Jeffrey Hall, Phoenix Aerial Imaging Page 1

Jeffrey Hall Phoenix Aerial Imaging
27 Michele Drive Portland, CT 06480

U.S. Department of Transportation Docket Operations West Building Ground Floor

Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590-0001

October 19, 2015

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam;

In accordance with the Public Guidance for Petition s for Exemption filed under Section 333, I, Jeffrey Hall of Phoenix Aerial Imaging request exemption fr om the Federal Aviation Regulations to allow for commercial sUAS (small Unmanned Aerial System) oper ations of the following:

1. Spreading Wings DJI S900

2. Kong FH800/PixHawk Hexacopter (equivalent to the DJ I S900 in size, shape and operation)

3. DJI Flamewheel 450

4. HMF 580/PixHawk Quadcopter (similar to the DJI Flam e wheel 450 in size, shape and operation)
5. DJI Inspire 1
6. DJI Phantom III

7. 3DR Solo

The above mentioned sUAS platforms would be useful for the purpose of aerial photography/remote sensing data collection of the following:

• Local civil/commercial utility infrastructure inclu ding but not limited to electrical power lines, wind turbines, cell towers, bridges, highways and n atural gas pipelines.

• Real estate marketing, surveying and engineering pr ojects.

• Archeological studies.

• Agricultural monitoring and mapping.

• Estuarine coastal studies and mapping.

• Provide assistance in local search and rescue opera tions in cases of emergency or natural disasters if local authorities request such help.

• Aerial film making and photography.

• Construction site inspections and monitoring.

• Wildlife and forestry monitoring.

I feel that the above mentioned and other flight op erations could be performed safely and more cost effectively than with a traditional manned aircraft

.Jeffrey Hall, Phoenix Aerial Imaging Page 2

Name and address of applicant:

Jeffrey Hall Phoenix Aerial Imaging
27 Michele Drive Portland, CT 06480 (860) 682-5472

Attachments:
1. sUAS User Manuals 2. sUAS Safety Guidelines (AMA sUAS Flight Safety G uidelines)
3. sUAS Maintenance Guidelines

Regulations from which the exemption is requested:

14 CFR 21, Subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 (b)(2)
14 CFR 91.109 14 CFR 91.119 (c)
14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(l) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H- In consideration of the size (less than 3feet in di ameter), weight (approximately 10 lbs), speed (less than 40 mph), and limited oper ating area associated with this sUAS and its operat ion, I request relief from 14 CFR part 21, Subpart H, an d any associated noise certification and testing requirements of part 36. The sUAS will carry neithe r pilot, passenger, explosive materials nor flammab le liquids.

14 CFR 45.23 (b)- Even though the sUAS will have no airworthiness cer tificate, an exemption may be
needed as the sUAS will have no entrance to the cab in, cockpit or pilot station on which the N-Number can be placed. Given the size of the sUAS, two-inch lettering will be impractical. Markings (N-Number) will be placed on the fuselage in as large a size a s practiable in compliance with 14 CFR part 45, Sub part C. The equivalent level of safety will be provided by having the sUAS marked on its fuselage as requi red by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification o f the

sUAS.

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the sUAS will not carry a pilot or passengers I request a relief from these regulations. Any pilot in command or (PIC) operating the sUAS will hold a Recreational Pilot (or greater) certificate. A visu al observer or (VO) will be utilized and required t o communicate verbally at all times. The sUAS will be limited to operations within visual line of sight of both the PIC and VO. All sUAS operations will take place in a controlled area with permission granted byJeffrey Hall, Phoenix Aerial Imaging Page 3

the client/property owner. The risks associated wit h the use of a sUAS are far less than similar commercial aircraft operations.

14 CFR 91.7 (a)- Since the sUAS will not carry a pilot or passe ngers there will be no airworthiness certificate issued for the aircraft, should this ex emption be granted, no FAA regulatory standard exis ts for determining airworthiness. Given the size of the a ircraft, maintenance, and use of safety checklist p rior to each flight, an equivalent level of safety will be provided. All flights will be in accordance with th e safety

and maintenance recommendations found in the attach ments.

14 CFR 91.9 (b)(2)- Given the size and configuration, the sUAS has no a bility to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level of safety will be maintained by ke eping the flight manual at the ground station where the sUAS pilot will have immediate access to it.

