Charles T. Lacey, Jr. PE

12137 Deer Haven Road Marriottsville, MD 21104
Commercial Pilot # 3207384

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Charles T. Lacey, Jr. , a commercial pilot and licensed site civil engineer , hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Charles T. Lacey, Jr. to pursue his commercial interests in providing
services to clients using a small advanced sUA S in the following areas: a erial photography and/or video for real estate, architecture, land surveying, engineering and other professional activities; television, public events, cinematography and news gathering; aerial insp ection/photography of residential/commercial structures, utility infrastructure; live video to assist with search and rescue operations; training in the use and application of a UAS

. Charles T. Lacey, Jr. states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have

ag re ed to be within the UAS radius during filming and photography applications.

Charles T. Lacey, Jr. has demonstrated the ability to safely and effectively fly the DJI Phantom 3 and will comp l y with all FAA regulations and all state or local laws regardi ng operations of sUAS.

I, Charles T. Lacey, Jr.

, a licensed commercial pilot, am seeking the exemption because I am committed to complying with all of the rules, guidelines , limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I have described. Without the exemption request granted, I would be unable to safely and effectively run my business, and it is my intention to comply with the FA A and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of responsibilities I assume as operator; it also contains information regarding the aircraft, pub lic benefit and safety features, a nd similar petitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121 14 C.F.R. 91.151(a)14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215
14 C.F.R. 91.401

- 91.417

I, THE OPERATOR , ASSUME THE FOLLOWING RESPONSIBILITIES 1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Opera tions for the purpose of closed

- set motion picture and television filming are not permitted.
3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determ ine compliance with the 87 knot speed restriction. In no case
will the sUAS be operated at airspeeds greater than the maximum sUAS operating airspeed recommended by the
aircraft manufacturer.
4. The sUAS must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The s UA S m

us t be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be
able to us e human vision unaided by any device other than corrective lenses , as specified on the PIC’s FAA

- issued
airman medical certificate or U.S. driver’s license. 6. All operations mus t utilize a visual observer (VO). The sUAS mus t be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be us ed to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mus t be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC mus t be designat ed before the flight and cannot transfer his or her designation for the duration of the flight. The PIC mus t ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the s UAS and conduct its operat ions in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents mus t be accessible during s UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and the limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and mus t be followed. Otherwise, the operator mus t fol low the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enfo rcement official upon request. The operator mus t also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator mus t 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 revisions to the operating documents. 8. Any s UAS tha t has undergone maintenance or alterations that affect the s UAS operation or flight characteristics, e.g., replacement of a flight critical component, mus t undergo a functional test flight prior to conducting further operations under this exemption. Functio nal test flights may only be conducted by a PIC with a VO and mus t remain at least 500 feet from other people. The functional test flight mus t be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is resp onsible for maintaining and inspecting the s UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC mus t conduct a pre

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

- flight inspectio n mus t 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 s UAS, the aircraft isprohibited from operating until the necessary maintenance ha s been performed and the UAS is found to be in a

condition for safe flight. 11. The operator mus t follow the s UAS manufacturer’s maintenance

, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each s UAS operated under this exemption mus t comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC mus t hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC mus t also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.
The PIC mus t 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

s 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, vessels, vehicles and structures. PIC qualification flight hours and currency mus t be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated
under this e xemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC mus t operate the s UA S with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. s UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations mus t be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not
authorized.
16. The s UA S may not operat e 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 current FAA

- published aeronautical char t, 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 mus t be made available to the Administrator or any law enforcemen t official upon
request.
17. The s UA S 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 s UAS loses communications or loses its GPS signal, the s UA S mus t return to a pre

- determined location within the private or controlled

- access property.
19. The PIC mus t abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considerin g wind and forecast weather conditions) there is enough available power for the s UA S 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.
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 un der the terms of the attached COA. 6
22. All sUAS operated in accordance with this exemption mus t be identified by serial number

. 23. Documents us ed by the operator to ensure the safe operation and flight of the s UAS and any documents required under 14 CFR §§ 91.9 and 91.203 mus t be available to the PIC at the Ground Control St ation of the s UAS any time the aircraft is operating. These documents mus t be made available to the Administrator or any law enforcement official upon request.
24. The s UA S mus t remain clear and give way to all manned aviation operations and activities at al l times.
25. The s UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations mus t be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and
structures unless: a. Barriers or structures ar e present that sufficiently protect nonparticipating persons from thes UA S and/or debris in the event of an accident. The operator mus t ensure that nonparticipating persons remain under

such protection. If a situation arises where nonparticipating persons le ave such protection and are within 500 feet of
the s UA S , flight operations mus t cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for opera ting 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 undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonpartic ipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission 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 the applicable COA mus t be reported to the FAA's U AS Integration Office (AFS−80) within 24
hours. Accidents mus t be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material re spects to relief previous ly requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes pu blic safety. Charles T. Lacey, Jr. is petitioning for an exemption to operate a DJI Phantom 3 with a built

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit
the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

- fly zone feature.
The DJI Phantom 3 also has a failsafe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

 The petitioner will only operate its sUAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas with in the sterile area described in the FOPM. Such operations will ensure
that the sUAS will "not create a hazard to us ers of the national airspace system or the public."

 When flying the sUAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right

- of

- way to avoid flying in the proximity of full

- scale aircraft. Maximum flight time for each operation
will be 30 minutes.

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserv e flight time to safely land the

sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videography is planned. Minimum crew for each ope ration shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

 The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current
FAA medical certificate.

 The sUAS operated by the petitio ner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneous ly move vertically and horizontally.