAA. Ifyou have any questions, please contactme at your earliest convenience.

Sincerely,



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# ........_ Lott S Gilbert Bolden II Drone's Eye View Consulting, LLC