**Date: November**  **12 ,**  **2015**

**George Bryce Watson III 181 Newbury Rd.**  **Howell, NJ 07731 Jumbojetguy@gmail.com**  **(954) 646 -** **7950 Native US Citizen**  **US Commercial Airline Pilot**

**U. S.**  **Department of** **Transportation Docket**  **Management System**  **1200 New** **Jersey Ave.,**  **SE Washington,**  **DC 20590** 

**RE: George**  **Bryce Watson**  **III for**  **Exemption Pursuant**  **to Section**  **333 of**  **the FAA**  **Reform Act.**  **Continued... .** **To Whom**  **It May**  **Concern:**

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, George Bryce Watson III, owner and operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial data collection, aerial inspections, aerial surveys and photography & videography and monitoring, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUAS, so long as such operations are conducted under the conditions outlined by the FAAas required by Section 333.1 The proposed exemption, if granted, would allow George Bryce Watson III to conduct commercial operations of small unmanned aircraft systems (“sUAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems” provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. We have closely reviewed the FAA’s existing exemption grants under section 333, and submit this request as being materially similar to Exemptions 11430, 11365, 11409, 11209, 11111, and 12646 among others. We are fully prepared andwillingto operate under (and abide by) the exemptions alreadygranted and the conditions required in Exemptions 11430 and 11365. The detailed request below is provided to further demonstrate ourunderstanding ofthe rationale for the FAR exemption requests and associated decisions by the FAA, as well as provide abasis forestablishingourneed forthe same. We hope the FAA determines that good cause exists for not requiring publishing petition summary in the Federal Register as this request does not set aprecedent and parallels existinggrant authorizations.
Sincerely, George Bryce Watson IIIThe Petitioner Requests ReliefFrom the followingregulations:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.405 14 C.F.R. 91.407 14 C.F.R. 91.409 14 C.F.R. 91.417 George Bryce Watson III is petitioning for exemption to enable George Bryce Watson III to operate; [BirdsEyeView Aeronautics FireFly6 (approved grant #12646)], [DJi Inspire 1 (approved grant #13055)] each weighing less than 10 Lbs. and utilizing flight controllers known and familiar to the FAA

– and having the required safety features; GPS, loss of signal RTL, GEO fence, low battery RTL, real

-time telemetry, OSD, etc. See below. The sUASs will be equipped with cameras or imagers, stabilizing gimbals and OSD (on screen displays) providing the PIC with GPS strength, altitude, airspeed, batterylife and direction. Our UAS flight controllers utilize GEO fence to limit the altitude above the ground and limit the radius of the distance it flies from the PIC. Our UASs have GPS guided failsafe functions allowing the autopilot system to flyback to the launch site autonomously. Ifthe transmitter is disconnected the system will automatically trigger return to home and will land safely. George Bryce Watson III is acommercial airline pilot foramajorUS Carrier. George Bryce Watson III is eminentlyqualified forall aspects ofUAS operations in the NAS. George Bryce Watson III has longworkedunder FAAguidelines and applied industrybest practices and received training

. George Bryce Watson III is anative US Citizen. Ourcommercial activities would include:

• Aerial datacollection, survey / mapping

• Aerial Infrared surveys of physical plant, assets, infrastructure, solar panels, structures, construction

• Aerial photo & video surveys of physical plant, assets, infrastructure, solarpanels, structures

• Real Estate & marketingpromotion (non

-closed set)

• Aerialvideographyand photography

• Agricultural surveys• Research and environmental monitoring

• Aerial Data Collection FCC INFORMATION Ourtransmitters used forcontrollingthe sUAS complywith part 15 ofthe FCC rules. Operation is subject to the followingtwo conditions: (1) This device maynot cause harmful interference, (2) This device must accept any interference received, including interference that maycause undesired operation. Our radio transmitters used for controlling the sUAS’ are wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.4GHz or 5.8GHz frequency range. STANDARD OPERATING PROCEDURES (unless revised per FAA grant of exemption) 1. Operations authorized by this grant ofexemption are limited to the specific UAS approved in the grant, when weighing less than 55 pounds including payload. Proposed operations ofany other aircraftwill require a new petition or apetition to amend this exemption. 2. Operations for the purpose of closed

