**Name and A ddress of Petitioner:** 

Mr. Carl Young Premier Drone Solutions, LLC 2205 Tuscany Drive Corinth, TX 76210

**Docket # FAA**

**- 2015** 

**- 6060**  RE: Request for additional information, letter dated February 23, 2016

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l) and (2), 91.417(a) and (b)

Premi er Drone Solutions, LLC, the petitioner, requests exemptions in order to legally operate an Unmanned Aircraft System (UAS), as defined under Section 333 Subtitle B (6), and specifically the DJI Phantom 3 and/or DJI Inspire 1 , as well as other similar FA A a pproved, and registered small UAS in the National Airspace System.

All flights of the UAS will be flown, in line of sight during daylight hours, at less than 175' above ground level (AGL) and well clear of the flight path of any manned aircraft. The UAS also uses a smartphone or similar device to enhance controls by showing current AGL and visual location of the UAS to the subject and its surroundings. The petitioner wishes to be granted the exemption for use of the UAS for commercial data collection incl uding, but not limited to, videography and photography of:

1. Residential and Commercial Real Estate for marketing or analysis 2. Construction (Residential and Commercial), providing a visual review of the construction process to be used for marketing or analysis 3. Property Survey, providing a visual review of the property for marketing or analysis. 4. Property Inspection, providing a visual review of existing conditions for marketing or analysis. 5. Landscaping, providing visual documentation of ‘before and after’ improvement for marketing or analysis.

Using a small UAS substantially reduces the risk to public safety in comparison to a manned fixed wing aircraft or rotorcraft. We ig hing less than 10 pounds, the UASs deployed by Premier Drone Solutions are incapable of causing the level of damage or injury that could potentially be caused by a full

- size, manned aircraft. In addition, the ecologic and noise impact is negligible as compared to a traditional manned aircraft. Furthermore, this valuable service is substantially more cost

- effective than using fixed wing aircraft or rotorcraft, thus providing a means for small businesses to capture previously cost

- prohibitive, but all too important, data.

Request for Exemption, Section 333 of the FAA Reform Act pe rtaining to Federal Aviation Regulations:

**14 CFR Part 21** Certification Procedures For Products and Parts

 **RE AS**  **ON FOR EXEMPTION** It has been determined that similar UAS’s do not require an airworthiness certificate as granted in Exemption No. 11623, 11650, 11664, and 11734.**14 CFR 61.23**

Medical Certificate Requirement

 **RE AS**  **ON FOR EXEMPTION** It has been determined that this requirement is not applicable for these stated purposes, and exemptions have been granted at least twice in exemption #'s 14977 and 14970

.

**14 CFR 61.101(e)4** Recreational Pilots may not act as pilot in command of an aircraft for compensation or hire.

 **RE AS**  **ON FOR EXEMPTION** It has been determined a recreational license may be used for compensation or hire under these circumstances. See Exem ption No.s 14977 and 14970.

**14 CFR 61.113(a) and (b)** Private pilot privileges and limitations: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensatio n or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that bu siness or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

 **RE AS**  **ON FOR EXEMPTION** All flights of the UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Premier Drone Solutions’s business; and (2) will not carry passengers or property for compensation or hire.

**14 CFR 61.315(a)** Sport pilots may not act as pilot in command of an aircraft for compensation or hire.

 **RE AS**  **ON FOR EXEMPTION** It has been determined a sport pilot certificate may be used for compensation or hire under these circumstances. See Exemption No.s 14977 and 14970.

**14 CFR 91.7(a)** Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

 **RE AS**  **ON FOR EXEMPTION** It has been determined that similar UAS’s do not require an airworthiness certificate, however the petitioner will ensure airworthiness through the combined use of the manufacturer's operations manual and preflight checks.**14 CFR 91.119(c)**

Minimum Safe Altitudes:(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated a reas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure.

 **RE AS**  **ON FOR EXEMPTION** The UAS will be flown no higher than 200’ AGL in line of sight over developed and developing residential areas th at may be considered congested areas. That will not always be the case when providing a ‘Property Survey’ flight because they could be conducted over empty lots or acreages with no structures. This will minimize the amount of bystanders present or in the s urrounding area. In the case of flying over or near existing private property while providing photography for ‘Residential and Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and ‘Property Landscaping’ landowners will be notified in p erson by the petitioner, or by a card left behind by the petitioner, of an occurring UAS flight. The petitioner also proposes to display a caution sign on site while a UAS flight is ongoing. The petitioner will review with the landowners the associated ris ks to people and property. Due to the small size of the UAS the associated risk to persons, vessels, vehicles, and structures is not comparable to manned aircraft.

**14 CFR 91.121** Altimeter Settings.

 **RE AS**  **ON FOR EXEMPTION** The UAS does not have a barometric altimeter. It does have a GPS that will calculate altitude. The petitioner will limit flights to a maximum altitude of 175 feet AGL as granted in Exemption No. 11623, 11650, 11664, and 11734.

**14 CFR 91.151** Fuel requirements for flight in VFR conditions

 **RE AS**  **ON FOR EXEMPTION** The UAS provides low battery warnings to indicate when the Pilot in Command should return the UAS to the launch point. The UAS will be landed upon the 1st low battery alert. The petitioner will not initiate a flight unless (consideri ng wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point. All flights will be done during the day and at an appropriate time as to not be a nuisance to others.

**14 CFR 91.405(a)** Ma intenan ce required: Each owner or operator of an aircraft: (a) Shall have that aircraft inspected as prescribed in Subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as presc ribed in part 43 of this chapter.

 **RE AS**  **ON FOR EXEMPTION**The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to follow manufacturer's recommended preflight checklist.

**14 CFR 91.407(a)(1)** Operation after maintenance, preve ntive maintenance, rebuilding, or alteration: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless(1)It has been approved for return to service by a person authorized under 43.7 of this chapter

 **RE AS**  **ON FOR EXEMPTION** The petitioner who has the responsibility for the operation and safety of the UAS will follow the manufacturer's suggestions for maintenance and repair, including the use of suggested replacement parts.

**14 CFR 91.409(a) (1) & (2)**  Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been a pproved for return to service by a person authorized by 43.7 of this chapter ; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records.

 **RE AS**  **ON FOR EXEMPTION** The petitioner will follow manufacturer’s suggestions to ensu re that the UAS is in a condition for safe flight.

**14 CFR 91.417(a) & (b)** Ma intenance Records: (a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or operator shall keep the following records (l)(i)(ii)(iii) (2)(i)(i i)(iii)(iv)(v) (vi) for the periods specified in paragraph (b) of this section: (1)(2)(3)

 **RE AS**  **ON FOR EXEMPTION** The petitioner will keep a record of all repairs and modifications. The petitioner will also use manufacturer approved parts for repa irs and modifications.

**SUMMA RY**  Premier Drone Solutions, LLC, the petitioner, requests for exemption Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l) and (2), 91.417(a) and (b) in order to legally operate an Unmanned Aircraft System in the Natio nal Airspace System in order to collect data including, but not limited to, aerial video and photography for real estate marketing, construction, survey, landscape and inspection purposes. This submission is substantially similar to granted exemptions 1497 7 and 14970.