1

JANUARY 19, 2016

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

Re: Petition of Michael Jeremiah Wraight for Exemption from Certain Federal Aviation Regulations to Operate Unmanned Aircraft Syst ems Pursuant to Section 333 of the FAA Modernization
and Reform Act.

Dear Sir or Madam:

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. part 11, Michael Jeremiah Wraight (Hereafter referred to as “the operator") hereby petitions the Federal Aviation Administration ("FAA") for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), a nd 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Raycom to operate unmanned aircraft systems ("UAS") for aerial data collection. Specifically, the operator seeks to operate UAS for Aerial data collection to include: Aerial photo graphy, videography, inspection and monitoring of agricultural sites, land restoration and remediation sites, environmental monitoring, inspection and monitoring of construction sites and utilities infrastructure, search and rescue, first responder service s, aerial photography and videography of real estate for marketing and land use and management, special events, UAS pilot training using the DJI Inspire 1, DJI Phantom 3 Pro, DJI Phantom
3 Advanced , DJI Phantom 2, 3DR Solo, Yuneec Q500+. Because this petit ion is similar in all material respects to previously

- granted Section 333 petitions, the operator requests expedited approval pursuant to the FAA's summary grant process.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS The operator holds and Airline Tran sport Pilot airmen certificate with multiengine land and commercial privileges as well as a Ground Instructor Instrument certificate and has 21 years’ experience as a professional aviator. The operator obtained an Associate’s Degree in General Aviation and a Bachelor’s Degree in Professional Pilot Technology from Indiana State University in Terre Haute, IN in 2001 . The operator has been involved in model aeronautics for 19 years, including building and flying remote control aircraft both powered and unpower ed. In 2004 the operator began working with nascent drone technology including GPS enabled autopilot as well as acting as a test pilot for a prototype drone. The operator was in charge of the technical writing and ab initio training program for this drone. Over the years the operator has gained thousands of hours operating both manned and unmanned aircraft and has extensive knowledge of the NAS, FARs, Navigation, Meteorology and Aviation Safety.

The operator proposes the following operations using UAS:

Aer ial data collection to include aerial photography, videography, inspection and environmental monitoring of: Agricultural sites, Land restoration and remediation sites, Land use and management, Inspection of and monitoring of construction sites and utiliti es infrastructure2

Search and rescue, First responder services, Real estate for marketing Special events, UAS pilot training.

Currently these functions are primarily performed by full size aircraft. These aircraft weigh thousands of pounds, are piloted by humans in dangerous conditions and environments (i.e., in close proximity to the ground and structures) , contain hundreds of gallons of highly flammable fuel and create disturbing noise levels. Full size aircraft can pose a substantial risk to property and individuals on the ground as well as the flight crew themselves. Using a lightweight drone allows these functions to be performed more safely to the public, with less risk of severe damage or loss of life or property. The reduced sound levels
are benef icial to the public as well.

Land restoration and remediation sites, environmental monitoring and land use and management sites are areas that are commonly populated by high concentrations of wildlife that may be disturbed by the noise levels created by low level full size aircraft. Migratory and other birds can cause a severe hazard to
fu ll size aircraft in these areas when disturbed en masse

.

Some of these sites require significant manpower and effort to access, exposing employees to dangerous conditi ons. Barriers to entry can include overgrowth of brush, running and standing water, and wildlife habitat. Further these employees are exposed to extremes of temperature and humidity and can be in inaccessible locations that render emergency extraction diff icult and time consuming. Using a UAS to perform these inspections removes the potential hazards to humans.

Inspection of infrastructure including towers require sending people up to dangerous heights or subject them to dangerous situations where the pos sibility of death or sever e injury is heightened . Using UAS to perform these inspection functions nearly eliminates this risk to human life. Use of UAS also allows
these sites to be accessed more expediently and with greater frequency.

Search and rescue w ith UAS benefits the public by being quick to deploy and operable in conditions where airports may not be available for use (i.e., the aftermath of a tornado outbreak, earthquakes, hurricanes).

UAS training offers the benefit of teaching and mentoring pil ots intending to become UAS operators. By being trained by a highly experienced pilot with extensive experience in the NAS a culture of safety can
be inculcated.

II. T HE UAS The operator requests an exemption to operate the following: DJI Inspire 1,
DJI Phant om 3 Pro, DJI Phantom 3 Advanced, DJI Phantom 2, 3DR Solo,3

Yuneec Q500+, 1 all of which are well below 55 pounds including payload. Through the Section 333 exemption process,
the FAA has authorized use of all UAS for which exemption is requested herein.