-set motion picture and television filmingare not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holdermayuse eithergroundspeed orcalibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended bythe aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude mustbe reported in feetAGL. 5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate orU.S. driver’s license.6. All operations must utilize a visual observer (VO). The UA must be operated

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that theVO can perform the duties required oftheVO. 7. All documents needed to operate the UAS and conduct its operations in accordancewith the conditions and limitations stated in the grant of exemption “operating documents.” The operating documents must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and mustbe followed. Otherwise, the operatormust f ollowthe procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The 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 update or revision would affect the basis upon which the FAA granted this exemption, then 4the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted ifquestions arise regarding updates or revisions to the operatingdocuments. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 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. Functional 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 anundue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in acondition 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 inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safeoperation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11. The operatormust followthe UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements forthe aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safetybulletins. 13. Underthis grant ofexemption, aPIC must hold eitheran 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 reviewrequirements specified in 14 CFR § 61.56 in an aircraft inwhich the PIC is rated on his orherpilot certificate.
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 emergency 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 determiningthe PIC’s abilityto safelyoperate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms ofthis 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 UAS 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 specialvisual flight rules (SVFR) are not authorized. 16. The UA may not operate 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 with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, 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 theairport management must be made available to the Administrator or any law

enforcement officialupon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhenvisibilityis 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 (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes orwith the reserve powerrecommended bythe manufacturerifgreater. 21. Air Traffic Organization (ATO) Certificate ofWaiver or Authorization (COA). All operations shall be conducted in accordancewith anATO

-issued COA. The exemption holdermayapplyforaneworamended COAifit intends to conduct operations that cannotbe conductedunderthe terms ofthe attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings mustbe 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 Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administratororanylawenforcement officialupon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS maynotbe operated bythe PIC from anymovingdevice orvehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipatingpersons, vessels, vehicles, and structures unless:a. Barriers or structures are 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. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a mannerensuringthe safetyofnonparticipatingpersons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closer to those ob jects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representativewill be obtained foreach 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 UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the NationalTransportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. Ifthis exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply. 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant ofexemption.

30. At least 3 days before aerial filming, the operatorofthe UAS affected bythis exemption must submit awritten Plan ofActivities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence ofthe FSDO. The plan ofactivities must include atleast the following:

a. Dates and times forall flights; b. Name and phone number of the operator for the UAS aerial filming conducted underthis grant ofexemption; c. Name and phone number of the person responsible for the on-scene operation ofthe UAS; d. Make, model, and serial orN−NumberofUAS to be used; e. Name and certificate numberofUAS PICs involved in the aerial filming; f. A statement that the operatorhas obtained permission from propertyownersand/orlocal officials to conduct the filmingproduction event; the list ofthose

who gave permission mustbe made available to the inspectorupon request; g. Signature ofexemption holderorrepresentative; and h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

**HOW THIS**  **REQUIST IS** **TO THE**  **BETTERMENT OF**  **OUR COMMUNITY**  George Bryce Watson III UAS’s are powered by batteries, smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels associated with traditional aircraft, enhance safety and diminish the likelihood of death or serious bodily injury. Also with a small payload and typical flight time ofonly 10

-25 minutes, there is little or no risk to national security. Low level photos and video are far more effective than ground or high altitude manned aircraft imagery for displaying detailed characteristics ofground based objects or elevations required for plant, asset and structural inspection with standard or infrared cameras. The applicant is aware of costs associated with full

-sized helicopters or planes for parallel purpose, which is proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UAS will be incrediblyvaluable to clients. **EXEMPTION REQUESTS**  **AND EQUIVALENT**  **LEVEL OF**  **SAFETY** George Bryce Watson III requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAS System.
14 CFR Part 21, Airworthiness Certificates: This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for our UAS’s under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes:(a) Research and development. Testing new aircraft design concepts, new

aircraft equipment, new aircraft installations, new aircraft operating techniques, ornewuses foraircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate ma jor design changes, and flights to show compliancewith the function and reliabilityrequirements ofthe regulations.

