5 Southwest Drive  Stamford  CT  

06905

O/F: (203) 890 9500  ECM C: (203) 856 2828 

 KWM C: (203) 912 4505

 

The Managed Project, LLC

Kenneth W. Myers, President

5 Southwest Dr.

Stamford, CT, 06905

ken@themanagedproject.com

203-890-9500

 

Date: October 26, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Kenneth W. Myers for Exemption Pursuant to Section 333 of the

FAA Reform Act.

 
5 South west Drive  Stamford  CT  

06905

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 KWM C: (203) 912 4505

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Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, Kenneth W. Myers, owner and operator of Small Unmanned Aircraft

Systems (“sUAS”) equipped to conduct aerial data collection, aerial inspections, aerial surveys

and photography & videography and monitoring, hereby applies for an exemption from the

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUAS, so long as

such operations are conducted under the conditions outlined by the FAA as required by

Section 333.1

The proposed exemption, if granted, would allow Kenneth W. Myers to conduct commercial

operations of small unmanned aircraft systems (“sUAS”) meeting or exceeding all of the

operational and safety requirements Congress has set forth in Section 333. Statutory

Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems” provides

a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the

NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the

guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear

that Section 333 provides a mechanism for “expedited operation authorization” if several

factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS

operations.

We have closely reviewed the FAA’s existing exemption grants under section 333, and submit

this request as being materially similar to Exemptions 11430, 11365, 11409, 11209, 11111

among others. We are fully prepared and willing to operate under (and abide by) the

exemptions already granted and the conditions required in Exemptions 11430 and 11365. 

The detailed request below is provided to further demonstrate our understanding of the

rationale for the FAR exemption requests and associated decisions by the FAA, as well as

provide a basis for establishing our need for the same.

We hope the FAA determines that good cause exists for not requiring publishing petition

summary in the Federal Register as this request does not set a precedent and parallels

existing grant authorizations.

Regards,

Kenneth W. Myers
5 South west Drive  Stamford  CT  

06905

O/F: (203) 890 9500  ECM C: (203) 856 2828 

 KWM C: (203) 912 4505

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The Petitioner Requests Relief From the following regulations:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.405

14 C.F.R. 91.407

14 C.F.R. 91.409

14 C.F.R. 91.417

Kenneth W. Myers is petitioning for exemption to enable Kenneth W. Myers to

operate; [DJi Phantom 3 (approved grant #13052)], [DJi Inspire 1 (approved grant

#13055)] each weighing less than 10 Lbs. and utilizing flight controllers known and

familiar to the FAA – and having the required safety features; GPS, loss of signal RTL,

GEO fence, low battery RTL, real-time telemetry, OSD, etc. See below.

The sUASs will be equipped with cameras or imagers, stabilizing gimbals and OSD

(on screen displays) providing the PIC with GPS strength, altitude, airspeed, battery

life and direction. Our UAS flight controllers utilize GEO fence to limit the altitude

above the ground and limit the radius of the distance it flies from the PIC. Our UASs

have GPS guided failsafe functions allowing the autopilot system to fly back to the

launch site autonomously. If the transmitter is disconnected the system will

automatically trigger return to home and will land safely.

Kenneth W. Myers owns and operates a project management and inspection services

company. Project Managers (like Kenneth W. Myers) have long worked under

industry standard operating procedures and industry best practices. 

Kenneth W. Myers is a native US Citizen.

Our commercial activities would include:

• Aerial data collection, survey / mapping

• Aerial Infrared surveys of physical plant, assets, infrastructure, solar panels,

structures, construction
5 South west Drive  Stamford  CT  

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• Aerial photo & video surveys of physical plant, assets, infrastructure, solar

panels, structures

• Real Estate & marketing promotion (non-closed set)

• Aerial videography and photography

• Agricultural surveys

• Research and environmental monitoring

• Aerial Data Collection

FCC INFORMATION

Our transmitters used for controlling the sUAS comply with part 15 of the FCC

rules. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference,

(2) This device must accept any interference received, including interference that may

cause undesired operation.

Our radio transmitters used for controlling the sUAS’ are wireless technology which

has been tested and found to be compliant with the applicable regulations governing

a radio transmitter in the 2.4GHz or 5.8GHz frequency range.

STANDARD OPERATING PROCEDURES (unless revised per FAA grant of exemption)

1. Operations authorized by this grant of exemption are limited to the specific UAS

approved in the grant, 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. Operations for the purpose of closed-set motion picture and television filming are

not permitted.

