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U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave, SE Washington, DC 20590 March 9, 2016 **RE: Petition	for**  **Exemption Pursuant	to**  **Section	333	of	the	FAA Modernization	and**  **Reform A**  **ct	of	2012 and	Part	11	of	the	Federal	Aviation	Regulations**  Dear Sir or Madam : Petitioner, 360 OnSite Security, LLC hereby petitions the Federal Aviation Administration (FAA) for an exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 . **Operator :**  360 OnSite Security , LLC P.O. Box 1531 Cy press, TX 77410 - 1531 Owner: James Hughes Phone: 281
- 315 - 3660 Email: jim.hughes@360onsitesecurity.com **Specific	applicable	regulations	from	which	relief	is	required	(CFRs) :**  Petitioner, 360 OnSite Security , LLC is requesting relief from the following Federal Aviation Regulations (FARs) 14 CFR §§ : 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b),2

to the extent necessary to allow 360 OnSite Security, LL C to commercially operate Unmanned Aerial Systems to perform aerial data collection and reporting with remote sensors and instrumentation aboard the UA for the proposed operations listed
. You'll find that our request is similar to relief previously requested in: Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA −2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA −2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), 126 45 to Allied Drones (see Docket No. FAA
- 2014 - 0804), 11433A to Cape Productions (see Docket No. FAA - 2015 - 0223), and 15005 to Thomas R. Guilmette (see Docket No. FAA
- 2015 - 5829), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carryingno passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel. **How	the	Operator	will	Maintain	an	Equivalent	Level of	Safety**  **or	NO	Adverse	Impact to	Safety**  **:** 360 OnSite Security , LLC will ensure that the exemption does not adversely affect safety and will operate at a level of safety equal to existing regulations by operating with the following limitations and conditions:

 All operations will strictly adhere to manufactures owners, operators and maintenance manual.  All maintenance will be conducted in accordance with manufacturers recommendations and documented in the aircraft logbook  Preflight operations will b e conducted in accordance with the manufacturer's recommendation and preflight checklist.  All operations will be conducted during daylight hours.  All operations will be conducted in uncontrolled airspace, unless specific permission is granted by the controlling agency  All operations will occur below 400 feet AGL.  All operations shall utilize a VO. The UA must be operated within the VLOS of the PI C and VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s maintains VLOS capability . The VO and PI C must be able to communicate verbally

at all times; electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO.  Aircraft will remain within unaided visual line of sight (VLOS) of the PI C and visual observer (VO) to see and avoid other aircraft or objects aloft or on the ground.  PI Cs will operate the UA not closer than 500 feet to any nonparticipating person without exception.  All operation will be at speeds less than that recommended by the manufacturer, and at all times less than 87 knots.3

 All operations will be condu cted in visual meteorological conditions (VMC) with visibility of at least three statute miles.  All operations will be conducted with at least 500 feet below clouds and with a horizontal separation of at least 2000 feet.  All PI Cs will be required to hold an Airline Transport Pilot, a Commercial Pilot, a Private Pilot, a Recreational Pilot, or a Sport Pilot certificate with a current FAA Airman Medical Certificate or a valid U.S. driver’s license.  Under all situations, the PI C is responsible for the safety of the operation. The PI C is also responsible for meeting all applicable conditions and limitations as prescribed in this exemption and ATO
- issued COA, and operating in accordance with the operating documents.  PI Cs will adhere to all flight review requirem ents specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.  All operations will strictly adhere to FAA regulations with safety being the number one priority
.  PI C qualifications: The PIC will be able to demonstrate the ability to safel y operate the UAS in a manner consistent with how it will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures befo re operating non
- training, proficiency , or experience
- building flights under this exemption.  PI C qualification flight hours and currency may be logged in a manner consistent with 14 CFR § 61.51(b), however UAS pilots must not log this time in the same columns or categories as time accrued during manned flight. UAS flight time must not be recorded as part of total time.  All training operations will be conducted during dedicated training sessions and may or may not be for compensation or hire.  UAS that have undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations. Functional test flights will only b e conducted b y a PIC with a VO and must remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property.  For UAS operations where GPS signal is necessary to safel y operate the UA, the PI C will immediately

recover/land the UA upon loss of GPS signal.  If the PI C loses command or control link with the UA, the UA must follow a pre
determined route to either reestablish link or immediatel y recover or land.  The UA S, the UAS PI C, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. **How	Granting	the	Exemption	would	be	in	the	Public	Interest :**  The primary purpose of 360 OnSite Security, LLC i s to use UAS to perform aerial data collection and reporting using the benefits of UAS which are safe and cost effective compared to using complex and expensive manned aircraft for the proposed operations listed
. UAS allow the completion of many tasks at a fraction of the cost of using traditional fixed and rotary wing4

aircraft or other conventional manned aerial methods
. Granting this exemption will enhance safety, lower costs, and improve the efficiency of operations. UAS greatly enhance efficiency and achieve a high level of safety . **Proposed	Operations :**  Th is request would permit 360 OnSite Security , LLC to research, develop, and commercially operate UAS to conduct: aerial data collection and reporting , aerial surveillance, aerial photography, aerial inspections, aerial survey s, aerial mapping, thermal imaging, infrared imaging, training and education , including inspection of utilities, transportation, and energy infrastructure, imaging for agriculture, real estate, events, search and rescue, and disaster response. The owner/manager of 360 OnSite Security , LLC , James Hughes is an experienced airline p ilot and airline pilot recruiter holding an Airline Transport Pilot Certificate and a current Flight Instructor Certificate. J ames Hughes , the Owner/Manager of 360 OnSite Security, LLC is also licensed by

the Texas Department of Public Safety PSB as a video surveillance and video alarm company . James Hughes has a great amount of aviation knowledge and experience with FAA rules an d regulations and with all aspects of fl ying and will serve the operations with the highest level of safety
. **Make	and	Model	of	the	Aircraft	for	Proposed	Operations :**  360 OnSite Security , LLC will conduct operations using UAS that have previously been approved b y the Secretary of Transportation under Section 333 at regulatory docket FAA
- 2007 - 3330 at www.regulations.gov
. All operations will be conducted with aircraft weighing less than 55 pounds including payload . Operations wi ll not include foreign civil aircraft. Make and model of aircraft for proposed operations include: 3D Robotics Iris DJIPhantom 1 DJIPhantom 2 DJIPhantom 3 DJIPhantom 4 DJIInspire 15

DJIInspire 2 Spreading Wings S900 Yuneec T yphoon H Yuneec Tornado H920 Respectfully , James Hughes 360 OnSite Security , LLC