February 27, 2016

Unmanned Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave. SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal
Aviation Regulations from: 14 CPR 21 subpart H; 14 CPR 45.23(b); 14 CPR 61.113(a); 14 CPR 91.7(a);

14 CPR 91.9(b)(2); 14 CPR 91.103;14 CPR 91.109; 14 CPR 91.119(c); 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.203 (a) and (b); 14 CPR 91.405 (a); 14 CPR 91.407 (a) (I) 14 CPR 91.409 (a)(!) and (2); 14 CFR 91.417(a) and (b)

To whom it may concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 1 4 CPR Part 11, Construction Staking Solutions, Inc. herein after also known as the operator, hereby applies for an exemption from the listed Federal Aviation Regulations to allow for commercial oper ation of Small Unmanned Aircraft Systems (UAS), so long as such operations are conducted within and under the conditions outlined herein or as established by the FAA as required by Section 333.

Commercial operation of UAS, as described herein, which a re equipped with cameras and sensors, would operate in the following manner:

• Aerial Photography and Videography for both public and private customers involving real estate, construction, mining and utilities industries.

• Aerial surveying, mapping and data collection (as

- built, development or while being constructe d)

• Patrolling Utility, Pipeline and Railway right of ways

• Educational and research operations

• Wildlife and forestry monitoring

• Aid in disaster and emergency management and monitoring, civil first response, communications relay, search and rescue, monitoring fire hazards, cleanup effort supervision, damage assessment and

estimation under authority a nd support of local officials

• Aid civil engineering: waterways and shipping, fo restry, fishery protection, pollution control and

air sampling and crop performance

• Product Demonstrations

• Telecommunications infrastructure inspection

• Utility, Energy systems and electrical engineering inspections and asset management• Agricultural surveying and produce field management

• Livestock management and accountability

• Video Documentation of Wild Horses, Equine sports and other Open Air Events

• Aerial filmmaking and photography for public and private use including television, public events, and live newsgathering

• Construction site inspections and monitoring

• Oil and gas pipeline inspection/patrolling and oil

- field inspection

• Real estate and marketing

• Aerial event security, surveillance and crowd management

• Aerial imagery evidence for property insurance claims

• Evaluation of disaster and catastrophic events.

As described fully below, the requested e xemption would permit the operation of UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operat ions in the industr y presently using conventiona l aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "....establish requirements for the safe operation of such

aircraft systems in the national airspace system."

The name and address of the applicant is:

Construction Staking Solutions, Inc. Attn: Bradley S Heath 375 Normandy Heights Road Taylorsville, KY 40071

Ph one : (502) 710

- 9274
Email: ssi@twc.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)
14 CFR 61.l 13(a)
14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103
14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121
14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b)
14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2)14 CFR 91.417 (a) & (b)

Regulatory Basis for Exemption Request

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this dete1mination, the Secretary is required to determine which types of UA do not create a hazard to users

of the NAS or the public or pose a threat to national security in light of the following:

The UA's size, weight, speed, and operational capability;

• Operation of the UA in close proximity to airpo r ts and populated areas

• Operation of the UA within visual line of sight of the operator.

The aircraft intended for use by the o perator includes the DJI Phantom 3 Advanced, DJI Phantom 3
Professional and DJI Inspire 1 . All of these aircraft have previously been approved by the FAA in other applicant's Sect ion 333 exemptions.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft

in the national ai rspace system." Id. §333(c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act,

wh ich includes UA, from the requirement that al l civil aircraft must ha ve a curr ent airworthiness

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §4470l (f) See also 49 USC §4471l(a); 49 USC §44704; 14 CFR §91.203 (a) (!).

Construction Staking Solution Inc.’s UAS are rotorcraft, weighting 55 or fewer pounds including payload. The UA operate under normal conditions at a speed of no more than 50 knots and have the capability to hover and move in the ve1tical and horizontal plane simultaneously. The UA will be operated only in line of sight and will be o perated only within a predetermined and protected flight area under the permission of the prope1ty representative. The UA will be operated under the below listed limitations and conditions to which the operator agrees to 

### be bound when conducting comm ercial operations under an FAA issued exemption, as well as any other limitations the FAA may place on future operations. Such operations will insure that the UA will "not create a hazard to users of the national airspace system or the public as per the Reform Act Section 333 (b).

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significan t public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UA for aerial data collection, the grant of therequested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the

FAA grant the requested exemption without delay.