3. The UA 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

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 400 feet above ground

level (AGL). Altitude must be reported in feet AGL.
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5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use 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 must utilize a visual observer (VO). The UA must be operated within

the 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 messaging 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. All documents needed to operate the UAS and conduct its operations in

accordance with the conditions and limitations stated in the grant of

exemption “operating documents.” The operating documents must be accessible

during UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in this exemption and the

procedures outlined in the operating documents, the conditions and limitations

herein 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 operating 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 this grant of exemption. If the operator determines that

any update r revision would affect the basis upon which the FAA granted this

exemption, then 4the 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 revisions 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 conducting further operations under

this exemption. Functional test 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.
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9. The operator is responsible 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 prohibited 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 requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must 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 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, vessels, vehicles and structures.

PIC qualification flight hours and currency must 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 exemption are permitted under the terms of this exemption. However, 5

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 must operate the UA

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
5 South west Drive  Stamford  CT  

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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 current

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

pre-determined 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 5 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 under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have identification

(N−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 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the aircraft is

operating.
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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

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator must

ensure that nonparticipating persons remain under such protection. If 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 permission 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 undue hazard. The PIC, VO, operator trainees

or essential persons are not considered nonparticipating 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 must be

reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents

must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov. If this exemption permits operations

for the purpose of closed-set motion picture and television filming and production,

the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual

(MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day
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notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating

persons consenting to be involved and necessary for the filming production, as

specified in the exemption holder’s MPTOM.

HOW THIS REQUIST IS TO THE BETTERMENT OF OUR COMMUNITY

Kenneth W. Myers sUAS are powered by batteries, smaller, lighter and more

maneuverable than larger aircraft running on combustible fuel, it operates at lower

altitudes with no people on board and will thereby reduce current risk levels

associated with traditional aircraft, enhance safety and diminish the likelihood of

death or serious bodily injury. Also with a small payload and typical flight time of

only 10-25 minutes, there is little or no risk to national security.

Low level photos and video are far more effective than ground or high altitude

manned aircraft imagery for displaying detailed characteristics of ground based

objects or elevations required for plant, asset and structural inspection with standard

or infrared cameras. The applicant is aware of costs associated with full-sized

helicopters or planes for parallel purpose, which is proven more costly than many

potential clients have been able to afford. The benefits of reduced cost and improved

quality of presentation from the UAS will be incredibly valuable to clients.
5 South west Drive  Stamford  CT  

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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Kenneth W. Myers requests an exemption from the following regulations as well as

any additional regulations that may technically apply to the operation of the sUAS

System.

14 CFR Part 21, Airworthiness Certificates:

This part establishes the procedures for the issuance of an airworthiness certificate.

While the FAA continues to work to develop airworthiness standards for Unmanned

Aerial Systems, we request an experimental certificate be issued for our UAS’s under

either or both of the following provisions: 21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft

equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other

operations to show compliance with the airworthiness regulations including flights to

show compliance for issuance of type and supplemental type certificates, flights to

substantiate major design changes, and flights to show compliance with the function

and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as

market surveys, sales demonstrations, and customer crew training, we would expect

that an experimental certificate would permit our commercial purpose as well. The

aircraft will not carry persons or property, will not carry fuel, and will only fly under

strict operational requirements. Combined with the UAS lightweight, being

constructed primarily of carbon fiber and plastic in conjunction with the ability to

utilize emergency parachute systems. We propose that the UAS will be at least

as safe, if not safer, than a conventionally certificated aircraft performing the same

mission. If an experimental airworthiness certificate is not appropriate for this

application, then we request an exemption of 14 CFR Part 21, Subpart H, and the

requirement for an airworthiness certificate in general, citing the equivalent level of

safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks:

These regulations provide that each aircraft must display "N" and the aircraft's

registration number in letters at least 3 inches high. Additionally, the aircraft must

display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance

to the cabin, cockpit, or pilot station. The sUAS does not have an entrance in which

the word "EXPERIMENTAL" can be placed, and may not have a registration number

assigned to it by the FAA. We will display at the ground station a flag or banner that
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containing the words "Unmanned Aircraft Ground Station." Since the aircraft will

operate within 3/4 NM of the ground station, the banner should be visible to anyone

that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness

certificate: As no such certificate will be applicable in the form contemplated by the

FARs, this Regulation is inapplicable. 

91.119 Minimum safe altitudes:

The regulation states that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

typical mission of the sUAS would be inspect or survey persons, vessels, vehicles or

structures it would be necessary to operate closer than 500 feet to the items listed.

The hazard to persons or property on the surface will be very limited. Therefore we

maintain that due to the small size of the UAS, the hazard to persons, vehicles and

structures is minimal compared to manned aircraft, which should be considered in

granting the exemption. The exemption is not unlike 11062, 11136, and 11111

among others.

