Geoffrey P. Armstrong

6617 Peppermill Dr Las Vegas, NV 891 46 (702) 56 9-8975 silverado595@gmail.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services.

I am a Commercial, In strument Rated FAA Helico p ter and Airplane Pilot, Certificate # 2932656

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Geoffrey P. Armstrong , a n FAA rated Helicopter and Airplane Commercial Instrument Pilot and freelance multimedia producer , hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below
to allow op eration of ou r Small Unmanned Aircraft Sy stem (sUAS) commercially in airspace regulated by the
Federal Aviation Administratio n (FAA) so long as such operations are condu cted with an d under th e con ditio ns outlined herein or as may be established by the FAA as required by Sectio n 333

.

The requested exemption would permit Geoffrey P. Armstrong to pursue his commercial interests in providing
services to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land Managemen t/ Surveying, and Special Events

. Geoffrey P. Armstrong states th at all sUAS flights will occur over private or
controlled access property and w ill d o so with the property owner's con sent and kno wledge an d that only peop le
who have consented or otherwise hav e ag re ed to be w ithin the UAS’ radius during filmin g and p hotography applications.

Geoffrey P. A rmstrong has demonstrated the ability to safely and effectively fly the sUAS D JI Insp ire 1 which will
be used for all commercial and private purposes. Geoffrey P

. Armstrong c om plies with local ordinan ces and laws regardin g t h e operation of sUAS , and adheres to all weather an d environmental restrictions or limitations in
reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regar ding privacy

.

I, Geoffrey P. Armstrong , am seeking the exemption because I am committed to complying with all of the rules,

g uidelines , limitation s, an d future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I have described, and for the purposes that I h ave described. Withou t the exemption request granted, I w ould be

u nable to safely and effectively run my business, and it is my in tention to comply with the FA A an d obtain an exemption of the fo llowing reg ulations.

The follow ing contains my list of regulations from which I am seeking exemp tion, and a comp lete list of

resp onsibilities I assume as operato r; it also contains in fo rm ation regarding the aircraft, public b enefit and safety features, a n d similar p etitions requests granted.

**Regulations from which exemption is**  **requested:**

14 C.F.R. Part 21

1 4 C. F.R. 45.23(b)

14 C.F.R. 61 .1 1 3 (a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.11914 C.F.R. 91.121

14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b)
14 C.F.R. 91.215
14 C.F.R. 91.401

- 91.417

**I, THE OPERATOR ,**  **ASSUME THE FOLLOWING RESPONSIBILITIES**
1. Operations authorized by this grant of exemption are limited to the DJI Insp ire 1 w eighing less than 55 pounds including payload

. Propo sed operation s of any other aircraft will require a new petition or a petition to am en d this exemptio n. 2. Opera tions for the purpose of clo sed -se t motion p icture and television filming are not permitted

. 3. The UA may no t be operated at a speed exceeding 8 7 kno ts (100 miles per h our). The exemption holder may use either groundspeed or calibrated airspeed to determ ine compliance with the 87 knot speed restriction. In no case will
th e UA b e operated at airspeed s greater than the maximum UA o perating airspeed recommended by the aircraft
manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above g round level (AGL). Altitude must be reported in feet A GL.

5. The UA must be operated with in visual lin e of sight (VLOS) of the PIC at all times. This requires the PIC to be
able to use human visio n un aided by any device other than corrective lenses , as specified on the PIC’s FAA -is sued
airm an medical certificate o r U.S. driver’s license.

6

. All operatio ns must utilize a visual observer (VO). The UA must be operated w ithin the visual line of sig ht (VLOS) of th e PIC and VO at all times. The VO may be u sed to satisfy the VLOS requirement as long as the PIC
alw ays maintains VLOS capability. The VO and PIC must be able to co mmunicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designat ed before the flight an d cannot transfer his or her designation for the duration of th e flight. The PIC must ensu re that the VO can perform the duties required o f th e VO.