The FAA has issued grants of exemption in circumstances similar in material respects to those presented in this petition. In Ex emptions Nos, 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 11109

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

14 C.F.R. Part 21, Subpart H, entitled Airwort hiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). The Federal Aviation Act (49 U.S.C.§44701 

### (±)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requireme nt for an airwort hiness ce1iificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the pa11icular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an
airwo1ihiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airw011hiness

certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder are rotorcraft weighing less than 55 pounds including payload,

car ries neither a pilot nor pass enger. Carries no explosive materials or flammable liquid fuels, and operates exclusively within visual line of sight of the pilot in command (PIC) and a visual observer (VO). They operate at a speed of less than 50 knots and have the capability to h over and move in the
ve11ical and horizontal plane sim ultaneously within a predetermined and protected flight area as described below. Such operations will insure that the UASs will not create a hazard to the users of the national airspace system. Unl ike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation. The F AA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness ce11ificates issued under 14

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no

credible thr

eat to national security posed by the UA, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carr y a substantial

external load.

The Secretary of Transportation has previously dete1mined that these aircraft meets the conditions of Section 333. Therefore, the FAA has found that request of relief from 14 CFR part 21, and any

associated noise certi fication and testing requirements of part 36, is not necessary. This has been stated

in exemptions to this regulation in Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230

The applicant proposes that the exemption requested herein apply to aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operati ons under the cu rr ent regulatory structure.These limitations and conditions to which the operator agrees to be bound when conducting commercial

operations under an FAA issued exemption include:

1. The UA; DJI Inspire I , DJI Phantom 3 Advanced and DJI Phantom 3 Pro fessional will weigh less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend the exemption.

2. Operations for the pur pose of closed

- set motion picture and television filming are not permitt ed.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 200 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to b e able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued airman medical ce1iificate or U.S. driver's

license

6. All operations must utilize a visual observer (VO). The UA must be operated within th e visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic mess aging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. The exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in the grant of exemption, are hereinafter refe1Ted to as the operating documents. The operating documents must b e accessible during UAS operations and made available to the Administrator upon request. I f

a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations therein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its op erating

documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any updat e or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or

re visions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conductin g further operations under this exemption. Functionaltest flights may only be conducted by a PIC with a VO and must remain at least 500 feet

from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is respon sible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibite d from operating until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight.

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requiremen ts for the aircraft and aircraft components.
12. Each UAS operated under the exemption must comply with all manufacturer safety bulletins.

13. A PIC must hold either an airline transport, commercial, private, recreational, or sport pilot
certificate. The PIC must also hold a current FAA air man medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a te1Titory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, v essels, vehicles and stru ctures. PIC qu alification flight hours and

curr ency must be logged in a manner consistent with 14 CFR 

### § 61.5l (b). Flights for thepurposes of training the operator's PICs and VOs (training, proficiency, and experiencebuilding) a nd determining the PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are pe1mitted under the terms of the exemption. However, training operations may only be conducted during dedicated tra ining sessions. During training, proficiency, and experience

- building flights, all persons not

essen t ial for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR 

### § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the cu rr ent FAA

- published aeronautical chart, unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled

- access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve po wer recommended by the

manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot

be conducted under the te1ms of the attached COA.

22. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N

- 6 Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.2 03 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at

all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons,
vessels, vehicles, and structures unless:

a. Bann ers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating pers ons remain under such protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating

persons; and

b. The owner/controller of any vessels, vehicles or structures has granted pe1mission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an u ndue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under the exemption.

27. All operations shall be conducted over private or controlled

- access property with pe1mission from the property owner/contro ller or authorized representative. Pe1mission from property owner/controller or authorized representative will be obtained for each flight to be

conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by t he applicable COA must be report ed to the FAA's

UASIntegration Office (AFS

- 80) within 24 hours. Accidents must be repor ted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the UAS operations

must comply with all applicable pa r ts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

14 CFR § 61.23 (a) & (c): Medical certificates: Requirements and duration.

This regulation sets forth medical certificate requirements for pilots

- in

- command of aircraft in that a

holder must have a first

- class medical certificate when exercising the PIC privileges of an airline transport pilot ce1tificate. Fmthe1more, the requirement states that the PIC must hold at least a secondclass medical certificate when exercising PIC privileges of a commercial pilot certificate, or must hold at

least a third

- class medical ce1tificate when exercising PIC privileges of a private pilot ce1tificate, recreational pilot ce1tificate, or flight instructor certificate. It also states that a person must hold and possess either a medical certificate issued under § 61.67 or a U.S. driver's license when exercising the privileges of a P IC of a sport pilot ce1tificate in a light

- sp01t aircraft other than a glider or balloon.

