Richard P. Gamble

–Section 333 Exemption

Petition P a g e | **1** U. S. Department of Transportation Docket ManagementSystem 1200 New Jersey Ave, SE Washington, DC 20590 January 28, 2016 **RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation**  **Regulations** Dear Sir or Madam; In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, I, Richard P. Gamble request exemption from the Federal Aviation Regulations to allow for commercial operations of a DJI Phantom 3 Standard, Unmanned Aerial System (UAS) for purposes of training other operators of a UAS in the National Airspace System (NAS), aerial photography and videography; but only 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 or Section 49 USC § 44701. **Applicant:** Richard P. Gamble 121 Peterson Drive P.O. Box 137 Sweetser, IN 46987 romeogolf70@hotmail

.com **Qualifications:** FAA Issued Airline Transport Pilot Certificate No. 2928921

-Airplane Multi

-Engine Land

-EMB 145 SIC Privileges FAA Issued Commercial Pilot Certificate No.2928921

-Airplane Single Engine Land; Instrument Airplane FAA Issued Flight Instructor Certificate No. 2928921CFI

-Airplane Single and Multi

-Engine Land; Instrument Airplane **Experience:** Chautauqua Airlines (CHQ)

– FirstOfficer Purdue University

–Assistant Chief FlightInstructor Part 141 Flight School Aircraft Owner: Cessna 150 Member Sweetser Indiana Town Council (Reelected to second term November 2015)Richard P. Gamble

–Section 333 Exemption

Petition P a g e | **2 Attachments:**  1. DJI Phantom 3Standard UserManual 2. DJI Phantom 3Standard Quick StartGuide 3. DJI Phantom 3Standard Release Notes 4. DJI Phantom 3 Safety Guidelines Disclaimer 5. DJI Phantom Pilot TrainingGuide 6. Intelligent Flight Battery SafetyGuidelines **Regulations from which the exemption is requested:**  14 CFR 21, Subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (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 91.119 (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 91.409 (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 UAS and its operation, I, Richard P. Gamble request relief from 14 CFR part 21, Subpart H, and any associated noise certification and testing requirements of part 36. The UAS will carry neither pilot, passenger, explosive materials nor 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 entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two
-inch lettering will be impossible.The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety 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 61.113 (a) & (b) & 14 CFR 61.133 (a) -**  Since the UAS will not carry a pilot or passengers I, Richard P. Gamble request a relieffrom these regulations. Any pilot in command or (PIC) operating the UAS will hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will be utilized and required to communicate verbally 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 aircraftoperations.Richard P. Gamble

–Section 333 Exemption

Petition P a g e | **3 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 FAA regulatory standard exists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to each flight, an equivalent level of safety will be provided. All flights will be in accordance with the safety and maintenance recommendations found in the DJI Phantom 3attachments. **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 adequately carry a flight manual. An equivalent level of safety will be maintained by 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 FAA approved flight manuals will be provided for the aircraft an exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight battery requirements, checking takeoff and landing distances along with those found in the attached "DJI Pilot Training" will be implemented. These actions will provide an equivalent or higher level ofsafety. **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 safety will be achieved using the real time ground station data and given the UAS will carry neither a pilot nor passengers. **14 CFR 91.119 (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 traffic 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 of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher level of safety will beachieved. **14 CFR**  **91.121 -**  As the UAS may not have a barometric altimeter, but instead a GPS barometric sensor for altitude information an exemption may be required. An equivalent level of safety will be achieved using a ground station which links to a telemetry data link. This will provide the pilot with live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator prior toflight. **14 CFR**  **91.151 (a)**  **-** The UAS has a limited range and will be limited to operations in a controlled environment. The battery power the UAS provides approximately 25 minutes of flight time. The UAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption. An equivalent level of safety will be achieved by monitoring the battery through the ground station and landing with a minimum of 30 percent battery powerremaining. **14 CFR 91.203 (a) & (b) -**  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 adequately carry a flight manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it.Richard P. Gamble

–Section 333 Exemption

Petition P a g e | **4** Given the following sections only apply to aircraft with an airworthiness certificate; these sections do not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS is in working condition before initiating eachflight: 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) **Equivalent Level of Safety**  In addition to the safety standards mentioned above the UAS will adhere to the following additional guidelines: 1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic Control has been established. 2. Flights will not exceed an airspeed of 36 mph (31.3 knots) 3. Flights will be operated at or below an altitude never exceeding 400 feetAGL. 4. The PIC and VO will communicate verbally at alltimes. 5. UAS operations will not be conducted during night. 6. All operations will be conducted under visual meteorologicalconditions. 7. The UAS will land with a minimum 30 percent battery reserveremaining. 8. The UAS will only be piloted within visual line ofsight. 9. The UAS will utilize an internal flight safety 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 alloperations. 11. The UAS will abort flight in the event of unpredictable obstacles oremergencies. **Public Interest**  I, Richard P. Gamble, believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carrying a crew and flammablefuel. As a professional aviator I experience the need to keep our skies safe. Therefore, my primary role will be to educate and train existing and future operators with their UAS in the NAS. These operators will no doubt be flying UAS with cameras and such the need to educate them as to their operation while maintaining the privacy of their neighbors. **Privacy** All flights will occur over private or controlled areas with the owner's consent. Capturing people in images will rarely occur. If a person is captured in a collected image they will have consented prior to filming or otherwise have agreed to be in the area prior to the filming takingplace. Sincerely, Richard P. Gamble