FROM: AvStrategies, LLC

Attn: Brian T. Foley

49 Seneca Trail Sparta, NJ 07871 (973) 729

- 6914 b@brifo.com

TO: Federal Aviation Administration US Department of Transportation Docket Management System 1200 New Jersey Ave. S.E Washington, DC . 20590

Re: Exemption Request Section 333 of the FAA Reform Act Pursuant to section 333 of the FAA Modernization and Reform act of 2012 (The Reform Act), and 14 C.F.R. Part 11, Av Strat eg ies,

LLC her e by seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to
allow himself to operate Small Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) under the conditions and limitations set forth in this petition. The requested exemption would permit AvStrategies , LLC to operate small, unmanned aircraft system (UAS) for the purpose of providing an aerial photography and survey service to Municipal ities, Utilities & Private consumers. The areas of use will include both photo and video in the Utilities, Communications industry, real estate industry, surveying industry, construction industry, agricultural industry. The UAS will be operated in airspace that is 1) limited 2) predetermined 3) would provide added safety enhancements to the already safe operations in the industry presently using conventional aircraft system.

Exemption request to section 333 of the FAA Reform Act Plan 11 Specific to UAS ope rations.

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.103;14 CFR 91.105; 14 CFR 91.109: 14 CFR 91.119(c);14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.401(a)(1) & (2); 14 CFR 91.417(a) 7 (b).Dear Sir or Madam:

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography of for public and/or private use including television , public events, cinematography and newsgathering

.

 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastruc ture included but not limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract and/or donation.

 The ability to offer training to persons or individuals belonging to both private and/or public organizations that have interests in the use and application of UAS for the purpose of the safe
operat ion of a UAS to enhance the safety of national aerospace system (NAS) as well as for protection of the persons and property.

As described full y below, and to be used as FOM, the requested exemptions would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements such as limited exposure to flight crew, climbing crews, weight of vehicles, speeds of usag e, non use of volatile fuels, etc

. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportations (the FAA administrators) responsibilities to “....establish requirements for the safe op eration of such aircraft systems in the national airspace system.

BACKGROU N D , AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The petitioner, AvS t rategies, LLC is under the direction of Brian T. Foley who is an FAA licensed instrument rated private pilot, with a current Class III medical.

The primary vehicle to be used is a Freefly Alta, which is currently awaiting FAA registration. The UAS weighs less than 50 lbs. The Freefly Alta relies on a 2.4 GHz radio
transmission to control the UAS and has a return to home via GPS feature to land the UAS in the
event of radio failure. The Alta also utilizes a 5.8GHz radio signal to send video from the UAS to the camera operator. While ve hicles may be upgraded as advances in technology and safety occur, the manufacturer will set the bar for operation and safety . No vehicle operated AvStrateg ies , LLC will be modified from the manufacturer design unless specifically directed by
the same manufacturer. L imitations and conditions to which the applicant agrees to adhere towhen conducting commercial operations under the FAA issued exemption as set forth in the flight

operat ions manual include:

 The UAS will weigh less than 55 lbs

 The UAS will have a maximum ope rating speed of no more than 30 mph

 Flights will be operated within line of sight of the pilot in command and/or visual
observer

 Maximum flight time for each operational flight wi ll be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs
first

 Flights will be operat ed at altitude of no more than 2 00 feet AGL and no more than 200 feet above an equivalent platform from whi ch filming is planned.

 UAS will NOT operate:

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

 2 NM from an airport without a published instrument flight procedure or an operational tower; or

 2 NM from a heliport with a published instrument flight procedure

 Minimum crew for each operation will consist of the UAS pilot (PIC), the visual observer (VO) and may include but not li mited to a camera operator

 The UAS pilot will be designa ted pilot in command and hold a current private pilots
license . If the PIC feels another operator to be qualified with the necessary skills to be pilot in command and possesses a valid private pilots license or above , that person may be designated PIC provided they have a minimum of 20 hours of flight time with the

UAS.

 A briefing will be performed regarding the planned UAS operations prior to eac h day’s flight consisting of the days production activities

 All flights will occur under visual flight rules meteorological conditions (VFR only).

 The operator will obtain verbal/written consent of all persons involved with the planned operations and ensure only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advance permission of the FFDO, operations at closer range may be appr oved.