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot's certificates (discussed above) to operate a UAS with a U.S. issued driver's license, in lieu of an FAA

- issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow spo1t pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver's license. The FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 61.101 (e) (4) & (5): Recreational pilot privileges and limitations.

This section limits recreational pilots to non

- commercial operations and that they may not act as pilot in

command of a recreational aircraft for co mpensation or hire, or in the fur therance of a busin ess. Unlike a conventional aircraft that carries the pilot and passengers, the UA is remotely controlled with no living thing on board. The area of operation will be predetermined and in a prot ected flight area under the

perm ission of the prope1ty rep resentative, and all flights are planned and coordinated in advance. The FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 61.113 (a): Priva te Pilot Privileges and Limitations: Pilot in Command.

This section limits private pilots to non

- commercial operations and that they may not act as pilot in command of an aircraft that is carrying passengers or prope1ty for compensation or hire. Unlike a convention al aircraft that carri es the pilot and passengers, the UA is remotely controlled with no living thing on board. The area of operation will be predetermined and in a protected flight area under thepe rmi ssion of the property representative, and all flights are planned and coordinated in advance. The

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 61.315 (a): What are the privileges and limits of my sport pilot certificate?

This section limits sport pilots to non

- commercial operations and that they may not act as pilot in

com mand of an aircraft that is carr ying passengers or property for co mpensation or hire, or in the furtherance of a business. They also may not carry more than one passenger, fly at night, and under other restrictions that are outside of the scope of intended flights of the UA. Unlike a conventional

aircraft that c arries the pilot and passengers, the UA is remotely controlled with no living thing on board. The area of operation will be predetermined and in a protected flight area under the permission of the property representative, and all flights are planned a nd coordinated in advance. The FAA has issued the following exemptions to this regulation: Exemption Nos. I 1278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 91.7(a): Civil aircraft airw orthiness.

The regulation re quires that no person may operate a civil aircraft unless it is in a irwort hy condi tion. As

there will be no airworth iness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standar

d will exist for determining airwo rthiness. Given the size of the aircraft for maintenance and use of preflight actions as prescribed by the aircraft's manufacturer prior to each flight, and given the FAA's prior approval of the same types of aircraft to be used in previous exemptions to this requirement (as set forth in Exemptions Nos. 11278, 11275, 11267, 11260, 11253 and 11230) we believe we can maintain a high standard of safety and due regard as to the aircraft's airwort hiness during flight operations. The FAA has issued the fol lowing exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 91.119 (c): Minimum safe altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescr ibed for helicopters by the FAA. As this exemption is for UAS that are rotorcraft and the exemption requests authority to operate at altitudes up to 200 feet AGL, an exemption may be needed to allow such operations. As set forth herein, the UA will neve r operate at higher than 200 feet AGL, will always be operated under VLOS of both the PIC and VO, its

area of operation will be predetermined and in a pro tected flight area under the perm ission of the property representative, all flights are planned and coordinated in advance and the UA will remain clear of, and give way to all manned avia tion operations and activities at all times.

The equivalent level of safety will be achieved given the size, weight, speed of the UA as well as the location where it is operated and under the conditions previously stated. Compared to flight operationswith aircraft or rotorcr aft weighting far more than the maximum 55pounds proposed herein and the lack

of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 feet AGL. In a ddition, the low

- altitude operations of the UA will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has issued the following exemptions to this regulatio n: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 91.121: Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an

altimeter t hat is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the UA may not have a barometric altimeter, but instead a OPS altitude read out, an exemption may be needed. An equivalent l evel of safety will be achieved by the operator, pursuant to the manufacturer's published procedures and live flight data monitoring, confirming the altitude of the launch site shown on the OPS altitude indicator before flight. In the event that the OPS altitude read out system becomes none functional during flight, the UA will also have a pre

- programmed maximum flight limit of 200 feet programmed into them so that they may not fly above unapproved altitude limits. The FAA has issued the following exe mptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 91.lSl(a) (1): Fuel Requirements for 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 of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

The LiPo battery powering the DJI Inspire I , DJI Phantom 3 Advanced and the DJI Phantom 3

Professional provides approximately 20 minutes of powered flight. The PIC will not begin a flight unless there is enough available power for the UA to conduct the intended operation and to operate after

that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

Applicant believes that an exemption from 14 CFR §91.15l (a) falls within the scope of prior exemptions, and that flight with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.15 l(a) was intended to alleviate given the size and speed of the small UAS. Similar exemptions have been granted to other operations, including Exemptions Nos. 11278, 11275, 112 69, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR 

### § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections.These regulations require that an aircraft operator or owner "shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...," and

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant.

An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. 