7. This exemption and all documents needed to operate the UAS and co nduct its operat ions in accordance w ith the
conditions and limitatio ns stated in this g rant of exemption, are hereinafter referred t o as the o perating docu ments. The operating documents must be accessible during UAS operation s and made available to the Ad min istrator up on request. If a discrepancy exists b etween the conditions and 4 limitatio ns in this exemption and the procedures

ou tlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must fol low the procedures as ou tlined in its op eratin g documents. The operator may up date
or revise its operatin g documents. It is the operator’s responsibility to track such rev isions and present up dated and
revised documen ts to the Administrator or an y law enfo rcement official upon request. Th e 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 u

pdate or revision would affect the basis upon wh ich the FAA gran ted this exemption, then the operator must petition f

or an amendment to its grant of exemption

. The FAA’s UAS In tegration Office (AFS −80) may be contacted if questions arise regarding updates or revisions to the operating documen ts.
8. Any UAS tha t has u nd ergone maintenance o r alterations that affect the UAS operatio n 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. Functio nal 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. 9. The operator is resp onsible 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 inspectio n 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 ha s 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. 5 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

em ergency 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 e xemption are permitted under the terms of this exemption. However, 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. 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 operat e 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 w ith an ARP, the center of the airport symbol as
denoted on the current FAA

- published aeronautical char t, 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 enforcemen t 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 w hen 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 (considerin g wind and forecast weather conditions) there is enough available pow er for the UA to conduct the intended operation and to operate after that for at least five
minutes or w ith 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 un der the terms of the attached COA. 6 22. All aircraft operated in accordance w ith this exemption must be identified by serial number, registered in
accordance w ith 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 St ation of the UAS any timethe aircraft is operating. These documents must be made available to the Administrator or any law enforcement

official upon request. 24. The UA must remain clear and give wa y to all manned aviation operations and activities at al l 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 ar e 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 le ave such protection and are w ithin 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 opera ting 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 nonpartic ipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property

ow ner/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 U AS 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.

**SIMILAR EXEMPTIONS**

They are similar in all/o r many material re spects to relief previously requested in Grant o f Exemption Nos. 11062, 11109, 11112, and 11213

**Public Benefit and Safety**

Unmanned Aircraft System sUAVs are often seen as sup erior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipmen t and personn el cost, reduced noise and as su ch, a much smaller environmental imp act which promotes pu blic safety. Geoffrey Armstrong is petitioning for an exemption to o perate a DJI In spire 1 with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above g round lev el (AGL), to limit the
radius of the distance it flies fro m the operator and to exclude it from o perations within designated Class B, C and

D airspace including a n o -fl y zone feature.
The DJI S900 also has a failsafe function th at is trigg ered in the event communication is lost between th e sUAS and the main controller transmitter. At that time, the sUAS will retu rn to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually

.

These specifications meet with the Model Aircraft Op eratin g Standards as set below:

 The petitioner w ill only operate its sUAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas w ith in the sterile area described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace system or the public." When flying the sUAS within three (3) miles of an airport, airport operators w ill be notified and th e operator w ill

g ive th e righ t -of-wa

y to avo id flying in th e proximity o f fu ll -sc ale aircraft. Maximum fligh t time for each operation
will be 30 minutes.

 Flights will be terminated when battery levels reach 25%, allo w ing su fficient reserv e flight time to safely lan d the

sUAS.

 The sUAS will be programmed so it will not be op erated at an altitude that exceeds 400 feet AGL, and not more
than 200 feet above an elevated platform from which videography is planned.

 Minimum crew for each ope ration shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

 The sUAS PIC w ill be an FAA licensed airman holding a minimu m of a Private Pilot certificate

.

 The sUAS operated by the petitio ner weighs less than 25 poun ds, including all p ayload (i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, an d can simultan eously move vertically and
h orizontally.

 Geoffrey P. Armstrong being a licensed FAA Helicopter and Airplane Commercial In strument rated Pilot will follow and adhere to th e Reform Act's safety requirements.

If you have any question or need additional information, please contact me at silverado595@gmail.com or (702) 569-8975

Thank you Geoffrey Armstrong