Brent Habbeshaw

104 Aspen St
Lufkin, Texas 75901
(936) 225

- 0225 Brent1956@gmail.com

To whom it may concern:
My name is Brent Habbeshaw and I would like to submit a petition for an exemption under Section 333 of the FAA. I would like to use a multi

- rotor quadcopter aerial drone Model DJI Phantom 3 Professional for commercial purposes. The quadcopter is fitted with a camera that will capture images for farming communities and real estate surveillances in rural a reas of Texas farmlands as to assist cattle farmers and produce farmers manage the locations of herds, waterholes and soil composition coloring for crop management. It will be flown within FAA guidelines for use and always abide by the FAA’s rules and reg ulation both presently and future. The Phantom 3 Professional quadcopter uses wireless communication with the controller transmitter operating in the 5.8 GHz frequency band. It is compliant with CE (300m) and FCC (500m) regulations and effective ranges. If it flies beyond the effective range i t will enter into a failsafe mode and return home. Max height and radius have been set in the unit’s software as well as no

-fly zones and restricted

- altitude areas. The software alerts the operator when near these area s and issues a warning when flying near the zone. If it enters a no

-fly zone it automatically lands. If trying to take

- off in a prohibited area the motors will not start. The quadcopter will be flown in residential areas and on personal farm property as pe rmitted by the land or home owner. Safety procedures will be in effect including a maximum height of 200 feet for flight and a maximum speed of less than 10m/s. In addition, propeller guards will be used when flying in proximity to people. The unit will be in DOL

- direct line of sight of the operator at all times. It will also be flown in winds under 10 mph to minimize risk of crashing. Pre

-flight safety check includes examining battery, propellers, calibrating the compass and the unit’s shell for damage an d that the self

-tightening propellers are secured. The quadcopter will not be flown in inclement weather including heavy wind and rain or fog . Obstacles such as trees, power lines and buildings will also be avoided at all times . Regular maintenance will be performed as required for the motors and internal circuitry. Propellers will be changed for new ones if chipped or damaged in any way. Screws on the unit’s shell will be inspected frequently for signs of loosening. The weight of the craft is 5.5 pounds wh ich is well below the m aximum weighted payload of 55 pounds . Max speed is 15m/s. My proposed speed will be much lower than this as I’m only concerne d with capturing images of farmlands, crop fields and property. The operating frequency of the controller’s wireless range extender is 2412MHz

- 2462MHz and the open area communica tion distance is 300m. I, Brent Habbeshaw , will be the only operator using the quadcopter under this exemption and am directly responsible for the proposed operation.I have become com pletely versed in operating this device fro m several months of personal flights.

Beginning with thorough review of the Phantom 3 Professional Owner’s Manual and 60 hours of logged flight time on the Phantom 3 and over 100 hours of flight time on the Hudso n H107C quadcopter. And studying FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 and will continue to keep updated with all new FAA Rules and Regulations and abide faithfully to all of them. Respectfully FAA, In accordance with the FAA's Guid elines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Refo rm Act of 2012, I, Brent Habbeshaw, request exemption from the following sections of Title 1 4, Code of Federal Regulations 61.113(a). 61.113(b). 91.119(c). 91.121 . 91.151 (a). 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 aerial photography, structural inspections of bridges, pipelines, waterways, well s and farmland and fields , real estate marketing and surveys an d other flight operatio ns that w ould be in 91.405(a). 91.407(a) (1). 91.409 (a) (1) & (2). 91.417(a) & (b) As discussed in Exemption 11138 (DO UGLAS TRUDEAU), I, Brent Habbeshaw, 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 recordkeeping, were sufficient to ensure that safety would not be adversely affected. The DJI Phantom 3 Professional

- unaltered in anyways is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an

a dvertised weight of less than 45 ounces (1242g) designed primarily to carry aloft a high definition 4k camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of l ess than 1500 feet per minute 10 m/s). It is powered by four electric motors with a distance between
motors of less than 14 inches ( 350mm )

. It 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 co ntrol (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 camera angle. It has fail safe modes of operation for either 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. Th e onboard flight controller will warn the pilot via telemetry and external lighting cues and verbal audio sounds 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 flight s will usually last less than 15 minutes. More information is available in attachment 1. Risk mitigation I, Brent Habbeshaw, 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 preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be verified before lau nch. 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, Brent Habbeshaw, state that operation will not occur within 5 miles of an airport or any unauthorized space. "The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 nautical miles of the geographic center of a non
towered airport as denoted on a current FAA p ublished aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with aNOTAM as required by the operator's COA. The letter of agreement with the airport management must

be ma de available to the Administrator upon request. Further if flying in dust cropping areas, all runway operators or towers will pre

- contacted that there are no scheduled crop dusting or surveillance within five miles of my flight area.

Public interest u se 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 p erforming inspectio ns of cattle farms, crop fields, and water supplies and real estate properties the UAS will minimize the risk to persons attempting to climb hills and ravens s and traverse large farm properties in fueled vehicles in rugged terrain or housing and barns savi ng fuel and reduce environmental impacts and saving our farmers valuable time and money and safety in surveying their properties in 1/10 of the time. It will provide a way for farmers to review photographs and provide better grazing and more fertile farm a reas to schedule crop rotations for present and future harvests. If an area is suspected of being inaccessible, the UAS can reach it to make an assessment eas ier and safer. I, Brent Habbeshaw, will also make the UAS and myself available as a local volunt eer to organizations (for no charge) such as fire departments, local law enforcement, etc., to perform search and rescue operations, or other similar events as requested by authorities. In addition the use of the UAS in order to facilitate commerce could l ead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance my personal photography. A visual observer will be utilized at all times that the UAS is performing duties for compensation. My o wn research shows an upward demand for these services that currently exists in the real estate market, surveying and other markets are just beginning to realize the need for such services for farmers and rancher who are often left behind in technological a dvantages, which I hope to assist them in making the United Sta t es of America the top cattle, dairy and crop producing nation in our world

. 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 rec orded and made available to FAA.
Conclusion I, Brent Habbeshaw , am requesting this exemption for the purposes of aerial photography of real est ate, bridge inspections, l and surveying, cattle grazing and useable crop farming lands , waterways and wells, and other flight operations. The reason for such a general and broad based request is that I, Brent Habbeshaw, wish to utilize a business strategy in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. My business model is based on the idea of offering small UAS services to individuals or companies , farmers and r ancher 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 g eneral public or individuals or livestock, being performed safely and more cost effectively wi th 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 co nditions identifie d and proposed by, BrentHabbeshaw, are drawn from references 13. 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 "dens ely populated". I, Brent Habbeshaw, reque st 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 n ot 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 t han 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’s batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC wil l initiate a landing procedure when battery power 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

. I, Brent Habbeshaw, live and work and would use my UAS in a very rural community, away from dense population, airports and people. I would only do my flight surveys in daylight and good weather conditions . With the upmost safety of persons, animals and structures, always abiding by the FAA’s present and future rules and regulation. Making my community a better place to live and conduct commerce and provide needed income for my son and myself. I sincerely thank you for the opportun ity to request exemptions and permission to fly commercially. Doing so legally with the FAA’s blessings and set an example to other UAS operators to do so legally within the FAA’s standards.
Sincerely, Brent Habbeshaw