14 CFR 91.103 (b)(2) - As no FAA approved flight manuals will be provide d for the aircraft an exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight battery requirements, checking take off and landing distances along with those found in the attached "AMA sUAS Flight Safety Guide" will be imp lemented. These actions will provide an equivalent or higher level of safety.

14 CFR 91.109- s UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control bo x that communicates with the aircraft via radio communications. An equivalent level of safety will be achieved using the real time ground station data and given the sUAS will carry neither a pilot nor p assengers.

14 CFR 91.119 (c)- The sUAS will never be operated at an altitude high er than 400 feet above ground level (AGL). The sUAS will operate in safe areas aw ay from public and traffic and only with permission of the property and structure owners. The sUAS will also be restricted by the flight controller to a maximum vertical height of 400 feet AGL, and Visual Line of Sight horizontally. Given the size, weight

, maneuverability and speed of the sUAS, an equivalen t or higher level of safety will be achieved.

14 CFR 91.121- As the sUAS may not have a barometric altimeter, bu t instead a GPS barometric sensor for altitude information an exemption may be requir ed. An equivalent level of safety will be achieved using a ground station which links to a telemetry d ata link. This will provide the pilot with live fli ght data monitoring, confirming the altitude of the launch s ite shown on the GPS altitude indicator prior to fl ight.

14 CFR 91.151 (a)- The sUAS has a limited range and will be limited to operations in a controlled environment. The battery power for the UAS provides approximately 20 minutes of flight time. The sUAS is unable to meet the 30 minute reserve requir ement and therefore requires an exemption. An equivalent level of safety will be achieved by moni toring the battery through the ground station and landing with a minimum of 30 percent battery power remaining.

14 CFR 91.203 (a) & (b)- Given the size and configuration, the sUAS has no a bility to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight man ual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station wh ere the sUAS pilot will have immediate access to it.

Given the following sections only apply to aircraft with an airworthiness certificate, these sections do not apply to this applicant. As a safety precaution, th e operator will perform preflight inspections and e nsure sUAS is in working condition before initiating each flight:Jeffrey Hall, Phoenix Aerial Imaging Page 4

14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)

Equivalent Level of Safety In addition to the safety standards mentioned above the sUAS will adhere to the following additional guidelines:

1. The sUAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic
Control has been established.

2. Flights will not exceed an airspeed of 40 mph (34.8 knots).

3. Flights will be operated at or below an altitude ne ver exceeding 400 feet AGL.

4. The PIC and VO will communicate verbally at all tim es. 5. sUAS operations will not be conducted during night.
6. All operations will be conducted under visual meteo rological conditions.

7. The sUAS will land with a minimum 20 percent batter y reserve remaining.

8. The sUAS will only be piloted within visual line of sight.
9. The sUAS will utilize an internal flight safety fea ture that will return to a preprogrammed position and land if communication with the remote control is lost.

10. Preflight inspections and protocol will be followed prior to all operations.

11. The sUAS PIC will abort flight in the event of unpr edictable obstacles or emergencies.

Public Interest
I believe the use of a sUAS in lieu of a manned air craft would enhance safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carrying a crew and flammable fuel. The inspections of cellular co mmunication towers, buildings, bridges or similar
structures will eliminate the risks associated with persons attempting to climb these structures. The photographs and video collected will provide engine ers with valuable information as to the safety of t hese structures. The monitoring of agricultural crops, archeological studies and mapping, and estuarine co astal studies and mapping could all benefit from the use of the sUAS as a mapping tool due to its ability to perform safely and more cost effectively than with a traditional manned aircraft. The use of a sUAS in the real estate industry provides both the buyer and se ller with a higher level of marketing and service. The sUAS is able to provide a view which encompasses th e entire property in a single photo or short video clip. When compared to similar operations, utilizin g a sUAS poses much less of a safety concern for th e general public with less fuel, time, noise and othe r resources.

Privacy All flights will occur over private or controlled a reas with the owner's consent. Capturing people in images will rarely occur. If a person is captured i n a collected image they will have consented prior to filming or otherwise have agreed to be in the area prior to the filming taking place.

Sincerely,

Jeffrey Hall Phoenix Aerial Imaging

# Attachments

# Attachment 1

User Manuals

# Attachment 2

Safety Guidelines

(AMA sUAS Flight Safety Guidelines)

# Attachment 3

Maintenance Guidelines