U. S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

Dear Sir/Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Jo seph W. Dinwiddie , would like to apply for an exemp tion from the following Code of Federal Regulations (C.F.R) to allow commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging, video, and surveillance. This video and image data will be used for survey analysis, safety and/or damage inspection, aerial photography, as well as search and rescue. These are services that will be offered and safely executed to various clients or industries with these types of needs. The operations of the service(s) will only be carried out with the proper approval from property owners and any other agencies requiring approval. Safety will be top priority before, during, and after operations of the services. Described herein, along with request for exemption, are details on how my operations will be equal to, or safer than use of traditional rotorcraft

Personal Information/Contact information
Jo seph W. Dinwiddie 29020 Old Cherry LnLebanon, Missouri 65536

Phone # 417
- 741
- 2267

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jo seph W. Dinwiddie will provide its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Joseph W. Dinwiddie has over 8 years recreational/hobby experience in all aspects of aerial video and photography with remote controlled helicopters and planes . The objective of Jo seph W. Dinwiddie ’s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting: • Aerial ac quisitions used for inspections of public and private structures as well for real estate. • Increase public knowledge of UAS and promote safe UAS operations. • Search and Rescue operations
.

**BACKGROUND** Unmanned Aircraft Systems: DJ I Phantom 3: Joseph W. Dinwiddie seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 is equipped with four main ro tors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3 UAs that will be operated by Joseph W.Dinwiddie will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14

C.F.R Part 47, Aircraft Regis tration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

**BASIS FOR PETITION** Petitioner, Joseph W. Dinwiddie, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3 in the National Airspace System (NAS), and for an exemption from the 6 Requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91. lSl(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Jo seph W. Dinwiddie operation of DJIPhantom 3 meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Joseph W. Dinwiddie reques ts relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Jo seph W. Dinwiddie submits that the reque sted relief is proper since an equivalent level of safety will be ensured. Joseph W. Dinwiddie will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents ( DJ I Phantom 3 ). Furthermore, Jo seph W. Dinwiddie will document and maintain all maintenance records for the DJI Phantom 3 . Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Joseph W. Dinwiddie to the extent necessary to allow that the PIC isable to safely operate the DJI Phantom 3 in a manner consistent with this 7 exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Jo seph W. Dinwiddie seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Joseph W. Dinwiddie submits that he will ensure that the DJI Phantom 3 UAS’s are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft are in a condition for safe flight. Joseph W. Dinwiddie also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJ I Phantom 3 will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Joseph W. Dinwiddie operation of the DJI Phantom 3 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Jo seph W. Dinwiddie seeks an exemption from the requirements of Section 91.15l(b), entitled Fuel requirements for flight in VFR conditions. Joseph W. Dinwiddie submits that safety will not be affected by operation of the DJ I Phantom 3 UAS’ during daylight hours in visual meteorological conditions (VMC) 8 under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

I request exemption for the purpose of Aerial Photography business. As a hobbyist flying for 8 plus years and always maintaining safe practices, line of sight flying, and proper maintenance and repair checklists.All photography I do is LOS, and performed less than 400' AGL. The aircraft I use have GPS guidance,

and "return to home" safety feature installed and standard on DJI Phantom 3. My primary business use would be real estate photography , home inspections, and general photography in nature, personal and private events. The use of my UAV is less costly than other means of aerial photography. My flights will consist of using the DJI Phantom quad copter. This is my request for exemption.

Very Respectfully
Jo seph W. Dinwiddie