Tim Shingleton

Playthings Etc. 2483 W illiam Flynn Hwy Butler PA 16001 724

- 285

- 7529 fax 724

- 285

- 7594

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) ( c)(d) (e)(f)(g)(h), 61.113 (a) & (b), 91.103
Following the format of FAA Exemption No. 11138

- Regulatory Docket No. FAA

–2014

– 0481 I have included: 1) Supplemental Response for Petition 2) BLADE Chroma Drone with CGO2+ Manual

Pursuant to Section 333 o f t he FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Tim Shingleton, a Model Aircraft operator for 10+ years, preparing this exemption request myself, would like to apply for an exemption from the following Code of Federal Regulations ( C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging and video of We stern Pennsylvania properties and buildings

. I own a hobby grade BLADE Chroma Drone (maximum gross weight 3 pounds, equipped with fo ur rotors that are driven by electric motors powered by batteries, the UAS has a maximum airspeed of 30 knots) manned only with a CGO2+ Camera for the intent of aerial photography/videography to enhance academic community awareness and augment real estate listing images and videos; following an exemption and approval by the FAA. My exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) in predetermined areas away from general public, ai rports, heliports
, and veh iculartraffic, daylight hours only, under 2 00 ft. and after carefully

reviewing, inspecting and examining the area of aerial observation. This would allow for community and individual homeowner real estate listing videos/images within property boundaries

. I will abide all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspections and protocols, during which safety carries primary importance.
**14 C.F.R. Part 21, Subpart H: Ai**  **rw orthiness Certificates 14**  **CFR § 91.203** Given the size, weight, speed, and limit ed operating area associated with the aircraft to be utilized, I am asking exemption from 14CF R part21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).
**14 C.F.R. 45.27(a): Location of marks; non fixed**

**- wi**  **ng aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks** 

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot
s tation on which to mark certain words or phrases. Additionally two

- inch lettering is difficult to place on such a small aircraft with dimensi ons smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word “E xperimental” or assigned number or name (based on a request or ruling by the FAA ) on its fu selage as requi red by §45.29(f) so that anyoneassisting him as a spotter will see the markings. I also ask for an

exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted sinc e they only apply to aircraft with an airworthiness certificate. But , as a safety precaution I will perform a preflight inspection of my UAS before each flight as outlined in it's operating documents.
**14 CFR 61.113 (a) & (b): Priv ate pilot priv**  **ileges and limitations: Pilot in command.** 
Under §61.113 (a) and (b) private pilots are limited to non

commercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passenge rs. W hile helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part61,et seq., I requests an exemption from §61.11 3 Private Pilot Privileges and Limitations.
**14 C.F.R. 91.103 (b)(1), (b)(2): Preflight A ction** 
If granted an exemption I agree to additional safety procedures including, but not limited to: 1) Keeping my UAS wi thin a radius distance of 10 00 feet from t he controller to both aid in direct line of sight visual observation. 2) Operate the UAS for 15

- 20 minutes per flight; land my UAS according to the manufacturer’s recommended minimum level of battery power. 3) Operate my UAS only within visual line of si ght (VLOS). Daylight hours only. 4) Use the UAS’s global positioning system (GPS) flight safety feature; it hovers and then slow ly lands if communication w ith the remote control. 5) Conduct all operations under my ow n personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”).6) I w ill operate and w ill actively analyze flight data and other

sources of information via telemetry to constantly update and enhance my safety protocols. 7) Contact respective airports if operations w ill be w ithin 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information. 8) Always obtain all necessary permissions prior to operat ion. 9) Have procedures in place to abort flights in the event of safety breaches or potential danger. Aerial videography for geographical
awareness of real estate marketing has been around for a long time through manned fixed winged aircraft and helicopt ers, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS, w hen used properly, w ill pose no threat to the public given its small siz e and lack of combustible fuel when compared to larger manned aircraft. I believe that the use of any tool that increases value to a home or community (by adding visibility to more potential buyers) is in the best interest of homeowners nationwide. Selling a home faster and for more money because of the use of new technology (being safely used and approved by the FAA) w ill go a long
wa y to ensure our economy continues to grow

.

Sincerel y, Tim Shingleton