December 2 nd 2015

Name and address of Petitioner Andrew E. Edwards 36954 J Mechling Rd. Springfield, OR 97478 541

-844

-6080
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
RE: Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations.

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, the petitioner, requests 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) 14 CFR Title 14 Chapter 1 Subchapter D Parts 60 thru 67

-61.1 to 61.429 14 CFR 91.203 (a) & (b) The petitioner requests exemption from the above mentioned FARs for the following reasons; **61.113 (A) 7 {b):** Private Pilot Privileges and Limitations
T he regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1) has a pilot certificate or special purpose authorization issued under this part in that person's physica l posse ssion or readily accessible.The flight is only incidental to that business or employment. (3) The aircraft does not carry

passengers or property for compensation or hire. The Petitioner will follow all manufacturers' training program and safety manual. I also believe these requirements are unnecessary for pilot controlled drone flight. Additionally, current FAA proposals have omitted this as a future requirement for small UAS ' s. **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 operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The pet itioner 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 responsi ble operations with safety as the paramou nt concern in areas of subdivisions and neighborhoods if required. **91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) 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) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. 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 in percent to the PIC. The UA ba tteries provide approximately 20 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 battery remaining reaches a specified level. Give n the limitations on proposed operations and the location of those proposed operations, The 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), the 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 operating documents an d the conditions and limitations specified, describing the requirements for maintenance, inspection, and Record keeping, were sufficient to ensure that safety would not be adversely affected.
**14 CFR Title 14 Chapter 1 Subchapter D Parts 60 thru 67**  **- 61.1 to**  **61.429:** This section pertains to flight rules, pilot certificate requirements, manuals, etc. The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and current FSS proposals have omitted this as a future requirement for small UAS's.**14 CFR 91.203 (a) & (b** ): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows: No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under 19.715 is displayed at the cabin or cock pit entrance so that it is legible to passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, documentation will be housed at a ground control point where the pilot is flying the UAS for immediate access to the extent they are applicable to the UAS's. In doing some research the FAA has issued numerous exemptions to this regulation. **Risk mitigation** The petitioner has reviewed FAA exemptions reference's 1

-4 conditions and limitations section s and believe that the procedure s specified therein are reasonable and will be utilized in order to manage and mitigate risk to ensure public safety. Any operator under this exemption will be required to successfully pass a training course and prove competency from an instructor that is considered qualified for training among his/her peers and is consistent with the current industry standard s for safety and operation of UAS’s. Only trained and qualified operators shall operate the UAS. A preflight inspection as per man ufactures and operations manual will be conducted to document the UAS's airworthiness before each launch. The preflight inspection reports will be maintained on file

. Flight data including UA flight time, control unit operation time, incident, accident, an d data concerning deviations from normal operations will be documented and made available to FAA. A designated safety spotter will be present and in direct communication with UAS operator for all operations. Appropriate notification of operation be given to persons in and around the planned flight path area. **Public interest** Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact incurred with conventional aerial inspections. In addition, the use of UAS to facil itate commerce can help to encourage economic growth. UAS’s are a valued asset to reduce carbon emissions, improve service and safety when used for legitimate commercial activities while maintaining the highest regard for public safety. Operations for this petition will provide service to property owners, commercial and agricultural companies, and utilities etc. that are seeking a safe affordable alternative

. These services will facilitate increased awareness, commerce and enhance the development of UAS technology and its benefits as a reliable safe inspection resource. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risk. The petitioner will provide clients with the photograph ic data for these purposes in a for hire basis acting as an independent contractor and provide volunteer emergency response services

. **Services to be provided** Aerial surveying, videography and photography, wildlife monitoring, precision forestry and agric ultural services , ut ility infrastructure inspection, inspection of residential/commercial structures and volunteer search and rescue.**The UAS :** 

The DJI Phantom 3 Professional and DJI Inspsire V.2 are a highly successful and reliable commercial grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 7 lbs (2935 g) designed primarily to carry aloft a high definition camera. It has an advertised maximum spee d of less than 42 knots (22 m/s). 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. They are controlled via 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 fail safe 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. Battery life limits flight times to approximately 20 minutes. The onboard flight controller will warn the controller via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and return to landing zone will be initiated when the battery reaches a predetermined low state. **Conclusion** UAS’s which our company would use, under authorization by the US DOT

- FAA, are small, light

weight devices operated within the line of sight of the operator

- in

- Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, sea plane base, spaceport, or other lo cation with aviation activities. UAS’s have proven capability for controlled flight. They are devices offered for general sale on the market around the world

. Studies conducted by the FAA, about Section 332, Public Law 112

-95, 2014, have provided the FAA with the assurances on the airworthiness and safety features of UAS’s We look forward to your response.
Respectfully submitted,

Andrew E. Edwards