### I f mechanical issues arise the UA can land immediately and will be operating from no higher than 200 fee t AGL and within VLOS of the PIC and VO. Prior to each flight, the PIC must conduct a pre

- flight inspection and
dete rm ine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperabl e components, items, or equipment. 

### If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. The FAA has issued the following exemptions to this regulation: Exemp tions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

Privacy

All flights will occur over private or controlled access prope1ty with the prope1ty representative or owner's prior consent and knowledge. Filming will be of people who have also consented to being

filmed or otherwise have agreed to be in the area where filming will take place.

All flights will occur in accordance with any state or local laws regardin g privacy.

UAS Information

sUAS's to be used are as follows but not limited to providing they are within the scope of the exemption granted by the FAA:



### 1. DJI Inspire 1

• Weight (Battery Included) 2935g

• Hovering Accuracy (OPS Mode) Vertical 0.5m, Horizontal 2.5m

• Max Angular Velocity Pitch: 300deg/s; Yaw l 50deg/s

• Max Tilt Angle 30deg/s

• Max Ascent Speed 5m/s

• Max Decent Speed 4m/s

• Max Speed 22m/s• Diagonal Distance 559mm (Landing gear lowered), 581mm (Landing gear raised)

a. DJI Inspire Gimbal

• Operating Curr ent

- Station: 750mA, Motion: 900mA

• Controllable Range

- Pitch:

- 90deg to +30deg

• Max Controllable Speed

- Pitch: 120deg/s, Pan: 180deg/s

b. DJI Inspire Battery

• Model (Standard) TB47

• Voltage 22.2v

• Capacity 4500mAh

• Energy 99.9Wh

• Net Weight 570g

c. DJI Inspire Remote Controller

• Frequency

o 5.725GHz

- 5.850GHz (Remote Controller to Remote Controller) o 2.400GHz

- 2.483GHz (Remote Controller to Aircraft)

• Battery Capacity 6000mAh

• Working Curr ent/Voltage l.2A@7.4V

2. DJI Phantom 3 Advanced (Exemption 13161)

• Weight (Battery Included) 1645 g

• Hovering Accuracy Vertical 0. 5 m, Horizontal +/

- 1 .5m

• Max Angular Velocity Pitch: 300deg/s; Yaw l 50deg/s

• Max Ascent Speed 5m/s

• Max Decent Speed 3 m/s

• Max Speed 16 m/s

d. DJI Phantom 3A Gimbal

• Controllable Range

- Pitch:

- 90deg to +30deg

e. DJI Phantom 3A Battery

• Type LiPo 4S

• Voltage 15.2 v

• Capacity 4480 mAh

• Energy 68 Wh

• Net Weight 365 g

f. DJI Phantom 3A Remote Controller

• Frequency

o 2.400GHz

- 2.483GHz (Remote Controller to Aircraft)

• Battery Capacity 6000mAh LiPo2S

• Working Curr ent/Voltage l.2A@7.4V3. DJI Phantom 3 Professional (Exemption 13178)

• Weight (Battery Included) 1645 g

• Hovering Accuracy Vertical 0. 5 m, Horizontal +/

- 1 .5m

• Max Angular Velocity Pitch: 300deg/s; Yaw l 50deg/s

• Max Ascent Speed 5m/s

• Max Decent Speed 3 m/s

• Max Speed 16 m/s

g. DJI Phantom 3P Gimbal

• Controllable Range

- Pitch:

- 90deg to +30deg

h. DJI Phantom 3P Battery

• Type LiPo 4S

• Voltage 15.2 v

• Capacity 4480 mAh

• Energy 68 Wh

• Net Weight 365 g

i. DJI Phantom 3P Remote Controller

• Frequency

o 2.400GHz

- 2.483GHz (Remote Controller to Aircraft)

• Battery Capacity 6000mAh LiPo2S

• Working Curr ent/Voltage l.2A@7.4V

Conclusion The use of UAS provide many benefits to the general public, such as: Decreased air pollution due to the enormous amount of leaded fuel needed to fly manned aerial vehicles, decreased noise pollution when near the public, Decreased air traffic congestion at airports and provides a more affordable and reasonable alternative to

curr ent options available to the consumer. As for safety, Small Unmanned Aerial Systems do not carry people or property so it provides less of a chance of injury in the case of an accident and because of the size and weight of manned aircraft the ground casualties can be far less or nonexistent in the case of a downed UAS vs a manned
aircraft.

Thank you for the consideration of these exemptions.

Sincerely,

Bradley S Heath Construction Staking Solutions, Inc. 375 Normandy Heights Road Taylorsville, KY 40071
502

- 710

- 9274

Email: ssi@twc.com