1 CESAR R.
MARDIROSSIAN

1202 NW 114 TH Ave. Coral Springs, FL 33071

Cell 754

- 245

- 0284 Email: baron4266@yahoo. com

October 2 2 nd

, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE

Room W12

- 140 West Building Ground Floor Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1) DJI Phantom 3 Professional User Manual V1.0 2) DJI Phantom 3 Professional Release Notes 3) DJI Safety Guidelines Disclaimer

References:

1) FAA Exemption No. 11 603, Regulatory Docket No. FAA

- 2015

- 0521 in the manner of the petition of JOHN KELLER 2) FAA Exemption No. 1 1 138, Regulatory Docket No. FAA

- 2014

- 0481 in the

matter of the petition of DOUGLAS TRUDEAU 3) FAA Exemption No. 1 1 136, Regulatory Docket No. FAA

– 2014

– 0508 in the

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 4) FAA Exemption No. 1 1 080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter

of the petition of FLYING CAM INC

Dear FAA,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption

under section 333 of the FAA Modernization and Reform Act of 2012, I, CESAR R.

MARDIROSSIAN , request exemption from the following sections of Title 14, Code of Federal Regulations §§61. 1 3(a). 61. 3(b). 91. 1 9(c). 91.121. 91.151(a). 91.405(a).91.407(a)(1). 91.409(a)(1). 91.409(a)(2). 91.417(a) & (b). In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of

aerial photography, structural inspections of bridges, pipelines, well and cell towers,

real estat e marketing and surveys and other flight operations that could be2 performed safely and more cost effectively with the use of small UAS at low

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed o nly at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and

raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The 31 conditions identified and proposed by, CESAR R. MARDIROSSIAN , are drawn from reference 1.

The FARs
I, CESAR R. MARDIROSSIAN , request exemption from the above

- mentioned FARs for the following reasons.

I have been a licens ed Private Pilot since June of 1988, Certificate # 2400042 , hold

a Current Medical Certificate Third Class 61. 1 3(a) & (b). I, CESAR R.

MARDIROSSIAN , request relief in order to facilitate the utilization of pilots, who hold

a PRIVATE PILOT (or greater) cer tificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions. A Visual Observer will be used at all times while under this requested exemption . 91. 1 9(c) As discussed in Exemption 11 138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional r elief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. I, CESAR R. MARDIROSSIAN , request waiver for this condition to allow reasonable and responsible operations wi th safety as my main concern in areas of subdivisions and neighborhoods if required.

91.151(a) as discussed in Exemption 1 1 1 36 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minim ums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 88 1 , 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batt eries provide approximately 23 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing proced ure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) As discussed in Exemption 1 138 (DOUGLAS TRUDEAU), I, CESAR R. MARDIROSSIAN , propose to inspect and ensure that the UAS is in a condition for safe flight i n accordance with the operating documents. The3 FAA found that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection,

and record keeping, were sufficient to en sure that safety would not be adversely

affected.

The UAS The DJI Phantom 3 Professional is a highly successful consumer grade small

rotorcraft in the quad copter configuration with an advertised weight of 2.82 pounds (1280g) designed primarily to carry aloft a high definition 4k Resolution camera. It has an advertised maximum speed of less than 32 knots (16m/s) and a maximum climb rate of less than 985 feet per mi nute (5 m/s). It is powered by four

electric motors with a distance between motors of less than 14 inches. It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain it s geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor batter y level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control gimbal camera angle.

It has fail

- safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 23 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be

initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 16 minutes. More information is available in

attachment

Risk mitigation
I, CESAR R. MARDIROSSIAN , have reviewed FAA exemptions reference’s 31

Conditions and Limitations section as found in (FAA Exemption No. 11 603, Regulatory

Docket No. FAA

- 2015

- 0521in the manner of the petition of JOHN KELLER), and believe that the procedures specified therein are reasonab le and will be utilized in order to manage and mitigate risk and ensure public safety.

A preflight checklist included by attachment as (Safety Guidelines Disclaimer), will be utilized as well as other checklists and employed to ensure that the UAS’s

airwo rthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.

I, CESAR R. MARDIROSSIAN , request that in a manner similar to reference 4, be allowed to operate within 5 miles of an airport provided that

“ The UA may not operate in Cl ass B, C, or D airspace without written approval from

the FAA. The UA may not operate within 5 nautical miles of the geograph ic center of a non towered airport as denoted on a current FAA published aeronautical chart unless4 a letter of agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA . The letter of agreement with the airport management must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a mechanism to facilitate such act ivities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

Public interest Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. In regards to performing inspections of bridges, towers, and natural gas pipelines

the UAS will minimize the risk to persons attempting to climb these structures and photograph problem areas. It will provide a way for companies to have their engineers review photographs and provide additional safety to the general public in regards to towers failing or natural gas pipelines having structural issues. Many of the natural gas pipelines in our area travel in areas that are hard to reach by vehicle or foot and if an area is suspected of having problems the UAS

can reach it to make an assessment easier and safer.

I, CESAR R. MARDIROSSIAN , will also make the UAS and myself available to local volunteer organizations (for no charge) such as fire departments, local law enforcement, etc., to perform search and rescue operations, or other similar

events as directed by authorities.

In addition the use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designates seeking an enhanced perspective for characteris tics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance my personal photography.

A visu al observer will be utilized at all times that the UAS is performing duties for compensation and the PIC will hold a Private Pilots license.

Flight data including UAS flight time, Control Unit operation time, incident, and

details will be recorded for eac h flight and made available to the FAA at any time

as requested.

Any deviations from normal operations will also be recorded and made available

to the FAA.5 Conclusion I, CESAR R. MARDIROSSIAN am requesting this exemption for the purposes of aerial photography of real estate, bridge inspections, land surveying, pipeline inspections, tower inspections, Aerial filming, Aerial videography, and cinematography to enhance academic community awareness and photography for coverage of events, enhanced real estate listings, structural inspections and other flight operations.

The reason for such a general and broad based request is that I, CESAR R.

MARDIROSSIAN , wish to utilize a commercial business enterprise in order to capitalize on opportunities as they may arise in the future without the long turnaround time

associated with additional exemptions.

The need for Licensed FAA Pilots who have the experience, knowledge and experien ce of operating within The National Airspace System will help ensure the growth of this market segment will be successful and in the public interest.

I have been a licensed Private Pilot since June of 1988, Certificate # 2400042 , hold a

Current Medical Ce rtificate Third Class, and have Radio Controll ed Aircraft experience

as well o wning various battery operated planes and electric ducted fan jets , as well as being a member of the AMA (Academy of Model Aeronautics).

I look forward to helping pave the way for successful UAS Operations within the National Airspace System.

Sincerely,

CESAR R. MARDIROSSIAN

1202 NW 114 TH Ave. Coral Springs, FL 33071

Cell 754

- 245

- 0284

Email: baron4266@yahoo.com