CFR 91.121 Altimeter settings:

The regulation requires that aircraft shall maintain cruising altitudes by reference to

an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly

below 400 feet AGL and will not need to maintain cruising altitudes in order to

prevent conflict with other aircraft. An Above Ground Level altimeter measurement

above the takeoff point is transmitted via radio from the sUAS on-board computer to

the display screen held by the PIC, providing a constantly updated AGL readout. The

Pix4D flight controller can be configured to geo-fence the UAS under the 400’

maximum altitude.

14 CFR 91.151 Fuel requirements for flight in VFR conditions:

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing

and to fly after that for at least 30 minutes. The purpose of this is to provide an

energy reserve as a safety buffer for delays to landing. Since the aircraft will never fly

more than 3/4 NM from the point of intended landing, a full battery charge at launch

will ensure that we meet the reserve energy requirement of this paragraph. 30%

minimum reserve for immediate landing.

14 CFR Subpart E (91.401- 91.417) -Maintenance, Preventive Maintenance,

Alterations: The regulation provides that the operator is primarily responsible for

maintaining the aircraft in an airworthy condition, including compliance with part 39

and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for
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return to service by a person authorized under 43.7" after maintenance and

inspection. It is our intention that the PIC perform maintenance and

inspection of the aircraft and "be authorized to approve the aircraft for return to

service." The PIC will ensure that the aircraft is in an airworthy condition prior to

every flight and in addition conduct detailed inspections after every five hours of

flight. All maintenance will be performed by the PIC in accordance with the

manufactures manual. If required maintenance is beyond the ability of the PIC the

maintenance will be performed by the manufacturer or their designated

repair facility. The PIC will document work performed in accordance with 91.417. We

feel that due to the size, construction, and simplicity of the aircraft, the PIC can

ensure an equivalent level of safety.

14 CFR 91.405(a), 407(a), 409(a) (1) & (2), 417(a) & (b)

Section 91.405(a) prescribes that: “(a) 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,”

Section 91.407(a) prescribes that: “(a) No person may operate any aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under 43.7 of

this chapter; and (2) The maintenance record entry required by 43.9 or 43.11, as

applicable, of this chapter has been made.”

Section 91.409(a) prescribes that: “(a) Except as provided in paragraph (c) of this

section, no person may operate and aircraft unless, within the proceeding 12

calendar months, it has had – (1) An annual inspection in accordance with part 43 of

this chapter and has been approved for return to service by a person authorized by

43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness

certificate in accordance with part 21 of this chapter.”

Section 91.417(a) and (b) prescribe, in summary, that each registered owner and

operator of an aircraft shall keep records of maintenance, alterations, service life, and

inspections.

Since, if an exemption is granted, the SUAS in question will not carry an

airworthiness certificate, and will not have established standards with which to

determine it airworthiness, we request exemption from the above listed regulations.
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Instead, the SUAS will be operated and maintained by the PIC per the manufacturers

operating and maintenance manuals for inspecting, maintaining, and repairing the

sUAS. Further, all flight operations will be recorded by way of an entry in the Log

Book.

The exemption request is not unlike exemptions granted in 11136 and 11062, among

others.

CONCLUSION

By granting Kenneth W. Myers the requested exemptions, the FAA will help drive

development of safe and successful commercial UAS operations and will advance the

public knowledge base for such operations of UAS. Kenneth W. Myers is committed to

promoting the UAS research efforts of policymakers by sharing data from its

commercial UAS operations and serving as a resource for future UAS research

operations.

As pointed out in this application, all the sUASs which our company would use,

under authorization by the US DOT-FAA, are small, light-weight devices operated

within the line of sight of the Pilot-in-Command (PIC), less than 400 feet above the

ground and outside 5 miles from any airport or location with aviation activities,

unless the air traffic control authorities (ATC) have been notified and have authorized

each flight within a radius of this distance.

Kenneth W. Myers seeks an exemption pursuant to 14 C.F.R. and Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation

of our UAS commercially, without an airworthiness Certificate.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the

interests of the public, by allowing Kenneth W. Myers to safely, efficiently, and

economically operate sUASs commercially within the NAS. Wherefore, in accordance

with the Federal Aviation Regulations and the FAA Modernization and Reform Act of

2012, Section 333, Kenneth W. Myers respectfully requests that the Administrator

grant this Petition for an exemption from the requirements of 14 C.F.R Sections.

Sincerely,

Kenneth W. Myers, President

The Managed Project, LLC
5 South west Drive  Stamford  CT  

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Attachments: operating manuals & safety check lists for the requested UAV’s.