Since the experimental certificate can be used forcommercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UAS lightweight, being constructed primarily of carbon fiber and plastic in conjunction with the ability to utilize emergency parachute systems. We propose that the UAS will be at least as safe, ifnot safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.
14 CFR45.23 Displayofmarks; general and 45.29 Size ofmarks: These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We will display at the ground station a flag or banner that containing the words "Unmanned Aircraft Ground Station." Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.
14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate: As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 91.119 Minimum safe altitudes: The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be inspect or survey persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet tothe items listed. The hazard to persons or property on the surface will be very

limited. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. The exemption is notunlike 11062, 11136, and 11111 amongothers. CFR 91.121 Altimeter settings: The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflictwith other aircraft. AnAbove Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. The Pix4D flight controller can be configured to geo-fence the UAS underthe 400’maximum altitude.
14 CFR 91.151 Fuel requirements forflight inVFRconditions: The regulation provides that no person may begin a flight in an airplane under day

-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. The purpose of this is to provide an energy reserve as a safety buffer for delays to landing. Since the aircraft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. 30% minimum reserve for immediate landing.
14 CFR Subpart E (91.401

- 91.417)

-Maintenance, Preventive Maintenance, Alterations: The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraftbe "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections aftereveryfive hours offlight. All maintenancewill be performed by the PIC in accordance with the manufactures manual. Ifrequired maintenance is beyond the ability of the PIC the maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level ofsafety.
14 CFR 91.405(a), 407(a), 409(a) (1) & (2), 417(a) & (b) Section 91.405(a) prescribes that: “(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections,except as provided in paragraph (c) ofthis section, have discrepancies repaired

as prescribed in part 43 ofthis chapter,” Section 91.407(a) prescribes that: “(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service by a person authorized under 43.7 ofthis chapter; and (2) The maintenance record entry required by 43.9 or43.11, as applicable, ofthis chapterhas been made.” Section 91.409(a) prescribes that: “(a) Except as provided in paragraph (c) of this section, no person may operate and aircraft unless, within the proceeding 12 calendar months, it has had

– (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordancewith part 21 ofthis chapter.” Section 91.417(a) and (b) prescribe, in summary, that each registered owner and operator of an aircraft shall keep records of maintenance, alterations, service life, and inspections. Since, if an exemption is granted, the SUAS in question will not carry an airworthiness certificate, and will not have established standards withwhich to determine it airworthiness, we request exemption from the above listed regulations. Instead, the SUAS will be operated and maintained by the PIC per the manufacturers operating and maintenance manuals for inspecting, maintaining, and repairing the sUAS. Further, all flight operations will be recorded bywayofan entryin the LogBook. The exemption request is not unlike exemptions granted in 11136 and 11062, amongothers. **Continued... CONCLUSION** 

By granting George Bryce Watson III the requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations of UAS. George Bryce Watson III is committed to promoting the UAS research efforts of policymakers by sharing data from its commercial UAS operations and serving as aresource forfuture UAS research operations. As pointed out in this application, all the sUASs which our company would use, under authorization by the US DOT

-FAA, are small, light

-weight devices operated within the line of sight ofthe Pilot

-in

-Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport or location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flightwithin aradius ofthis distance. George Bryce Watson III seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit saf

e operation of our UAS commercially, without an airworthiness Certificate. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing George Bryce Watson III to safely, efficiently, and economically operate sUASs commercially within the NAS. Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, George Bryce Watson III respectfully requests that the Administrator grant this Petition foran exemption from the requirements of 14 C.F.R Sections.
Respectfully, George Bryce Watson III,

Attachments: operatingmanuals & safetychecklists forthe requested UAV’s.