U.S. Department ofTransportation Federal Aviation Administration Washington, DC

September 9, 2015

Petitioner
Stephen M. Shroyer 1609 E. 6th Street Deer Park, WA 99006 509-276-5538 shroyersm12@gmail.com

Stephen Shroyerwill be providing clients with high quality imaging for a variety of commercial, public and residential uses. He is a retired U.S. Army MasterAviator and a currentAirline Transport Pilot certificate holderwith over 7,000 hours offlying**experienc~** in both rotary and fixed wing aircraft and is seeking an exemption from these specific requirements ofTitle 14 C.F.R.:

I. 61.113 (a) and (b) II. 91

.119 (b) and (c) Ill. 91.121 IV. 91.151 (a) V. 91.405 (a) VI. 91.407 (a)(1) VII. 91.409 (a)(1) and (2) VIII. 91.417 (a) and (b)Definitions

I. AGL Above Ground Level II. ATC AirTraffic Control 

### Ill. COA Certificate ofAuthorization IV. FAA Federal Aviation Administration V. FAR Federal Aviation Regulation VI. GPS Global Positioning System VII. NAS NationalAirspace System VIII. PIC Pilot in Command IX. UA Unmanned Aircraft X. sUAS Small Unmanned Aerial System XI. VFR Visual Flight Rules XII. VLOS Visual Line ofSight

Summary In the instance ofgranting exemption, Stephen Shroyerwill be operating the sUAS in ordertofulfill contract obligations, such as: aerial photography and videographyfor real estate agents, appraisers, property managers, general contractors; solar panel installation technicians; agriculturists, utility inspections (onlywhere safeflight is attainable); chambers ofcommerce and associated businesses; wildlife conservation organizations; public departments; and all other institutions requiring filmography (safe flightpermitting)I

Aircraft

DJI Phantom 3



### A. Weight (Including Battery and Propellers) B. Diagonal Size (Including Propellers) C. MaxAscent Speed 

### D. Max Descent Speed E. Max FlightTime F. Remote Controller Operating Frequency 

### G. Auto -Takeoff

H. Auto-Return Home

I. Low Battery Failsafe 2.821bs 23.23 in 11.2 mph 6.7 mph -23 minutes 2.400 GHz- 2.483 Ghz Rises to a preset height and will hover in place until directed where to go Remembers the exactspot it took offfrom to enable atap of a button to return back home Ifthe flight battery is running low
orthe Phantom 3 loses connection with the remote it will automatically return back home

Specific Sections ofC.F.R. From Which Stephen Shroyer Seeks Exemption

I. Section 61.113(a) and (b)- Private Pilot Privileges and Limitations Section 61.113 states that no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation
or hire; nor maythat person, for compensation or hire, act as a pilot in command ofan aircraft. The sUAS will not carry a pilot or passengers. Then the stated operations can achieve the equivalent level ofsafety by requiring the PIC operating the aircraftto have completed FAA Private Pilot Ground school instruction and passed the FAA Private Pilot written exam to operate these sUAS. These sUAS are not capable ofcarrying a pilot or passengers, therefore distinguishing them as remotely controlled vehicles. The
area ofoperation is controlled and restricted providing a sound level ofsafety referenced from the operations manual. The risk associated with the operation ifa UAS is greatly reduced with a certificated Airline Transport Pilot acting as PIC this exceeding the present level achieved by section 61.113.

### II. Section 91.119
- Minimum Safe Altitudes Section 91.119 states persons may operate a helicopter at less than the minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operating the helicoptercomplies with routes oraltitudes specifically prescribed for helicopters bythe FAA. The sUAS meetsthis criterion as a helicopterand requests the abilityto operate at altitudes up to 400'AGL. Only in accordance with pre-obtained consentwill the sUAS operate while also maintaining an altitude less than 400' AGL. For comparison with traditional aircraft and rotorcraftthe sUAS weighs less than 10 lbs. while also preventing potential risks associated with flammable fuel. Lastlythe 400' AGL ceiling limits any abilityforthe sUAS to interferewith conventional aircraft operating at orabove 500' AGL.



### Ill. Section 91.121 -AltimeterSettings Section 91.121 states each person operation and aircraft shall maintain the cruising altitude orflight level ofthat aircraft, asthe case may be by reference to an altimeter this is set, when operating below 18,000feet MSL, to the current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft. Inthe
case ofan aircraft notequipped with a radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure. The sUAS will reference its altitude base on GPS and will be restricted to a 400' AGL ceiling. The PIC will also verify GPS elevation from multiple ground basedsources priorto takeoff.



### IV. Section 91.151- Fuel Requirements for Flight in VFR Conditions Section 91.151 states no person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least20 minutes. The sUAS battery powered operation flighttime is not able to incorporate a 20 minute reserve windowfollowing successful first point ofintended landing dueto the current battery capacity limitations. In ordertq provide adequate
reserve powerfor return landing the sUAS will abide bythe 12 minute flight time or25% of remaining battery power, whichever happens first.V. Section 91.405(a), 91.407 (a)(1), 91.409 (a)(1) and (2), and 91.417(a) and (b) These sections only applyt aircraftwith an airworthiness certificate; Stephen Shroyer requests exemption from these sections because the DJI Phantom 3 does not require airworthiness certificates. The sUAS is in accordance with the FMRA Section 333 for operation, absent and airworthiness certificate. In orderto insure proper maintenance the operation manual will be cited for necessary corrective measures. In addition, the PIC is the person mostfamiliarwith the aircraft and best**suit~d** to maintain the aircraft in
an airworthy condition, and any sUAS conducted maintenance will be documented for the life ofthe aircraft.

Public Interest**~** Real estate agents will be able to settheir listing apartwith a unique perspective only available from sUAS photographic equipment, therefore increasing the prospect ofmeeting or exceeding the asking price.**~** Property managers and contractors will have the abilityto surveytheir property for anomalies with preventing human endangerment due to hazardous conditions**~** Solar panel and ce11 phone towertechnicians can safely inspect potential installation locations as well as detecting probable maintenance issues associated with their equipmentwithout putting themselves in high elevation, sloping or hazardousweather conditions.**~** Agriculturists will have the abilityto survey their land in a timelier manner and betterdocumentthe condition oftheir property.**~** Marketing firms and other businesses would use unique aerial photography and videoto promote marketing campaigns and increase revenue.**~** Search and rescue entities could utilize the sUAS to help quickly aid in finding the location ofperson(s) while providing a bettervantage point in closer quarters.**~** Governmental Natural Resource agencies could use sUAS as a tool to better manage the conservation and use of public lands.

Public Safety**~** The sUAS will reduce air and noise pollution do to the aircraft being powered by
a battery and brushless electric motors.**~** This small aircraft creates less potential for harm, should and emergency situation occur, thanks to its size and weight.**~** Furthermore the lack ofcombustible fuel also significantly decreases the chance of producing harm.Conclusion

Based on the criteria provided underthe FMRA Section 333, Stephen Shroyer requests thatthe FAA grant him exemption form 14 C.F.R Sections 61.113(a)&(b), 91.119(b) and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91409(a)(1) & (a)(2), and 91.417(a) &(b) in orderto conduct contracted commercial sUAS operations using the OJI Phantom 3 for a wide range ofindustries and applications.

Sincerely,