U. S. Department of Transportation, Docket Operations

West Building Ground Floor Room w12
- 140 1200 New Jersey Avenue, S.E
. Washington, DC 20590 **Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use of Unmanned Aircr aft Systems**  August 20, 2015 **Petitioner** : Siteswork.com, LLC David S. Smith, Owner 306 Woodstock Ave. Kenilworth, IL 60043 Cell: 847

- 256
- 8918 Email: dsmith@siteswork.com Website: www.siteswork.com Dear Sir or Madam: This application is substantially based on the FAA's findings in Exemption No. 11062 granted to Astraeus Aerial on September 25, 2014, and in reliance on the analysis provided therein. Siteswork.com, LLC designs and manages websites for various types of sports teams, with golf and tennis facilities being the primary focus currently. These websites include data consisting of photography and videography of the venues. We at Siteswork.com, LLC would like to enhance our services by offering videography that can be collected us ing Small Unmanned Aircraft Systems (sUAS). An example is performing flyovers of golf and tennis facilities to capture the scope and quality of the facilities. The data collected by the sUAS will be done in a competent and safe manner, following local, sta te, and federal laws and regulations. The operation of the sUAs will be done with the authorization and supervision of the managers of these facilities. **1. Sections from which exemptions are sought: Application is hereby made for exemption from:**  a. FAA Modern ization and Reform Act of 2012, PL 112

- 95 FEB. 14, 2012, Section 333 b. 14 CFR Part 21, subpart H c. 14 CFR Part 61.113(a) and (b) d. 14 CFT Part 91: 1.1. 91.103(b)(2) 1.2. 91.105 1.3. 91.109 1.4. 91.119 1.5. 91.121 1.6. 91.151 1.7. 91.405 1.8. 91.407 1.9. 91.4091.10. 91.417

**2. Relief sought:** 

 Siteswork.com wishes to operate sUAS for commercial purposes to include (but not limited to) videography, photography, inspections and analyses. This relief is sought because commercial use of UAS's is currently prohibited by law unless performed under an exemption.
 This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources, and have similar operating characteristics: o MULTIROTO R service

- drone G4 models o DJI Ph antom and Inspire models o 3DR Solo models **3. Public bene**  **fit:**

 Use of UAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods:
 Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line inspections) and due to other dangero us activities that can be avoided (e.g., scaffolding/rigging failures during st ack or bridge inspections).
 Reduces the cost of obtaining such information, which benefits consumers and the economy.
 Reduces environmental impact by eliminating sources of hydr ocarbon emissions from manned aircraft.
 The videography displayed on the internet gives the public a more detailed and realistic view of facilities so that they can make informed choices about using those facilities. **4. Safety not adversely affected:** 
a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. c. All flight operations will be conducted by two individuals who will maintain verbal comm unication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations: i. A Pilot in Command (PIC) with extensive experience flying sUAS: ii. A Visual Observer (V). d. All flight operati ons will comply with the following: i. The manufacturers' Aircraft Flight Manuals and operation guidelines ii. Siteswork.com flight operations policies including lost communication and other emergency and safety procedures.iii. Conducted in Visual Meteorological Conditions (VMC) during daylight hours

iv. PIC and VO will maintain Visual Line of Site (VLOS) at all times. v. Pre
- flight inspections (including ground control station, if any) and safety risk assessments will be conducted p rior to each flight vi. Flight altitudes will remain below 400 feet above ground level vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into Class B, C or D airspace. Not be made near persons as required in 14 CFR 91.119 an d not over persons on the ground without their prior permission ix. Each flight will be logged in both the PIC's logbook and the aircraft logbook x. Not exceed 75% of the battery or fuel capacity of the aircraft, o r 30 minutes, whichever occurs fir st. xi. Any incidents will be reported within 24 hours of occurrence. xii. All other applicable regulations concerned with the operation of aircraft. f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data. I n s ummary , Siteswork.com , LLC seeks an exemption under 14 CFR § 11.81 to allow commercial use of sUAS which will be used to collect videography of sports facilities, primarily golf and tennis clubs. The videography will be used to enhance the websites of these faci lities so that the public can get a realistic view of the scope and quality of the facilities. The videography will be collected in a safe and competent manner, using a PIC, VO, and under the supervision of the management of the facilities. Please advise us of any additional information or changes that are required.
Sincerely, David S. Smith Owner, Siteswork.com , LLC