U.S. Department ofTransportation, Peter P. Miller 4981 Mallet Hill Dr Cincinnati, Oh 45244

Docket Operations West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, SE Washington, DC 20590

05/20/2015

Petition for 333 Exemption

I, Peter P. Miller, Airline Transport Pilot (airman certificate #3028069), of4981 Mallet Hill Dr. Cincinnati Oh. 45244, am petitioningthe Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) ofTitle 14, Code ofFederal Regulations (14 CFR). This proposed exemption would allow me to operate a DJI Phantom Vision 3 Quad Copter Unmai:med Aerial System (UAS) for the purpose of aerial mapping, videographer arid real estatephotography. The use ofa UAS for

. these activities will have a substantial social benefit. Itwill bring an over-head perspective to future customers thatwere previously only possible through the prohibitively expensive use ofrotorcraft and fixed wing aircraftwith expensive

camera equipment. I would bringthis service at an affordable price and due to the simple nature ofthe UAS, with substantial savings. Due to the ever-improving nature ofthis technology a new UAS can become obsolete within a few months ofrelease. I am also seeking an exemption in addition the to

one listed above, to include other unmanned aerial systems (UAS) that meet the operational limitations outlined in the notice ofproposed rulemaking (NPRM) pertainingto the operation ofsmall unmanned aircraft systems in proposed part 107 to Title 14 Code ofFederal Regulations (14 CFR). Safety I will utilize my knowledge as a professional pilotto maintain the highestlevel of safety during the proposed use ofthe UAS. Flight would consist ofthree parts: preflight, flight and postflight. The preflightwill consist ofextensive inspections ofthe area, the UAS and the airspace in which itwill be operating. A detailed inspection ofthe UAS will be conducted and all major systems will be examined, including power plant, airframe and controls. Any discrepancywill be noted and ifthe discrepancyaffects the safety ofthe flight, the flight will not: corimi.ence.

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. Operations will only cominericein reasonably**saf~** environments thatwill be strictly controlled during the flight ofthe 

### oAs. The areawillbe surveyed for powerlines,

### ] elevated lights and other propertywith the potential to affectthe safety ofthe flight There will be no flights within the proximity ofactive airports withoutfirst contactingthe appropriate agencies or authorities to ensure the highestlevel of safety and compliance with all regulations. Operations will also not commence where there is a reasonable possibility ofinadvertentphysical contactwith the populace. Duringthe flight portion ofthe operation, safetywill be the primary concern. Given the size, weight, speed and limited operating area ofthe UAS; flight will be inherently safe. The UAS will notbe operated above individuals not associated with its operation and care will be given to avoid propertythatwas noted during the preflight inspection ofthe area. Duringthe post-flight debrief, all individuals associated with the operation will evaluatethe success ofthe operation and address any concerns broughtforward aboutthe safety ofthe flight. Any pertinent issues will be noted and action will be taken to ensure the safety offuture flights. Exemptions from regulations All proposed exemptions from regulations are listed below and are accompanied by reasoning as to why itwould be unreasonable to comply with the regulation.

• 14 CFR § 21 SubpartH: Airworthiness Certificates and 91.203 (a) and (b): Certifications required

o Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, an exemption is requested and would meetthe requirements for an equivalentlevel ofsafety under 14 CFR part 11 and Section 333 ofP.L. 112-95 (Section 333)

• 14 CFR § 45.23: Display ofmarks; general

o An exemption is requested because the UAS has no cabin, cockpit or pilot station on which to display certain words or phrases. Furthermore, is would be unreasonable to mark the aircraftwith 2 inch lettering since the airframe has dimensions smallerthan the minimal lettering requirement Iwill place the word "Experimental" on the airframe ofthe UAS as required by§ 45.29(t) so that anyone assisting as a spotter and I will see the markings.

• 14 CFR § 91.9 (b) (2): Civil aircraft flight manual, marking and placard requirements

o An exemption is requested from the cited regulations because the UAS manufacturer does not supply a flight manual that contains information found in manuals supplied by manufacturers oftraditional aircraft. Also, due to the size, weight, speed and operating area ofthe aircraftto be utilized itwould be unrealistic to expectitto.

• 14 CFR § 91.119: Minimum safe altitudes

o An exemption is requested from the cited regulations due to the purpose that the UAS being used was created for. This UAS is designed for use in an environmentthat is contraryto this regulation. Also, the UAS would notbe operated at an altitude ofmore than 500 feet above the surface, as to notinterfere with anypotential air traffic. • 14 CFR § 91.121: Altimeter settingso An exemption is requested because no pitot static system is installed in the aircraft and due to the altitudes is operates at adherenceto this regulation would be unrealistic and unnecessary. Also, GPS position information is transmitted to the aircraft controller, providing much more accurate information than whatwould be shown by a traditional altimeter.

• 14 CFR § 91.151: Fuel requirements for flight in VFR conditions

o Due to the nature ofthe aircraftbeing used, adherence to the regulation would be unrealistic. The UAS has an average flight time of approximately 25 minutes and a "return to home" function in the event ofan impending power failure. Therefore, an exemption from the cited regulation is requested.

• 14 CFR § 91.405(a): Maintenance required, 91.407(a)(1): Operation after maintenance, preventative maintenance, rebuilding or alteration, 91.409 (a)(2): Inspections, 91.417(a) and (b): Maintenance records

o Exemptions are requested from the cited maintenance regulations because they only apply to traditional aircraftwith an airworthiness certificate. Qualifications and closing By granting me a section 333 exemption Iwill be able to bring a service to my community thatbefore, was associated with high cost and high environmental impact. As a professional pilot, the skills and knowledge that I have gained through training and experience will add an additional level ofsafety to the operation ofthe UAS. Coupled with an in-depth knowledge ofairspace, Federal Aviation Regulations (FARs), safety offlight and science offlight information Ibelieve there should beno question as to the soundness ofmy petition for exemption. *Note All information regardingthe DJI Phantom 3 quad copter can be found on the manufacturers webpage below. Model specifications will be submitted with this documentfor ease ofreference. http://www.dji.com/product/Phantom

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Sincerely,