Steven L Hayes June 2, 2015

P.O. Box 1514 Spotsylvania, VA. 22553 Cell (703)489

- 9115 Email: steve@hayes

- ent.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) 3DRobotics Iris+ User Manual 2) APM Copter http://copter.ardupilot.com / (open source flight controller firmware manual consists of multiple instructional pages) 3) Flight Log Template

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the pe tition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA ’ s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012

, I

, Steven L Hayes

, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

61.113(a) ; 61.113(b) ; 91.119(c) ; 91. 121 ; 91.151(a) ; 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) ; 91.409(a)(2) ; 91.417(a) & (b) ; In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, videography, and other flight operations that could be perform ed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of client s or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems.

So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333 t he conditions identified and proposed by the petitioner are drawn from references 1

- 3.The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons ; 61.113(a) & (b) ; The petitioner requ ests relief in order to facilitate the utilization of an experienced UAS

operator with the option of a trained observer. All pre

- flight inspection, maintenance and flight logs will be saved and made available to the FAA an d Secretary of Transportation ( SO T) for

review ; with the purpose of safely integrating civil UAS operation in the National Airspace System

. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be oper ated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “ congested areas ” and

“ densely populated ” . The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be operated over designated properties with the owner ’ s consent and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations for commercial operations in low

- risk , controlled

environments.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) , this section is inapplicable

since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric

sensor for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) and Exemption Nos. 2689, 5745, and 10650, prior relief has been granted for manned aircraft to operate at less than the prescribed minimums

. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining status in voltage to the PIC. The UA b atteries provide approximately 1 5 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when batte ry remaining reaches a

pre

- set level. Given the limitations on proposed operation s and the location of those proposed operations, t he FAA found that a reduced minimum power reserve for flight in daytime VFR

conditions was reasonable. 91.405(a) ; 91.407(a)(1) ; 91.409 (a)(1) & (2) ; 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), t he petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner ’ s operating documents and the conditions and limitations spec ified, describing the requirements for maintenance, inspection,

and record keeping, were sufficient to ensure that safety would not be adversely affected.The UAS

The 3D Robotics Iris+ is a consumer grade small rotorcraft in the quadcopter configuration

, weighing less than 5lbs, designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motor s with a dist ance between motors of approximately 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Batt ery life

limits flight times to approximately 1 5 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 12 minutes. More information is

available in attachment 1

.

Risk mitigation The petitioner has reviewed FAA exemptions reference ’ s 1

- 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airworthin ess will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. These

documents will be made available to the FAA and SO T to assist in future implementation of safety standards and regulations. The petitioner will only operate the UAS over designated properties with the owner ’ s consent. Flight plans will be predetermined to limit the UAS s flight

time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within

VLOS of the PIC and the observer.

Public interest

Use of the UAS in lieu of a m anned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to

facilitate commerc e could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be disp layed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for these purposes on a‘ for hire ’ basis acting as an independent contractor. A visual observer will be utilized. Flight data

including UA flight time, Control Unit o peration time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA via

traditional mean s or other means as required.

Conclusion The petitioner is requesting this exemption for the purposes of “ aerial photograph y, cinematography, videography , inspections and other flight operations ” . The reason for such a general and broad based request is that the petitioner wishes to utilize a business strateg y of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associa ted with additional exemptio ns. The petitioner's business model is based on the id ea of offering ad hoc small UAS services to individuals or companies who wish to e mploy these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has refrained from engaging in

commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer th ose services while remaining in compliance.

Respectfully,

Steven L Hayes