Aerial Oklahoma, INC 4501 N Classen Blvd, Suite 113 Oklahoma City, OK 73118

T: +1 405 840 8977 jtyeager@aerialok.com

M

arch 30, 2015

U . S. Department of Transportation

D ocket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re : Request for Exemption Per PL 112

- 95 §333 from 14 CFR 61.113(a) and (b),
14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

D ear Sir or Madam:

P lease consider this a request for an exemption of the above applicable sections of
title 14 CFR for Aerial Oklahoma, I NC for the purpose of conducting commercial aerial survey and photography operations with its small Unmanned Aircraft System (s UAS) within controlled access airspace, using licensed airmen, and employing a comprehensive safety, training, and planning program. The employment of sUAS platforms for these missions should provide the FAA with good cause to find that these operations en hance safety by eliminating the need to use conventional aircraft in the sometimes unique environments where an sUAS would be particularly adept, but a conventional aircraft may pose a hazard to its crew and those on the ground.

A erial Oklahoma, INC requests exemption from the following applicable regulations, pursuant to the Administrator’s authority to grant exemptions contained in 49 U.S.C. § 106(f), 40113, and 44701:



### 14 CFR 21 Part H 14 CFR 61.113(a) and (b),

14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119,14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

OP ERATION OVERVIEW

O ur current staff are professionally trained airmen with commercial and ATP privileges and have thousands of hours experience with the regulations and operations of the National Airspace System, ensuring an equivalent, if not greater level of safety.

O ur operations utilize sUAS in a manner that provides services not offered by manned aircraft or enhances the level of safety at which the tasks can be completed in manned aircraft

E xamples of the proposed aerial photography operations include both real estate and insurance damage assessment. Both operations restrict the use of the sUAS to a small area typically encompassing a limited number of residential and commercial properties a t a time. The areas in which the flight takes place can readily be protected with secured access by the staff of Aerial Oklahoma INC

, comparable to that of a movie production set. The structures on these properties provided sufficient protection from the s UAS and can be completed with much less risk than what would be assumed in a manned operation at low altitudes.

O ur intended film production operation would typically include both photography and videography for commercial purposes including promotional video and commercial production for businesses. These events are restricted to only the invited participants and are closed to the general public, providing the opportunity to operate only in an area where informed, consenting participants and personnel

a re present. By adhering to the restrictions and exemptions previously established to movie production entities Aerial Oklahoma, INC will be able to provide a level of safety equal to or greater than the manned aircraft that would typically provide
these se rvices.

F inally, our survey operation includes the orthomosaic mapping of both agriculture and construction sites utilizing our sUAS rotorcraft flying pre

- programmed grids that can be interrupted and returned to a safe landing zone by our FAA certified pilots at any time. Currently these operations are executed by general aviation aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudesand speeds. Our operation would greatly increase the level of safety, replacing large aircraf t with an sUAS under 6.5 pounds and restricted to speeds no greater
than 43 knots. These sites are areas that can readily be secured by Aerial
Oklahoma personnel and would not provide any additional risk to the general public.

A ll of Aerial Oklahoma, I NC operations will be performed by FAA licensed pilots with trained Visual Observers and, where necessary, Site Security Coordinators, in controlled and secured environments only after a safety assessment has been completed and approved risk mitigation pra ctices to a level equivalent to or less than the previous granted exemptions to the motion picture industry.

A ny operations under the exemption would be conducted in accordance with the strict parameters specified herein.

AI RCRAFT

A erial Oklahoma, Inc will operate the four

- rotor DJI t600 aka DJI Inspire 1 sUAS
which is a commercially available off

- the

- shelf sUAS. The sUAS is rotocopter configuration and will weigh no more than 6.5 pounds. It will operate no faster
than 43 knots groundspeed. The aircraft are agile, having the ability to hover, and move about its three axes simultaneously. The aircraft will be operated below 400 feet Above Ground Level (AGL) a nd continuously within the Pilot in Command’s (PIC) line of sight, so as to not create a hazard to users of the national airspace system or public. The aircraft is equipped with failsafe protocols that return the aircraft to a predetermined point and land if any abnormalities are present. Because of the sUAS’ specifications and flight characteristics, it poses no threat to national security.

T hese limitations an d conditions that Aerial Oklahoma, INC agrees to be bound to
include:

1. T he sUAS will weigh less than 6.5 lbs

. 2. F lights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 15 minutes

. F lights will be terminated at 25% battery power reserve should that occur prior to the 15 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer and based on results of the safety assessment may include a security coordinato r
6. s UAS pilot will be an FAA licensed airman with at least a private pilot’s
certificate and third class medical. The observer will hold at least a thir d
cl ass medical.

7. The UAS will only operate within a confined “Sterile Area” where Aerial Oklahoma, INC have control over an person and or property that will be operated near and/or above.

8. A briefing will be conducted in regard to the planned sUAS op erations prio r
t o each mission . It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be presen t
f

or this briefing

. 9. Th e operator will file a FAA Form 7711

- 1, or its equivalent, as modified in
l ight of the requested exemption, with the appropriate Flight Standards
District Office.

10. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 30 feet of the flight operat ion. This radius may be reduced further based upon a n

e quivalent level of safety determination with the advanced permission of
the relevant FSDO.

