August 5, 2015

Gabriel Graveline 9101 N.130 th East Av e. Owasso, OK 74055
U.S. Department of Tr ansportation Docket Operations We st Building Ground Floor Room W12

- 140 1200 New Jersey

Av enue, SE., Wa shington, DC 20590

- 0001

**RE:** Exemption Request Section 333 of the F AA Reform Act of 2012 and Part 1 1 of the Federal Av iation Regulations Dear Sir or Madam; In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, Gabriel Graveline requests exemption from the Feder al Av iation Regulations to allow for commercial UAS operations of a DJ I Phantom 2 V ision +, DJ I Phantom 3 Professional, DJ I Inspire 1, and Yuneek Q500 4k T yp hoon for the purpose of aerial photography

, tower inspection, real estate marketing, surveying, agricultural mapping , search and rescue, and other flight operations that could be performed safe r, quicker, and more cost effectively than with traditional manned aircraft. **Applicant:** Gabriel Graveline 9101 N.130 th East Av e. Owasso, OK 74055 (918) 899

- 21 13 aviatorgabe@gmail.com **Attachments** links to: Documents and manuals for:

DJIphantom 2 Vi sion + http://www.dji.com/product/phanto m - 2

- vision

- plus/download DJIphantom 3 professional http://www.dji.com/product/phantom

- 3/downloadDJIInspire 1

http://www.dji.co m/product/inspire

- 1/download Yuneek Q500 4k T

yphoon http://y uneec.com/support/manuals/q500_4k.html

Regulations from which the exemption is requested: 14 CFR 21, Subpart H 14 CFR 45.2 3 (b) 14 CFR 61.1 13 (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 91.1 19 (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 91.4 09 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)
**14 CFR 21, Subpart H**

- In consideration of the size, weight, speed, and limited operating area associated with this U AS and its operation, I Gabriel Graveline request relief from 14 CFR part 21, Subpart H, and an y associated noise certification and testing requirements of part 36. The UAS will carry neither pilot, passenger, explosive materials or flammable liquids. **14 CFR 45.23 (b)**

- Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no cabin, cockpit , or pilot station on which the word "Experimental" can be placed. Given the size of the UAS, two

- inch lettering will be not be possible. The word "Experimental" will be placed on the fuselage in compliance with § 45.29 (f). The equivalent level of safet y will be provided by having the UAS marked on its fuselage as required by § 45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental."**14 CFR 61.1**  **13 (a) & (b) & 14 CFR 61.133 (a)**

- Since the UAS will not carry a pilot or passengers , IGabriel Graveline request relief from these regulations. As a licensed private pilot Iwill be the PI C and sole manipulator of the controls

. A visual observer or ( VO) will be utilized and required to communicate verball y with me at all times. The UAS will be limited to operations within visual distance of both the PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use of a UAS are far less than similar commercial aircraft operations. **14 CFR 91.7 (a)**

- Since the UAS will not carry a pilot or passengers there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no F AA regulatory standard exists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safet y checklist prior to each flight, an equivalent level of safet y will be provided. All flights for each aircraft will be in accordance with the safe ty and maintenance recommendations found in the attac hed manufacturers’manuals

. **14 CFR 91.9 (b)(2)**

- Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity , or pilot on board to adequ atel y carry a flight manual. An equivalent level of safety will be maintained b y keeping the flight manual at the ground station where the UAS pilot will have immediate access to it. **14 CFR 91.103 (b)(2)**

- As no F AA approved flight manuals will be provide d for the aircraft listed, an exemption is needed. Alternate procedures including but not limited to reviewing airspace, weather conditions, checking flight battery requirements, checking takeof f and landing distances , along with checklists found in the manufacturers’manuals will be implemented. These actions will provide an equivalent or higher level of safet y . **14 CFR 91.109**

- UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. An equivalent level of safet y will be achieved using the real time ground station data since the UAS will carry neither a pilot or passengers. **14 CFR 91.1 19 (c)** 

- The UAS will never be operated at an altitude higher than 400 feet AGL. The UAS will operate in safe areas away from public and traf fic and only

with permission of the property and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical height of400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved. **14 CFR 91.121**

- As the UAS may not have a barometric altimeter, but instead a GPS bar ometric sensor for altitude information an exemption may be required. An equivalent level of safet y will be achieved using a ground station which links to a tele m etry data link. This will provide the pilot with live flight data monitoring, confirming the a ltitude of the launch site shown on the GPS altitude indicator prior to flight. **14 CFR 91.151 (a)**

- The UAS has a limited range and will be limited to operations in acontrolled environment. The battery power the UAS above provide approximately 2 2 minutes of flight time. The UAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption. An equivalent level of safet y will be achieved b y monitoring the battery

through the ground station and landing with a minimum of 30 percent b attery

power remaining. **14 CFR 91.203 (a) & (b)**

- Given the size and configuration, the UAS does not have the ability to carry a flight manual on the aircraft. There is no room, capacity , or pi lot on board to store a flight manual. An equivalent level of safet y will be maintained by keeping the flight manual at the ground station where the UAS 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 ap plicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight: **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)**  **Equiv alent Level of Safety**  In addition to the safet y s tandards mentioned above the UAS will adhere to the following additional guidelines: 1. The U AS will not be operated within 5 miles of an airport unless prior contact to Air Tr af fic Control has be en established. 2. Flights will not exceed the an airspeed of 87 knots (100 mph) 3. Flights will be operated at or b elow an altitude of 400 feet AGL. 4. The PI C and VO will communicate verball y at all times. 5. UAS operations will not be conducted duri ng night , as defined in 14 CFR § 1.1. 6. All operations will be conducted under VMC

. 7. The UAS will land with a minimum 30 percent battery reserve remaining. 8. The UAS will only be piloted within visual line of sight

. 9. The UAS will utilize an interna l flight safet y feature 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 UAS will abort flight in the event of unpredictable obstacles or emergencies. 12. Operated b y the Applicant , a licensed private pilot. **Public Inter est**  I believe the use of a s UA V ‘s to supplement manned aircraft w ill enhance safet y and help reduce the impact t o the environment compared to similar operations conducted with a manned aircraft carrying a flight crew and flammable fuel.The inspections of cellular communication towers or similar structures will eliminate the

risks associated with persons climbing these structures. The photo graphs and video s collected can provide engineers with valuable information as to the needed maintenance of these structures for safety

. The use of a s UAV in the real estate industry helps provide a higher level of marketing and service for all parties i nvolved . The s UA V is able to provide a view which can capture the entire property in a single photo or short video clip. When compared to similar operations, utilizing a UAS poses much less of a safety concern for the general public with less fuel, time, n oise and other resources. The use of sUA

V’ s in search and rescue make it possible to place resources where they need to be quicker which can help save lives and property

. A sUA V can be deployed and provide a broader picture of conditions to help the inci dent commander make a more informed decision.
**Privacy** All flights will occur over private or controlled areas with the owner's consent. An y person captured in a collected image will have consented prior to filming or otherwise have agreed to be in the area prior to the filming taking place. The right to privacy will alway s be respected and considered. In the case of search and rescue, the standard operating procedure of the authority having jurisdiction will serve as rule in the case of emergencies when consent cannot be obtained from each individual.
Sincerely ,

Gabriel Graveline Applicant/Operator