December 2nd 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

The 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 physical possession 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 

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 with safety as the paramount 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 batteries 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. Given 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 and 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 cockpit 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 sections and believe that the procedures 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 standards for safety and operation of UAS’s. Only trained and qualified operators 

shall operate the UAS. A preflight inspection as per manufactures 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, and 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 

facilitate 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 photographic 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 

agricultural services, utility 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 (2935g) designed primarily to carry aloft a high definition camera. It has an advertised 

maximum speed of less than 42 knots (22m/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, lightweight 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, seaplane base, spaceport, or 

other location 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