U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, S.E. Washington, DC 20590



## Petition for Exemption Under 14 CFR § 

## 11.81 to Allow Commercial Use ofUnmanned Aircraft Systems

Petitioner: DRONE AERIAL PHOTO & VIDEO CHRISTOPHER GRUSZCZYNSKI 840 5th ST. SAN LEON, TX.77539 Email: droneaerialphotovideo@yahoo.com Ph.832 446 2200

To Whom ItMay Concern, This application is substantially based on the FAA's findings in Exemption No. 11351 granted to bizUAS Corp onApri117, 2015, and in reliance onthe analysis provided therein. 1. Sections from which exemptions are sought: Application is herebymade for exemption from: a. FAA Modernization and Reform Act of2012, PL 112-95 FEB. 14, 2012, Section 333 b. 14 CFR Part 21, subpart H c. 14 CFR Part 61.113(a) and (b) d. 14 CFT Part 91: 1. 91.103(b)(2) 11. 91.105 111. 91.109 iv. 91.119 v. 91.121 VI. 91.151 Vll. 91.405 viii. 91.407

IX. 91.409 X. 91.417 2. Reliefsought: a. Drone Aerial Photo & Video wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to)videography, cinematography, photogrammetry, industrial inspections and analyses. This reliefis soughtbecause commercial use ofsUAS is currently prohibitedby law unless performedunder an exemption. b. This exemption will coveruse ofthe following airframes, all ofwhich will weigh less than 55 pounds including payload and energy sources: 

### 1.DIJ Phanthom 3 Professional 2.DIJ lnspire1 Other models to be added by future amendmentto this exemption. 3. Public benefit: a. Use ofsUAS technology to obtain imagery, information and data currently obtainedby use ofmanned flight ormanual methods: 1. Reduces statistical risk to human life due to manned aircraft accidents (e.g., powerline inspections) and dueto other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack orbridge inspections). ii. Reduces the cost ofobtaining such information, which benefits consumers andthe economy. 111. Reduces environmental impact by eliminating sources ofhydrocarbon emissions from manned aircraft. 4. Safetynot adversely affected: a. Aircraft willberegistered and marked in accordance with Section44711 andPart 47 and Part 45, Subpart C. b. Aircraftwill comply with maintenance andinspection requirements ofthe manufacturer. All repair and maintenance workwill be conducted or approvedby qualifiedpersonnel such as those authorizedby Robotic Skies (or equivalent), and willrequire a test flight after suchwork. Records ofall maintenance and repair work willbekept in a maintenance log for each aircraft. c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight, and who willremain stationary on the ground during the flight operations: 1. A Pilot In Command (PIC) who possess the following credentials:· 1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA 2. A Third Class medical certificate issued under 14 CFR 67. 3. A bi-annual flight review under 14 CFR 6i.56 4. A certificate ofcompetency for UAS issued by UMEX (or equivalent certification). 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft (or UAS fixed-wing in the case offixed-wing flight operations underthis exemption). Such cycles and hours maybe gained during flights underthis exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119. 6. At least 5 hours offlight experience and 3 takeoffs and landings in make and model being flown inthe prior 90 days. Such cycles andhours may be gained during flights under this exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119. n. A Visual Observer. m. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificates of Authorization. e. All flight operations will comply with the following: 1. The manufacturers' AircraftFlightManuals and Operation Guideline 2. Drone Aerial Photo 

### &Video flight**opt~rations** policies including lost communication and other emergency and safety procedures. 

### 3. Conducted in VMC conditions duringdaylight hours. 4. PIC and VO will maintain VLOS at all times. 5. Pre-flight inspections (including ground control station, ifany) and sa fety risk assessments will be conductedprior to each flight. 6. Flight altitudes will remain below 400 feet above ground level. 7. Flight ground speeds will not exceed 50knots. 8. Not intrude into Class B, CorD airspace, orpublished approach, SID or STAR, or take place within 5 nautical miles ofan airport. 9. Not be made near persons as required in 14 CFR 91.119 persons onthe ground without theirpermission 10 .Each flight will be logged in both the PIC's logbook and the aircraft logbook. 11. Notexceed 75% ofthe batte1y or fuel capacity ofthe aircraft, or 30 minutes, whicheveroccurs first. 12. Any incidents will be reported to NTSB within 24 hours ofoccurrence. 13. Drone Aerial Photo & Video will maintain liability insurance ofat least $1,000,000 issuedby a major aviation insurance underwriter. 14. Any applicable local FSDO requirements. 15. All other applicable regulations concemed with the operation ofaitcraft. f. Aircraft will use 2.4 GHz for control ofthe aircraft, and 5.8 GHz for sending data with well- defined and tested lost linkprocedures. Please advise us ofany additional information orchanges that may be required. Sincerely,

Christopher Gruszczynski CEO Drone Aerial Photo & Video 07/10/2015