January 10, 2016

Ronald C. Hill
3519 West 7580 So. West Jordan, UT 84084
Phone 801-550-1100 Email: Rcproductionsinc@gmail.com

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 2 User Manual v1.4 2)DJI Phantom 2 Relaease Notes 3)DJI Inspire 1 Pro User Manual v1.0 4)DJI Inspire 1 Pro Product Release Notes 12.24 5)DJI Spreading Wings S1000 User Manual v1.10 with 6)DJI Spreading Wings S1000 Release Notes, 7)DJI A2 Controller User Manual v1.24, (for S1000) 8)DJI Lightbridge 2 User Manual v1.2 (for S1000) 9)DJI Zenmuse Z15-A7 gimbal User Manual (for S1000) 10)Ronald C. Hill's Request for exemption Section 333

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA20140508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC 4) FAA Exemption No. 11603, Regulatory Docket No. FAA-2015-0521in the manner of the petition of JOHN KELLER

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, Ronald C. Hill, request exemption from the following sections of Title 14, Code of Federal Regulations §§ 61.113(a). 61.113(b)., 91.119(c)., 91.121., 91.151(a)(1)., 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 construction inventory control, search & Rescue, aerial photography, wildlife surveying, news gathering, structural inspections of structures, pipelines, well & cell towersand other flight operations that could be 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 only 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 conditions identified and proposed by, Ronald C. Hill, are drawn from references 1,2,3 & 4

The FARs

I, Ronald C. Hill, request exemption from the mentioned FARs for the following reasons. I, Ronald C. Hill Hold an Private Pilot Certificate # 3397650

61.113(a) & (b). As discussed in Exemption 11603 (JOHN KELLER), I, Ronald C. Hill, request relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. 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. 119(c) As discussed in Exemption 11138 (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 relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. I, Ronald C Hill, request waiver for this condition to allow reasonable and responsible operations with safety as my main concern in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UAS batteries provide approximately 15 to 25 minutes of powered flight depending on battery size. 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 procedure 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 11138 (DOUGLAS TRUDEAU),

I, Ronald C Hill, propose to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The 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 ensurethat safety would not be adversely affected.

The UAS’s

The DJI Phantom 2,Inspire 1 Pro & Spreading Wings s1000 are small rotor-craft in the quad-copter & octo-copter configuration with a weight of 2.5 to 9.7 lbs designed primarily to carry aloft photo equipment. It has a maximum speed of less than 35 knots (16m/s) and a maximum climb rate of less than 1000 feet per minute (6 m/s). It is powered by four to eight electric motors. All 3 UAS's utilize the following items for UA operation conditions and control. They utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its 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 battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control gimble camera angle. It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the on-board flight controller and maximum altitude can be pre-programmed by the PIC. Battery life limits flight times to approximately 15 to 25 minutes depending on battery size. The on-board 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 9 min for 15 min capacity battery and 16 minutes for 25 min capacity battery's. More information is available in attachments

I have enclosed User Manuals and release notes for equipment used.

Risk mitigation

I, Ronald C Hill, have reviewed FAA exemptions reference’s 13 Conditions and Limitations section and believe that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A pre-flight checklist will be developed and employed to ensure that the UAS’s 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. I, Ronald C Hill, request that in a manner similar to reference 3, be allowed to operate within 5 miles of an airport provided that. “The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAA published aeronautical chart unless 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 activities 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 interestUse 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 construction assets, buildings, bridges, towers, and 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 assets counted without the need for people to travel in areas that are hard to reach by vehicle or foot. 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 business owners or their designers seeking enhanced business processes like inventory control, aerial photography and aerial video. A visual observer will be utilized at all times and the PIC ( Ronald C. Hill ) holds a private Pilot Certificate. Flight data including UAS flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from normal operations will also be recorded and made available to FAA.

I, Ronald C. Hill, 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

Conclusion

I, Ronald C. Hill am requesting this exemption for the purposes of inventorying construction material, building inspections, land surveying, pipeline inspections, tower inspections,land & wildlife surveying, search & Rescue, aerial photography, aerial video,news gathering, real estate photo & video and other flight operations.

The reason for such a general and broad based request is that I, Ronald C. Hill, wish to offer a broad range of services to current and potential entity's without delaying requested services that would require the long turnaround time associated with additional exemptions. My business plan is based on the idea of offering small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or prevent structural disasters that may influence the general public or individuals. Research shows an increased demand for Licensed FAA Pilots who have the experience & knowledge of operating within The National Airspace System legally with safety as there main concern.

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

Sincerely, Ronald C. Hill Operator