### September 4, 2015
To: U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590
From: Jeffrey Cline 15400 Cedar LeafCt Cedar Springs, MI49319 616-337-3138 jeffrey.ted.cline@gmail.com Petitioning for ExemptionUnder Section 333. FAA authorization to operate a UAS for civil (nongovernmental) purposes other than for recreation orhobby. This is the new FAA streamlined UAS for commercial operation at orbelow 200 feet.
I seekreliefofoperation ofa UAS for commercial photography and videography.


### Itwill benefit the public byflying at a lower altitude and byproviding unique views in video and photographs. Safety will not adversely be affected since the FAA created safety guidelines that will be followed.
Therule is: PUBLIC LAW 112-95-FEB. 14,2012 126 STAT. 77 SEC 336. SPECIAL RULE FORMODEL AIRCRAFL (I) the aircraft is flown strictly for hobby orrecreational use; 

### The exemption requested is to operate a UAS for commercial purposes at orbelow 200 feet.
Thankyou,

Jeffrey ClinePursuant to Section 333 ofthe FAAModernization and Reform Act o:£2012 (the "Reform Act") and 14 C.P.R. Part 11, Jeffrey Cline, an individual, seeks exemption from requirements of 14 C.P.R. § 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103; 14 C.P.R.§ 91.105; 14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.15l(a); 14 C.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 91.407(a)(l); 14 C.P.R. § 91.409(a)(2); 14 C.P.R. § 417(a) and (b) to operate an unmanned aerial vehicle (U AV) in support ofcommercial aerial photography and videography ofindividual commercial, public, andresidential properties and structures with owners/operators permission and appropriate authorization.
Therequest for this exemption is in the Public Interest asthere are many consumer applications for the services that can be provided byUAV that are currently conducted bymanned aircraft. Using aU AV for many ofthese applications creates an environmentally friendly, lower cost solution to boththe operator and consumer. These aircraft can be operated safely, and without significant financial impactto the operator or any person orproperty on the ground in the event ofthe loss ofan aircraft. Utilizing these UA V will create a safe and more productive work environment. reduce environmental pollution and have
a positive impact onthe local economy, which is in the Public Interest. Jeffrey Clinerespectfully requestthat the FAA grant the following requested exemptions: 14 C.P.R.§ 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.P.R.§ 91.215; 14 C.P.R. § 91.405(a) and (d); 14 C.P.R. § 91.407(a)(1); 14 C.P.R.§ 91.409(a)(2); 14 C.P.R.§ 417(a) and (b).
14 C.P.R. 21, Subpart H: Airworthiness Certificate Jeffrey Cline requests an exemption from 14 C.P.R. 21, Subpart H. This Subpart establishes the procedures for the issuance ofan airworthiness certificate. Jeffrey Cline requests an exemption fromPart 21, Subpart H because the UAV is under 50 pounds (including payload) and meets an equivalent level of safety pursuant to Section 333 ofthe Reform Act due to its small size, light weight, andrestricted operating environment.
14 C.P.R. 43.11: Records for Inspections Jeffrey Cline requests an exemption from 14 C.P.R. 43.11. This partprovides thatmaintenance record entries bemaintained, that the inspector list discrepancies, and to afftx placards to the aircraft. Due to its small size the UAV proposed for use, does not have room for placards to beplaced in or onit and no inspections for UA V havebeen certified by FAA at the present time. However, as a condition to the grant ofthe exemption, Jeffrey Cline willperformthe inspections and time replaceable items recommended bythe manufacturer andkeep records and logbooks ofall maintenance and repairs.
14 C.F .R91.103: Preflight Action Jeffrey Cline requests an exemption from 14 C.F .R. 91.103. This regulation requires each pilot to take certain actions before flight to insure the safety offlight. As FAA approved flight manuals will not be provided for the UAV, an exemption is needed. Jeffrey Clinewill follow the manufactures preflight inspection.
14 C.F.R 91.105: Flight Crewmembers at Stations Jeffrey Cline requests an exemption from 14 C.F .R. 91.105. Jeffrey Cline requests an exemption from 14 C.P.R. 91.105 since this partis not applicable due to the UAV carrying no flight crewmembers. An equivalent level ofsafety will bemaintained by ensuring the pilot does not change inflight.

### SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER Department ofTransportation Federal Aviation Administration Petitioner: Jeffrey Cline Petition ofexemption from sections of; 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121,91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Description ofreliefsought; Jeffrey Cline seeks an exemption for commercial operation ofan unmanned aerial vehicle that isunder 50 pounds including payload.
The unmanned aircraft vehicle has an onboard camera system capable ofacquiring highresolution data. Proposed operations will offer real estate aerial photography, videography and aerial surveying services forother commercial industries.