UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Patrick V Cullen W278 N2337 Prospect Ave Pewaukee, WI 53072 262

- 893

- 3463 Pcullen1275@gmail.com

Dear Sir or Madam: This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act o f 2012 (the Reform Act), and 14 C.F.R. Part11, Patrick Cullen, a freelance multimedia produc er, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federa l Aviation Administration (FAA) so long as such op erations are conducted with and under the conditio ns outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Patrick Cullen to pursue his commercial interests in providing services to clients usi ng a small advanced sUAV in the following areas: Real Estate, Marketing, Land Management/Surveying, and Special Events. Patrick Cullen st ates that all sUAS flights will occur over private or controlled access property at a Altitude no more than 200 feet an d will do so with t he property owner's consent and knowledge and that only people who have consented or otherwise ha ve agreed to be within the UAS’ radius during filmin g and photography applications. Patrick Cullen is a member of the AMA, and has demonstra ted the ab ility to safely and effectively fly the sUAS BLADE CHROMA 1080P which will be used for all commercial and private purposes. Patrick Cullen complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and
env ironmental restrictions or limitations in reference to the operations of sUAS. All flights will occur in ordinance with any state o r local laws regarding privacy. I, Patrick Cullen, am seeking the exemption because I am com mitted to complying with all of t he rules, guidelines, limitations, and 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 have d escribed. Without the exemption request granted, I would be unable to safely and effectively run my busi ness, and it is my intention to comply with the FAA and obtain an exemption of the following regulations.The following contains my list of regulations from which I am seeking exemption, and a complete list of

responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and safety features, and similar petitions requests granted. Regulations from which exemption is requested:
14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(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. 91.119 the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 1. The UA must remain clear and give way to al l manned aviation operations and activities at all times. 2. The UAS may not be operated by the PIC from any moving device or vehicle. 3. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and st ructures 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. If a situa tion arises where nonparticipating persons leave such protection and are within 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 operating 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 nonparticipating persons under this exemption. 4. 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 representative will be obtained for each flight to be conducted. 5. 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 Naonal Transportaon Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
SIMILAR EXEMPTIONS Th ey are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 Public Benefit and SafetyUnmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video g athering

platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety. Patrick Cullen is petitioning for an exemption to operate a BLADE CHROMA 1080P w ith a built

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Cl ass B, C and D airspace including a no

-fly zone feature. BLADE CHROMA 1080P also has a failsafe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its po int 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 Operating Standards as set below: The petitioner will 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 within the sterile area described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to users of the national airs pace system or the public." 6. 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. If the inspection reveals a condition that affects the safe operation 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. 7. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 8. Each UAS operated under this exemption must comply with all manufacturer safety bull etins. 9. 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 10. 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 maintainin g 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 exemption 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 § 91.119.11. UAS operations may not be conducted during night, as defined in 14 CF R § 1.1. All operations must

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rul es (SVFR) are not authorized. 12. The UA may not operate within 5 nautical miles of an airport referenc e 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 the airport management must be ma de available to the Admin istrator or any law enforcement official upon request. 13. The UA may not be operated less than 500 feet below or less than 2,000 fe et horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 14. If t he UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property. 15. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 16. 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 opera te after that for at least five minutes or with the reserve power recommende d by the manufacturer if greater. 17. 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 under the terms of the attached COA. 6 18. 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 must be as large as practicable. 19. 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 b e available to the PIC at the Ground Control Station of the UAS any time give the right

-of

-way to avoid flying in the proximity of full

- scale aircraft. Maximum flight time for each operation will be 30 minutes. 1. Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS. 2. The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from which videogra phy is planned. 3. Minimum crew for each operati on shall consist of: sUAS pilot and the camera operator. 4. The sUAS operated by the petitioner weighs less than 25 pounds, incl uding all payload (i.e. camera, lens, and stabilized gimbal).5. The sUAS will o perate at speeds of no more than 50 knots, can hover, and can simultaneously move

vertically and horizontally. 6. Given the small size of the sUAS and the restricted sterile environmen t within which it will operate, SkyVideoCT’s operations adhere to the Re form Act's safety requirements.

14 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 7. Operations authorized by this grant of exemption are limited to the BLADE CHROMA 1080 P when weighing less than 55 pounds including payload. Proposed operations of any ot her aircraft will require a
new petition or a petition to amend this exemption.
8. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 9. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 8 7 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airsp eed recommended by the aircraft manufacturer. 10. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 11. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective le nses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. 12. 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 ma y 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 ve rbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be d esi gnated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 13. This exemption and all documents needed to operate the UAS and condu ct its op erations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator u pon request. If a discrepancy exists between theconditions and 4 limitations in this exemption and the procedures outlined in the operating documents,

the conditions and limitat ions herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s respons ibility 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 the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS −80) may be contacted if quesons arise regard ing updates or revisions to the operating documents. 14. 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. Fun ctional test flights may on ly be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test fli ght must be conducted in such a manner so as to not pose an undue hazard to persons and property. 15. The operator is responsible for maintaining and inspecting the UAS to ensure tha t it is in a condition for safe operation.

The applicant, Patrick Cullen requests your respective approval of this Section 333 exemption petition request. Thank you for your attention in thi s matter. Please notify Patrick Cullen Of your actions, and or approvals. Thank you, for your interest in this request

Patrick Cullen