III. REQUEST FOR SUMMARY GRANT Because this petition is similar in material respects to previous petitions the FAA has granted, the
operator requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited
summary grant process. Specifically, the public inter est and safety benefits the operator’s operations will achieve are materially similar to those recognized in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA

- 2014

- 0352), Ill 09 to Clay co, Inc. (see Docket No. FAA

- 2014

- 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

- 2014

- 0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA

2014

- 0642). Ray com will adhere to a series of operating parameters that will offer the same level of safety as the conditions the FAA currently requires in its summary grants. 2

IV. APPLICANT INFORMATION The name and contact information of the applicant is:

Michael Jeremiah Wraight 522 Pennsylvania Ave., Plymouth, IN 46563

- 2759

Phone: (574) 540

- 9553
Email: michaeljwraight@gmail.com

V. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a);
14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

1 See Exemption No. 11274A to United Services Automobile Association, Regulator y Docket No. FAA2014

- 0796 (authorizing use of the 3DR Solo , DJI Phantom 3, and DJI lnspire); Exemption No. 11875 to Green Bee Limited, Regulatory Docket No. F AA

- 20 15

- 0698 (authorizing use of the DJI Phantom 2); Exemption No. 12023 to William J. Henderson, Regulatory Docket No. FAA

- 2015

- 1518 (authorizing use of the Yuneec Q500 Typhoon).

2 See, e.g., Exemption No. 12160 to Star Engineering Services LLC, Regulatory Docket No. FAA

- 2015

- 1690 (Jul. 27,

2015 )4

VI. OPERATING PARAMETERS The Operator will adhere to the following operating par ameters when operating U AS pursuant to a grant of the requested exemption:

1. Operations will be conducted using the DJI Inspire 1, DJI Phantom 3 Pro, DJI Phantom 3 Advanced, DJI Phantom 2, 3DR Solo, Yuneec Q500+

2. The UAS will not be operated a t a speed exceeding 87 knots (1 00 miles per hour), at an altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations will be conducted during the day under visual meteorological conditions.

3. All operations will be conducted in accordance with a Ce rtificate of Waiver or Authorization ("CO A'').

4. All operations will use a pilot

- in

- command ("PIC") and a visual observ er ("VO"), and the UAS will remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS capability and the ability to co mmunicate verbally with the VO at all times.

5. The PIC will hold an airline transpor t, comme rcial, private, recreational, or sport pilot cer tificate, as
well as an FAA airm an medical certificate or a valid U.S. driver's license. The PIC will meet the flight review requirements specif ied in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rate d on his or her pilot certificate.

6. The operator will ensure prior to operation that the PIC has demonstrated the ability to safely operate
the UAS in a mann er consistent with how the UAS will be operated under this exemption, including
evasive and eme rgency maneuvers and maintaining appropriate distances from pe rsons, vessels,
vehicles and stru ctures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 C.F.R. § 61.51(b).

7. Raycom's operating documents will be ac cessible during UAS operations and made a vailable to the Administrator upon request.

8. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the U AS is found to be in a condition for safe flight.

9. Any UAS that has undergone maintenance or alterations that affect the U AS operation or flight characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to conducting fu r ther operations under this exemption.

10. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety b ulletins, for the aircraft and aircraft components.

11. The PIC will ab ort the fl ight in the event of unpredicted obstacles or emergencies, and will yield to all
manned aviation activities.

12. The operator will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.5

VII. THE FAA’S AUTHORITY TO GRANT THIS PETITION The FAA has authority to grant the exemption requested herein under the FMRA and the Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, and directs the Secretary of Transportation to determine which UAS, "as a result of their size, weight, speed, operational capab ility, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security." 3 Section 333 further directs the Secretary to "establish requirements for the safe operation of such aircraft systems in the national airspace system. " 4 The Federal Aviation Act authorizes the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions of the Act where such exemptions are in the public interest. 5 Part 11 of the Federal Aviation Regulations governs the FAA's exemption process and requirements. 6 The FAA has granted more than 1,100 exemptions to date purs uant to its Section 333 and exemption authority, enabling commercial UAS operations in a wide variety of industries

VIII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER Should the FAA determine that publication in the Federal Register is required, the operator offers the following summary pursuant to section 11.81 of the FAA's rules: 7

Petitioner: Michael Jeremiah Wraight

Sections of 14 C. FR. Affected: 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315 (a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Description of Relief Sought: Petitioner s eeks relief from the requirements of 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91. 405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for aerial data collection to include aerial photography, videography, inspection and environmental monitoring of: Agric ultural sites, Land restoration and remediation sites, Land use and management, Inspection of and monitoring of construction sites and utilities infrastructure Search and rescue, First responder services, Real estate for marketing Special events, UAS p ilot training.

3 Pub. L. No. 112

- 95, 126 Stat. 75

- 76 (codif ied as a Note to 49 U.S.C. § 40101 )

4 Id.

5 49 U.S.C. § 44701 (f) ("The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of t his title if the Administrator finds the exemption is in the public interest.")

6 See 49 C.F.R. Part 11

7 I d.§ 11.81(1)6

IX. CONCLUSION As demonstrated above, the UAS operations the operator has proposed in this petition for exemption will garner significant public benefits while pr esenting minimal safety risks. The operator 's petition
satisfies the criteria of Section 333 of the FMR A and is substantially similar to previous petitions the FAA has granted, meriting a summary grant of exemption. The operator respectfully requests that the FAA grant this petition to grant the operator ability to provide imp ortant ae rial data collections services.

Sincerely,

Michael Jeremiah Wraight