11. The operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot unless otherwise advised by the FSDO.

12. Pilot and observer will have been trained in operation of UAS generally and received up

- to

- date information on the particular UAS

. 13. Observer and pilot will at all times be able to communicate by voice

14. Written and/or oral pe rmission from the relevant property holders will be
obtained.

15. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the Security
Perimeter and land

. 17. T he sUAS will have the capability to abort a flight in case of unpredicte d

o bstacles or e mergencies.s UAS CONTROL

T he control of the sUAS will be through a Radio Transmitter and Receiver manufactured by DJI Industries operating on the 2.4ghz and 5.8ghz spec trum.
The DJI C1 Control System is FCC approved and provides range of greater tha n
2 km. The Control Link system also provided telemetry status of the link strength and critical flight information on its built in display.

s UAS PAYLOAD

T he DJI t600 is designed to carry it’s purpose built camera system which is fully integrated into the design of the sUAS platform. Any change from a known configuration will result in a notation in the aircraft log from a company approved
technician and in accordance with Aerial Oklahoma, INC ’s Flight operations manual Section 5.6. Prior to resuming commercial operations the sUAS will be flight tested in accordance with our maintenance procedures outlined in our FOM.

A IRWORTHINESS CERTIFICATION

Th e sUAS to be operated by Aerial Oklahoma, INC weight less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the FOM. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the FOM’s requirements and wil l provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness
certificate s issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive mater ials or flammable liquid fuels, and inability to carry a substantial
external load.

FL IGHT CREW

F light Crew (14 CFR 61.113 (a) and (b)) “Flights are planned and coordinated in accordance with manual.” Prior to flight, the PIC and Visual Observer (VO) (“flight crew”) will have completed the qualification process as outlined in the operator’s manual. The Pilot in Command will possess, at minimum, a private pilot’scertificate, meet applicable recent flight experience requirements and hold at least
a thir d class medical. The Visual Observer will be trained in accordance with the company’s FOM and will undergo routine competency checks.

PR EFLIGHT ACTION

I n accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather briefing, survey the launch and recovery environments and review takeoff and landing distances and other applicable aircraft performance data, check the aircraft and ground station/transmitter battery levels, and brief the Visual Observer (VO) and any other supporting crew on the mission, safety, and contingencies. All flights will be conducted in Day VMC conditions. Minimum flight crew shall include the PIC, Visual Observer to assist with seeing

- and

- avoiding other aircraft, a Site Security Coordinator as determined by preflight risk analysis.

FL IGHT INSTRUCTION

F light Instruction (14 CFR 91.109), No pilot or passengers will be carried aboard.

M INIMUM SAFE ALTITUDES

A erial Oklahoma, INC requests authority to operate at altitudes up to but not exceeding 400 feet AGL within a specifically defined, controlled, restricted perimeter per 14 CFR 91.119. Aerial Oklahoma, INC will establish and maintain a security perimeter for the purpose of protecting structures and people not associated with the operation. In establishing the s ecurity perimeter, Aerial Oklahoma, INC will receive the permission of the owner of the property upon which the ground crew will stage and above which the aircraft will operate, and at no time will the sUAS be operated directly over a person. Should the flight take place over public lands, Aerial Oklahoma, INC will obtain the permission of the governing body of jurisdiction. Obtaining permission to operate will serve as notification to the property owner or governing body that operations will be taking plac e. The sUAS will be continuously operated at an altitude which will allow a safe descent and recovery should a mechanical issue arise.

A LTIMETER SETTING

Th e sUAS does have a n internal barometric altimeter along with GPS altimeter. In meeting 14 CFR 91 .121, an equivalent level of safety provided is by preflight action where the PIC will compare the GPS altimeter with the MSL altitude of the safe operating perimeter as ascertained by applicable aeronautical andtopographical charts and ma ke an calibratio n as necessary. If GPS signal is lost, the sUAS will use the internal barometric altimeter as a failsafe along with the vertical distance sensors inherent with the DJI t600’s design (DJI Vision Positioning Technology) to return to the predetermined safe a rea.

FUEL REQUIREMENTS

Aerial Oklahoma, INC seeks exemption from 14 CFR 91.151(a). The sUAS is powered by a battery, which provides up to 20 minutes of powered flight. Because of the absence of flammable operating fluids, an sUAS would not pose the same level of risk as a conventional aircraft. All participants in safe operating perimeter have been informed and educated, and have indicated consent. All Aerial Oklahoma, INC PICs will terminate flights when remaining battery power l evel
reaches 25%.

sUAS MAINTENANCE

Aerial Oklahoma, INC requests exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b). The sUAS does

not have an airworthiness certificate. Aerial Oklahoma, INC and/or DJI North America will conduct all maintenance on the sUAS in accordance with the flight operations manual and pilot operating handbook. All maintenance will be conducted by a trained Aerial Oklahoma, INC associate. Because of relatively small operating perim eter, any mechanical issues that may arise during flight could be quickly mitigated by terminating the flight.

Privacy

Because the purpose of operation is commercial, the consent to operate on a property or establishment of a contract would imply consent from the owner or authority with jurisdiction. Film or photos would only be taken of people who

consent.



### Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximi ty to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Aerial Oklahoma, INC’ s requested exemption, allowing for Aerial Oklahoma, INC

s UAS commercial operations f or the purpose of photography, film and

survey.

### Sincerely,

Jamin T Yeager
CEO Aerial Oklahoma, INC