IN THE MATTER OF:

PETITION FILED BY UNITED STATES OFAMERICA DEPARTMENT OF TRANSPORTATION FEDERALAVIATION ADMINISTRATION WASHINGTON, DC

* REGULATORY DOCKET * NO. * ARTHUR RAY GRISSETT, JR. d/b/a * LORAY DRONES * FOR EXEMPTION FILED UNDER 

### * SECTION 333 OFTHE FAA * MODERNIZATION * AND REFORM ACT OF 2012 *

SUBMITTED ON OCTOBER 7, 2015

ARTHUR RAY GRISSETT, JR. D/B/A LORAY DRONES

1572 HINES RD MORELAND, GA 30259 (678) 949-7872 raygrissett@gmail.comPursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, Arthur Ray Grissett, Jr. d/b/a Loray Drones, operatorofan Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. I, Arthur Ray Grissett, Jr. d/b/a Loray Drones, requestexemption from the following sections ofTitle 14, Code of Federal Regulations: 61.113(a)(b), 91.119(b)(c), 91.121, 91.151(a)(b), 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) 

### & (b).

Operations will be performed only at the request ofand with the authorization and permission ofclients ortheir authorized agents in orderto facilitate commerce and raise

awareness ofthe beneficial uses ofsmall unmanned airsystems. So long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.

I, Arthur Ray Grissett, Jr., have over20 years ofexperience in the aviation industry and hold a commercial pilot's license.

Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

Aerial inspection/photography of residential/commercial structures under contractwith the owners or local governing authority.

Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

Aerial video/photography or providing live video feed to assistwith search and

rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities or government has requested it by contract or donation.

The ability to offertraining to persons individually or belonging to both private and/or public organizations that have interests in the use and application of an UAS forthe purpose ofthe safe operation ofan UAS to enhancethe safety of the National Airspace (NAS) as well asforthe protection ofthe persons and property.

Petitionerseeks an exemption to operate OJI Phantom 3 and OJI Inspire 1 UAS systems for compensation or hire within the NAS. The OJI Inspire 1and the DJI Phantom 3 are vertical takeoffand landing with a ground control station utilizing electronictablet orsmart phone systems.The DJI Phantom 3 Professional and the OJI Inspire 1are highly successful consumer grade small rotorcrafts in the quadcopter configuration with an advertised weight of less than eight pounds designed primarily to carry a high definition camera. They have an advertised maximum speed of less than 30 knots and maximum climb rate of less than 1200fee per minute. It is powered byfour electric motors with a distance between motors of less than 14 inches. It is controlled primarilythrough an FCC certified radio control unit. Real timevideo and telemetry information is transmitted backto a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude and distancefrom PIC, camera imagery and control camera angle. They have fail safe modes ofoperation foreither 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 25 minutes. The onboard flight controllerwill warn the pilotvia telemetry and external lighting cues before reaching a low battery state. An automatictermination offlight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 10 minutes.

The DJI UASAircrafts will not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed and operational capacity.

Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). The PIC and VO will have been trained in operation of UAS and receive up-to-date information forthe particular UAS to be operated. The PIC and VO will be able to communicate by voice or radio atall times. Ifthe UAS loses communication with the remote controller or loses GPS signal, the UASwill have the capabilityto return to a pre-determined location within a designated location and land autonomously. The UAS will have the capability to abort a flight in case ofunpredicted obstacles, weatheror emergencies. A preflight checklistwill be developed and employed to ensure thatthe UAS airworthiness 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. The risk of interference with another aircraft is minimal. UAS operations will be conducted at leastfive miles from any public airport.

Given the small size ofthe UAS and the controlled environment in which theywill be operating, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. The UAS will weigh less than 55 lbs. and will have a maximum operating speed of no more than 50 mph. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). Maximum flighttime for each operational flightwill be 25 minutes. Flights will beterminated at25% battery power reserve or25 minutes offlight time, whichever occurs first. Flights will be operated atan altitude of no morethan 400 feet above ground level (AGL).

Use ofthe UAS in lieu ofa manned aircraftwould enhance safety and reduce the environmental impact as compared to similaroperations conducted with manned aircraft ofgreater proportions, carrying a crew and flammablefuel. Additionally, use ofthe UAS in orderto facilitate commerce could lead to economic growth. Operationsforthis petition will enable service for property owners ortheir designees seeking an enhanced perspectivefor characteristics, amenities, and benefits oftheir desired photographic subjectsthat cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and use ofpesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. Liability insurance will be obtained commensurate with the granting ofthis requestforexemption. The granting of this petition will furtherthe public interest by allowing me, Arthur Ray Grissett, Jr., to safely, efficiently and economically perform aerial photography and videography ofreal estate, construction sites, and landscape over certain areas ofthe United States. Additionally, use ofthe OJI UAS Aircrafts will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits tothe economy. Notably, the benefits of petitioner's proposed operation ofthe OJI UAS aircrafts will be realized without implicating any privacy issues.

In conclusion, said petitioner is requesting this exemption forthe purposes ofaerial photography, cinematography and videography. The primary purpose ofseeking this exemption is to obtain the capabilityto offerthose services while remaining in compliance with FAA regulations.

Respectfully submitted this

## ihdayofOctober, 2015.