 The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permis sion and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or losses GPS signal, the

UAS w ill have the capability to return to a pre

- determined location within a designated location and land autonomously. The UAS will have the capability to abort a flight and return to designated landing area in case of unpredicted obstacles, weather, or emerg encies.

 VO or PIC instructed to switch UAS to automatically return home in event either are incapacitated.

As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below 200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less than 55 pounds, operations are conducted during daytime Visual Fligh t Rules (VFR) conditions and within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports.

In seeking authorization, petitioners will require exemptions from regulations with which they cannot fully comply. The table below provides guidance regarding regulations from which a petitioner may require exemption. However, some proposed operations may require exemption from regulations not listed here, while others may not require exemption from all regulations
li sted here.

14 CF R Part 21

, Subpart H 14 CFR 45.23(b) 14 CFR 61.113(a)

14 CFR 91.103(b)(2)

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151

14 CFR 91.405

14 CFR 91.407

14 CFR 91.409

14 CFR 91.417

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. Sec 91.203(a)(1)

The UAS will operate at 55lbs or less (Gross), carry neither a pilot or passenger, carry no explosive materials or flammable liquid fuels, and operate within a secured and pre

- determined designated area, at altitudes not to exceed 200 feet AGL or speeds in access of 50 MPH.

14 C.F.R. Sec 45.23(b). Marking of the Aircraft Regulations require that when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experim ental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lig ht

- 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 or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage

as r equired by §45.29 (f) where the pilot, observ er and others working with the UAS will
see the identification of the UAS as “Experimental.”

14 C.F.R. Sec 61.113(a) and (b): Private Pilot Privileges and Limitations:

Pilot in Command, by current regulations because the applicants UAS does not carry passengers, or property. The use of UAS is far less dangerous (weight, speed, f uel) than the inherent usage of
commercial activities outlined in 14 CFR.16. The pilot in command shall hold a current private pilot l icense or above and a state drivers license, which is used in lieu of a medical certificate.

14 C.F.R. Sec. 91.103: Preflight Action:

Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC will take all actions as stated in FOM, under normal procedures included but not limited to review of weather, examination of batteries for flight time anal ysis, landing and takeoff distances as well as flight and aircraft performance in flight.

14 C.F.R. Sec 91.105 Flight crew members at station

Exemption may be required, the PIC may not leave his station nor shall VO leave station. In
event that PIC or V O become incapacitated, UAS is to automatically return to designated landing area, as outlined in FOM

14 C

. F

. R

. Sec 91.109 Flight Instruction (Dual Controls)

Requiring that no person shall operate a civil aircraft for flight instruction unless the airc raft has fully functioning dual controls. UAS and Remote controlled aircraft by design do not have dual controls, to do so on a radio controlled aircraft would lower the ability to safely operate the UAS. This section cannot reasonably apply

14 C.F.R. Se c 91.119 Minimum Safe Altitudes

Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then minimums prescribed, providing the person operating helicopter complies with any route with and or altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards and operation a request for exemption to operate at altitude’s not to exceed 200 AGL or not more than 200 ft above any elevated platform from which take off is necessary to achieved filming. I n the event of such particular flight plan, property owners, filming crews and other personnel wouldall be briefed as to safety and conduct procedures during flight. FOB or ATC having jurisdiction

in such area would have notification and briefing as manda ted.

14 C.F.R. Sec 91.121 Altimeter Settings

The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from corresponding airports as predetermined in flight plan, unless ordered otherwise. As the
UAS has no ba rometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied. Per a preflight checklist and live flight data monitoring, the altitude of launch site will be predetermined and therefore calculated into the UAS GPS indicator before flight.

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

The maximum flight time under ideal conditions is 30 minutes with the current manufacturers battery pack. The proposed rule under this exemption would require the UAS to return to its point of launch if its battery reaches less than 25% provides a higher s tandard of safety when applied to

UAS.

14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator will provide minor maintenance and in spection to the UAS, documented as outlined in the operational and safety guidelines. Given the size and simplicity of the UAS combined with the operational and safety guidelines outlined in this petition the operator can maintain or exceed the required
le vel of safety.

Sincerely,

AvStrategies, LLC Attn: Brian T. Foley
49 Seneca Trail Sparta, NJ 07871 (973) 729

- 6914
b @brifo.com