**1 |**  Page Colley Petition

Jeffrey Ring Papa Power Productions 40 Middlebrook Lane Rochester, New York 14608 -4406 (Office) 585 -442 - 2742 (Cell) 585 - 747 - 5508 June 16 , 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Jeffrey Ring, a Film and Video Media Production specialist for the past 30 years, preparing this exemption request myself, would like to apply for an exem ption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems ( S UAS) for the purposes of aerial imaging, data collection, Photography and Videography. Jeffrey Ring seeks exemption from the requirements of 14 C.F.R 21(h), 43.7, 43.11, 45.11 (a,b,c), 45.27(a), 45.29(3), 61.56, 61.113(a,b), 61.113, 91.7(a), 91.9(b2, c), 91.103(b2), 91.105, 91.113(b), 91.119(c), 91.121, 91.151, 91.403, 91.405(a,d), 91.407(a,b), 91.409, 9 1.417, to opera te commercially s mall Unmanned Aircraft System (S UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). Approval of th e exemptions requested will allow for commercial operations of th e DJI S900 and Phantom to be conducted , LO S only, for the purpo ses of collecting aerial video, mapping, photography, and sensory data to be used in support of agricu lture applications, inspection operations, forestry, land management, new sensor development and the expansion of basic and fundament al research principles and applications related to the above, in addition to search and rescue . All flights will be under 400 feet in altitude, never within 5 miles of any Commercial or private Airp ort, always with a spotter/assistant and within Class G a irspace within the United States. Following examples o f; FAA Exemption No. 11 38 1 - Regulatory Docket No. FAA- 2014 - 0481 , FAA Exemption No. 11784 - Regulatory Docket No. FAA - 2015 - 0288, FAA Exemption No. 11788 - Regulatory Docket No. FAA – 2015 - 1003 and FAA Exemption No. 11769 – Regulatory Docket No. FAA – 2015 -0896 I have included: 1) Supplemental Response for Petition 2) The DJI S900 and Phantom manual s are too large for upload to regulations.gov. Therefore, if interested, plea se follow the link bel ow to the assembly and operating manual for the sUAS. http://www.dji.com/product/spreading -wings - s900/download 3 ) Personal protocols and controls - Safety/Flight concerns**2 |**  Page Colley Petition

I have vast experience in flying Remote Control Airplanes (fixed -wing) for over 40 years and Multi copters for the past 5 years for recreation, testing, reviewing and photographic purposes, without incident. I currently have dozens of planes and numerous Multi - copters including the DJI S900 and Phantom which I am requesting this exem ption for. Approval of m y exemption request would permit operat ion of these two particular Multi - copters in predetermined areas away from general public, airports, heliports and vehicular traffic, under 4 00 ft. and after carefully reviewing, inspecting a nd examining the area of aerial observation. I will abide all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspections and protocols, during which safety carries primary importance. As a member of the AMA #869451 and the RCCR for many years, my primary concern has, and always will be, Safety! Our club has always had a passion for proper training for the younger generation of RC flyers and works closely with local Colleges and Universities to promote interest in the Aeronautical arena. **14 C.F.R. Par t 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203**  Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I am asking exemption from 14CFRpart21, Subpart H (Airworthiness Certificates) and§91.203 ( a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of P.L. 112 - 95 (Section 333). It is evident, by many of your previous approvals, that you are totally aware of the attributes of these specific two Multi - copters. **14 C.F.R. 45.27(a): Location of marks; non fixed -** **wing aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks**  Furthermore I re quest an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two - inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word “Experimental” or assigned number or name (based on a request or ruling by the FAA ) on its fusel age as required by §45.29 (f) so that anyone assisting as a spotter will see the markings. I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. But, as a safety precaution , I always have and will continue to perform a preflight inspection of my UAS before each flight as outlined in operating documents. **14 CFR 61.113 (a) & (b): Private p ilot privileges and limitations: Pilot in command.**  Under §61.113 (a) and(b) private pilots are limited to non - commercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part61,et seq., I requests an exe mption from §61.113 Private Pilot Privileges and Limitations. In**3 |**  Page Colley Petition

my decades of RC flight, I have conducted seminars on flight training, maintenance and assembly in addition to being a reviewer/contributor to RC Groups on line Magazine and Fly RC Magazine . I have a lso flown almost every class of RC Airplane including control line, glow & gas, gliders, 3D, Sport, 1⁄4 & 1/3 Scale, EDF Jets and every size Multi - copter micro/mini, Quads, Hexas and Octos. Multi - copters and the many positive uses that they have th e capacity to perform has become my passion and I will continue to properly promote and inform the general public, whenever I have the opportunity to do so , that this technology has many advantages for advancing data collection and discovery in the world of flight. **14 C.F.R. 91.103 (b) (1), (b)(2): Preflight Action**  If granted an exemption I agree to additional safety procedures including, but not limited to: 1. Keeping my U AS within a radius distance of 1000 feet from the controller to both aid in direct l ine of sight visual observation. 2. Operate the UAS for 8 - 15 minutes per flight; land my UAS according to the manufacturer’s recommended minimum level of battery power. 3 . Ope rate my UAS only within visual line of sight (VLOS). 4. Use the UAS’ global positioning system (GPS) flig ht safety feature ; Return to Home. 5. Conduct all operations under stringent flight safety protocols . 6. I will operate and will actively analyze flight data and other sources of information to constantly 7. Always obtain all necessary permissions prior to operation 8. Always have procedures in place to abort fl ights in the event of safety breaches or danger. I wish to thank you for giving me this opportunity to apply for a 333 Exemption and I hope that my application will meet with your ap proval. I look forward to continue my exploration of RC flight with the proper FAA credentials for SUAS operation. With your approval, I will have the ability to be commercially able to provide a positive service in many exciting industries including ; agriculture, forestry, a erial photography and video for real estate, archit ecture, land surveying, commercial utility infrastructure engineering, public events, news gathering, aerial inspection of residential and commercia l structures , c losed set filming of motion pictures, music videos, web videos, corporate videos, televisi on programs and commercials, training for proper UAS operation, photos and videos to assist with search and rescue operations; and any other related profess ional activities. How exciting! Sincerely yours, Jeffrey Ring Papa Power Productions