September 15, 2015

Submission by: Ronald Shelnutt

 6124 Hanover Chase Lane

 Indianapolis, In. 46239

 (317) 557-3686

 ronshelnutt@gmail.com

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

RE: Exemption request under 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations.

Dear Sir or Madam,

I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405, 91.407(a)(1),

91.409(a)(2) and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14CFR) was

granted in Exemption Numbers 11138, 11395, 11428 and 11434.

I will operate a DJI Phantom 3 Pro and an DJI Inspire 1. Both of these UAS will weigh under 10

pounds at take off. The operations performed by myself with the sUAS are to include but not

limited to real estate photography and videography both residential and commercial, event

coverage, aerial videography, search and rescue and for educational training. 

In the publics interest: The use of UAS reduces the need for conventional aircraft with

flammable fuel in populated areas and will now allow for safe and responsible aerial filming and

photography. The uses in which I plan on using these UAS would normally require some other

type of manned aircraft to complete. This unnecessarily puts those persons in the aircraft and

those on the ground at risk. Unfortunately in the past, both in real estate and in television,

catastrophic accidents have occurred, which have lead to the loss of life. These same shots

can now be achieved with a UAS at a very low risk.

Operations under this exemption will be conducted as outlined in the proposed rule set in

motion on 02/23/2015 in docket FAA-2015-0150.

Unmanned aircraft must weigh less than 55 lbs. (25 kg).

Visual line-of-sight (VLOS) only; the unmanned aircraft must remain

 within VLOS of the operator or visual observer.

At all times the small unmanned aircraft must remain close enough to

 the operator for the operator to be capable of seeing the aircraft with

 vision unaided by any device other than corrective lenses.

Small unmanned aircraft may not operate over any persons not directly
 involved in the operation.

Daylight-only operations (official sunrise to official sunset, local time).

Must yield right-of-way to other aircraft, manned or unmanned.

May use visual observer (VO) but not required.

First-person view camera cannot satisfy “see-and-avoid” requirement

 but can be used as long as requirement is satisfied in other ways.

Maximum airspeed of 100 mph (87 knots).

Maximum altitude of 500 feet above ground level.

Minimum weather visibility of 3 miles from control station.

No operations are allowed in Class A (18,000 feet & above) airspace.

Operations in Class B, C, D and E airspace are allowed with the

 required ATC permission.

Operations in Class G airspace are allowed without ATC permission

No person may act as an operator or VO for more than one unmanned

 aircraft operation at one time.

No careless or reckless operations.

Requires preflight inspection by the operator.

A person may not operate a small unmanned aircraft if he or she knows

 or has reason to know of any physical or mental condition that would

 interfere with the safe operation of a small UAS.

Proposes a microUAS option that would allow operations in Class G

 airspace, over people not involved in the operation, provided the operator certifies he or she 

has the requisite aeronautical knowledge to perform the operation. 

I request an exemption from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b)

Maintenance Inspections since they only apply to aircraft with an airworthiness certificate. I will,

however, perform a preflight inspection of my sUAS before each flight as outlined in the

operating documents.

I request exemption from §91.151. The pilot in Command will abide by the following personal

protocols and controls:

Operator will only operate in reasonably safe environments that are strictly controlled, are

away from power lines, elevated lights and airports. Operator will conduct extensive preflight

inspections and protocols as outlined in the operating documents.

Operate the UAS below 500 feet and within a radius distance of 1500 feet from the controller 

while maintaining direct line of sight. (VLOS)

Land the UAS before the manufacturers recommended minimum battery level.

Have procedures in place to abort flights in the event of safety concerns or potential danger.

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that

since there is currently no certificate applicable to my operation, this regulation is inapplicable.
91.119 prescribes safe altitude for the operation of civil aircraft, but it allows helicopters to be

operated at a lower altitudes in certain conditions. Operator will not operate the sUAS above

500 feet above ground level (AGL) and will also only operate in safe areas away from the public

and traffic, thus providing a level of safety at least equivalent to or below those in relation to

minimum safe altitudes.

91.121 Altimeter settings are inapplicable since the DJI Phantom 3 and Inspire 1 utilize

electronic GPS with a barometer sensor.

Ronald Shelnutt